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Privacy Policy

 

I. General

  1. Scope

This privacy policy relates to the following topics:

 

The Privacy Policy for the FAZUA App can be found here.

 

  1. Body responsible for data processing (“controller”)

We take the protection of your personal data and the legal obligations to ensure data protection very seriously. The law requires full transparency regarding the processing of personal data. You as a data subject can only understand the details of the processing if you are duly informed about the purpose, nature and scope of the processing.

The body responsible for the data processing, i.e. the controller within the meaning of the General Data Protection Regulation (GDPR) is

Porsche eBike Performance GmbH
Marie-Curie-Straße 6
85521 Ottobrun
Germany
Tel.: +49 (0)89 / 540462-100
Mail: contact@porsche-ep.com

referred to hereinafter as "controller" or “we”.

You can contact our data protection officer at:
dpo@porsche-ep.com

 

  1. Definitions

The terms used in this privacy policy (e.g. data categories, purposes and legitimate interests, as well as terms from the GDPR) are explained in the section "Definition of terms" (IX.).

 

  1. Information on data processing

We only process personal data to the extent permitted by law. We only disclose or transfer personal data to third parties in the cases described below. The personal data are protected by appropriate technical and organisational measures (e.g. pseudonymisation, encryption).

Except where we are obliged by law to store the data or disclose or transfer them to third parties (including but not limited to prosecuting authorities), the decision which personal data we process and for how long and to which extent we may disclose or transfer them to third parties depends on the specific website features you use from time to time.

 

  1. Storage duration

The personal data will be deleted as soon as the purpose of the processing is no longer applicable or another reason for deletion pursuant to Art. 17 para. 1 GDPR applies (e.g. you have revoked your consent given to us). In exceptional cases, we may nevertheless continue to process your personal data if an exception to the deletion obligation applies, in particular pursuant to Art. 17 para. 3 GDPR or another law (e.g. there is a statutory storage obligation).

If we need to provide information about the storage duration of cookies and similar technologies, you will find the relevant details in our consent tool, which you can access here.

Personal data that we process as part of an application (see below) will be stored for a period of DURATION after completion of the application process.

 

  1. Automated individual decision-making, including profiling

Automated individual decision-making including profiling does not take place.

 

  1. Data subjects‘ rights

As a data subject you have the right of access/ right to information under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR and the right to data portability under Art. 20 GDPR.

You have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

The supervisory authority responsible for us/our headquarters is:

Bayerisches Landesamt für Datenschutzaufsicht
Promenade 18
91522 Ansbach
However, you are free to file a complaint with any other data protection supervisory authority

 

  1. Controller’s notification obligations

We will communicate any rectification or erasure of your personal data or restriction of processing carried out in accordance with Art. 16, Art. 17 (1) and Art. 18 GDPR to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request it.

 

  1. Obligation to provide or disclose data

Unless stated otherwise in the explanations below regarding the applicable legal basis, you are not obliged to provide or disclose personal data to us. However, in the cases referred to in Art. 6 (1) (b) GDPR, the personal data are necessary for entering into or performing a contract. If you do not provide use with the relevant personal data, it will be impossible for us to enter into, or perform, the contract. If you do not provide us with the data in the cases referred to in Art. 6 (1) (a) and (f) GDPR, you will not be able to use the respective parts of our website.

 

  1. Transfer of data to third countries

Data transfers to third countries outside the European Union (EU) and the European Economic Area (EEA) are only permitted in compliance with the special provisions of Art. 44 et seq. GDPR. If such a third country transfer occurs when processing your personal data, we will inform you below about the third country transfer and the basis for the transfer.

General information on the basis of the transfer:

If the transfer is based on an exception pursuant to Art. 49 GDPR, you will find the details at the relevant point.

If the transfer is based on an adequacy decision within the meaning of Art. 45 GDPR, you will find an overview of the adequacy decisions here:

If If the transfer is based on so-called standard contractual clauses of the EU Commission within the meaning of Art. 46 (2) (c) GDPR, you can find the implementing decision 2021/914 of the EU Commission, which contains the standard contractual clauses, here:

If the transfer is based on binding corporate rules (BCR) within the meaning of Art. 46 (2) (b) GDPR, you can find an overview of the published BCR here:

 

  1. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 (1) (1) (f) GDPR. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. The objection is not subject to formal requirements and should be sent to the contact data stated above.

 

  1. Revocation of consent

Pursuant to Art. 7 (3) sentence 1 GDPR, you have the right to withdraw your consent by mail or email, without observing any other formal requirements, at any time with effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After you have withdrawn your consent, we will delete the personal data we have processed based on your consent unless there is another legal basis for the processing of these data.

The withdrawal is not subject to formal requirements and should be sent to the contact data stated above.

 

II. Interaction of the privacy policy and the cookie policy

The privacy policy informs you about data processing on the basis of the provisions of the GDPR. If you are searching for information on storing or reading data on your end device, you will find the relevant information in the consent tool and in the cookie policy.

 

III. Use of our website(s)

The use of the website(s) and its functions regularly requires the processing of personal data. Unless otherwise indicated, the following statements refer to all websites that we operate and that refer to this privacy policy.

Please note that links on our website may take you to other websites that are not operated by us, but by third parties. Such links are either clearly marked by us or are recognizable by a change in the address line of your browser. We are not responsible for compliance with data protection regulations and the secure handling of your personal data on these websites operated by third parties.

Unless otherwise stated, the information on processing activities applies to all websites. Where sections only apply to certain pages, this is noted in brackets as follows:

Label

Website

Porsche eBike Performance

https://www.porsche-ebike-performance.com

FAZUA

https://fazua.com/

B2C-Shop

https://shop.fazua.com

B2B-Shop

https://shop-b2b.fazua.com

Dealer Portal

https://dealer.fazua.com/

 

Use of our website
Purpose of processing: Advertising and personalized marketing measures, Information security
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; customer acquisition, customer retention, customer recovery; promotion of sales activities; operation, integrity and security of digital products
Data categories: Usage data, connection data
Recipients of data: IT service providers
Intended third country transfer: in individual cases third countries (based on adequacy decision of the EU commission, standard contractual clauses)

Online store (B2C store, B2B store)
Purpose of processing: Purchase order execution and contract management, advertising and personalized marketing measures
Legal basis: Art. 6 (1) (1) (b), (f) GDPR
Legitimate interests: Design, operation and availability of digital products; customer acquisition, customer retention, customer recovery; promotion of sales activities; operation, integrity and security of digital products
Data categories: Master data, contact data, content data, contract data, payment data, usage data and connection data
Recipient of data: IT service provider
Intended third country transfer: in individual cases third countries (based on adequacy decision of the EU commission, standard contractual clauses)

Subscription to our personalized newsletter and other mailings (Porsche eBike Performance, FAZUA, B2C store, B2B store)
Purpose of processing: Advertising and personalized marketing measures, user, prospect and/or customer support, analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (a), (f) GDPR
Legitimate interests: Customer acquisition, customer retention, customer recovery, promotion of sales activities, promotion of economic interests, advertising and image improvement, market and opinion research
Data categories: Master data, contact data and connection data
Recipient of data: IT service provider
Intended third country transfer: in individual cases third countries (based on standard contractual clauses)

Customer account (B2C store, B2B store)
Purpose of processing: Advertising and personalized marketing measures, Purchase order execution and contract management
Legal basis: Art. 6 (1) (1) (b), (f) GDPR
Legitimate interests: Design, operation and availability of digital products; customer acquisition, customer retention, customer recovery; promotion of sales activities; operation, integrity and security of digital products
Data categories: Connection data, content data, master data if applicable and contact data if applicable
Recipients of the data: (IT) service providers
Intended third country transfer: In individual cases, third countries (on the basis of standard data protection clauses and on the basis of adequacy decisions)

Use of contact forms and support requests
Purpose of processing: User, prospect and/or customer support
Legal basis: Art. 6 (1) (1) (f) GDPR; Art. 6 (1) (1) (b) GDPR (if the request leads to the conclusion of a contract at a later date or concerns an existing contract)
Legitimate interests: Integration of desired or required functionalities; promotion of economic interests; analysis and optimization of our own offers, services and advertising measures; customer acquisition, customer retention, customer recovery
Data categories: connection data, content data, in some cases master data and contact data
Recipients of data: IT service providers
Intended third country transfer: in individual cases third countries (based on adequacy decision of the EU commission, standard contractual clauses)

Payment services (B2C store, B2B store)
Purpose of processing: Purchase order execution and contract management, Identity and/or creditworthiness check
Legal basis: Art. 6 (1) (1) (b), (f) GDPR
Legitimate interests: Prevention of criminal offenses, administrative offenses and other detrimental actions
Data categories: contact data, master data, contract data if applicable, payment data, usage data if applicable, connection data if applicable
Recipients of the data: Banks and other financial service providers
Intended third country transfer: None

 

Consent management
Purpose of processing: Legal affairs and compliance measures, information security
Legal basis: Art. 6 (1) (1) (c), (f) GDPR
Data categories: master data, contact data, usage data, connection data (if applicable)
Legitimate interests: Prevention of criminal offenses, administrative offenses and other detrimental actions, integration of desired or required functionalities
Recipient of the data: IT service provider
Intended third country transfer: None

Marketing measures
Purpose of processing: Advertising and personalized marketing activities.
Legal basis: : Art. 6 (1) (1) (a), (f) GDPR
Legitimate interests: promotion of economic interests; advertising and image improvement, market and opinion research, analysis and optimization of our own offers, services and advertising measures
Data categories: Usage data, connection data
Data recipients: IT service providers, operators of advertising networks and advertising partners
Intended third country transfer: Depending on the services used, for details see Cookie Policy or Consent Tool.

Analysis and performance measurement
Purpose of processing: Analysis and Performance measurement as well as optimization of products and/or services; advertising and personalized marketing activities
Legal basis: Art. 6 (1) (1) (a), (f) GDPR
Legitimate interests: advertising and image improvement, market and opinion research; promotion of economic interests; advertising and image improvement, market and opinion research
Data categories: usage data, connection data, in some cases content data
Recipients of data: IT service providers
Intended third country transfer: depending on the service used, for details see our Cookie Policy.

Integration of external fonts
Purpose of processing: Advertising and personalized marketing activities
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products
Data categories: connection data
Recipients of data: IT service providers
Intended third country transfer: in individual cases third countries (based on adequacy decision of the EU commission)

Integration of external contents (photos, videos and other content)
Purpose of processing:
 Advertising and personalized marketing activities
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; Integration of desired or required functionalities; customer acquisition, customer retention, customer recovery
Data categories: connection data; in some cases usage data
Recipients of data: IT service providers
Intended third country transfer: in individual cases USA (based on adequacy decision of the EU commission)

Download area (Dealer Portal)
Purpose of processing:
 Purchase order execution and contract management
Legal basis: Art. 6 (1) (1) (b), (f) GDPR
Legitimate interests: Promotion of sales activities, integration of desired or required functionalities
Data categories: Usage data, connection data, possibly content data
Recipient of the data: IT service provider
Intended third country transfer: None

 

IV. Processing of applications (Jobs and career)

Processing of applicantions
Purpose of processing: Applicant management
Legal basis: Art. 6 para. 1 sentence 1 letter b GDPR in conjunction with § 26 para. 1 sentence 1 BDSG; for the forwarding of your application to affiliated companies Art. 6 para. 1 sentence 1 letter a GDPR in conjunction with § 26 para. 1 sentence 1, para. 2 BDSG.
Data categories: Master data, contact data, content data, contract data, applicant and employee data, possibly connection data, in some cases also usage data and possibly special categories of personal data within the meaning of Art. 9 (1) GDPR (depending on the specific job advertisement; we will only store the data relating to your application that you provide to us and that we are permitted to process for the purpose of processing an application))
Recipient of the data: IT service providers; if relevant affiliated companies (depending on the consent)
Intended transfer to third countries: None

Management of a talent pool
Purpose of processing: Applicant management
Legal basis: Art. 6 para. 1 sentence 1 letter a GDPR in conjunction with § 26 para. 1 sentence 1, para. 2 BDSG
Data categories: Master data, contact data, content data, contract data, applicant and employee data, possibly connection data, in some cases also usage data and possibly special categories of personal data within the meaning of Art. 9 (1) GDPR (we will only store the data relating to possible future job openings that you provide to us and that we are permitted to process for the purpose of processing an application))
Recipient of the data: IT service providers
Intended third country transfer: None

 

V. Trainings and other events (online and offline)

Data processing for events
Purpose of processing: Event management, Purchase order execution and contract management, User, prospect and/or customer support, information security.
Legal basis: Art. 6 (1) (1) (c), (f) GDPR
Legitimate interests: Promotion of sales activities, advertising and image improvement, market and opinion research, design, operation and availability of digital products, operation, integrity and security of digital products, integration of desired or required functionalities
Data categories: master data, contact data, content data, usage data, connection data, payment data, location data
Recipients of the data: (IT) service providers.
Intended third country transfer: In individual cases USA and other third countries (on the basis of adequacy decisions)

 

VI. Application and certification for service partners (B2B)

Application and certification
Purpose of processing: Purchase order execution and contract management, user, prospect and/or customer support
Legal basis: Art. 6 (1) (1) (b), (f) GDPR
Permitted interests: Promotion of sales activities, advertising and image improvement, market and opinion research, design, operation and availability of digital products, operation, integrity and security of digital products, integration of desired or required functionalities
Data categories: Master data, contact data, content data, usage data, connection data, payment data, location data
Recipients of the data: IT service provider
Intended third country transfer: None

 

VII. Information on external sites

The use of external sites and their functions regularly requires the processing of personal data. Unless otherwise indicated, the following statements refer to all external sites that we operate and which link to this privacy policy.

Facebook
Purpose of processing: Advertising and personalized marketing activities; analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; advertising and image improvement, market and opinion research; customer acquisition, customer retention, customer recovery
Data categories: Master data, contact data, content data, usage data, connection data, in some cases location data
Recipients of data: Platform operators and media (Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland („Meta“)
Intended third country transfer: in individual cases USA and other third countries (based on standard contractual clauses or adequacy decisions of the EU commission)

Instagram
Purpose of processing: Advertising and personalized marketing activities; analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; advertising and image improvement, market and opinion research; customer acquisition, customer retention, customer recovery
Data categories: Master data, contact data, content data, usage data, connection data, in some cases location data
Recipients of data: Platform operators and media (Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland („Meta“)
Intended third country transfer: in individual cases USA and other third countries (based on standard contractual clauses or adequacy decisions of the EU commission)

LinkedIn (Profil)
Purpose of processing: Advertising and personalized marketing activities; analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; advertising and image improvement, market and opinion research; customer acquisition, customer retention, customer recovery
Data categories: Master data, contact data, content data, usage data, connection data, in some cases location data
Recipients of data: Platform operators and media (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland (“LinkedIn“))
Intended third country transfer: in individual cases USA and other third countries (based on standard contractual clauses or adequacy decisions of the EU commission)

X (Twitter)
Purpose of processing: Advertising and personalized marketing activities; analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; advertising and image improvement, market and opinion research; customer acquisition, customer retention, customer recovery
Data categories: Master data, contact data, content data, usage data, connection data, in some cases location data
Recipients of data: Platform operators and media (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Irland („Twitter“))
Intended third country transfer: in individual cases USA and other third countries

YouTube Channel
Purpose of processing: Advertising and personalized marketing activities; analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; advertising and image improvement, market and opinion research; customer acquisition, customer retention, customer recovery
Data categories: Master data, contact data, content data, usage data, connection data, in some cases location data
Recipients of data: Platform operators and media (Google Ireland Ltd., Gordon House, Barrow Street Dublin 4, Irland ("Google"))
Intended third country transfer: in individual cases USA and other third countries

TikTok
Purpose of processing: Advertising and personalized marketing activities; analysis and Performance measurement as well as optimization of products and/or services
Legal basis: Art. 6 (1) (1) (f) GDPR
Legitimate interests: Design, operation and availability of digital products; advertising and image improvement, market and opinion research; customer acquisition, customer retention, customer recovery
Data categories: Master data, contact data, content data, usage data, connection data, in some cases location data
Recipients of the data:Platform operator and media (TikTok Information Technologies UK Limited, WeWork, 125 Kingsway, London, WC2B 6NH, London, England ("TikTok UK") and TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland ("TikTok Ireland") as joint controllers ("TikTok")
Intended third country transfer:In individual cases third countries

 

Information regarding joint controllers

n the cases listed below, we are jointly responsible with another body within the meaning of Art. 4 No. 7, 26 GDPR. You are free to contact any of the joint controllers directly with your request. Depending on the specific agreement on data subject rights with the other entity, we will forward your request to the other entity.

Operation of our Facebook page(s)
As part of the operation of our Facebook page(s), there is a joint responsibility with Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Meta").
The essence of the agreement can be found here: https://www.facebook.com/legal/terms/page_controller_addendum.
Facebook is responsible for implementing your data subject rights.
Facebook will inform you about your rights as a data subject at: https://www.facebook.com/legal/terms/information_about_page_insights_data

Operation of our Instagram page(s)
As part of the operation of our Facebook page(s), there is a joint responsibility with Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Meta").
The essence of the agreement can be found here: https://www.facebook.com/legal/terms/page_controller_addendum.
Facebook is responsible for implementing your data subject rights.
Facebook will inform you about your rights as a data subject at: https://www.facebook.com/legal/terms/information_about_page_insights_data

Operation of our LinkedIn page(s)
As part of the operation of our LinkedIn page, there is a joint responsibility with LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland).
The essence of the agreement can be found here: https://legal.linkedin.com/pages-joint-controller-addendum
LinkedIn is responsible for implementing your data subject rights..
LinkedIn will inform you about your rights as a data subject at: www.linkedin.com/legal/privacy-policy.

Operation of our TikTok page(s)
As part of the operation of our TikTok site(s), we have a joint responsibility with TikTok Information Technologies UK Limited, WeWork, 125 Kingsway, London, WC2B 6NH, London, England ("TikTok UK") and TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland ("TikTok Ireland").
The essence of the agreement can be found here: ads.tiktok.com/i18n/official/article?aid=300871706948451871
TikTok is responsible for the implementation of your data subject rights (see the overview of responsibilities under the above link).
TikTok will inform you about your data subject rights at:  www.tiktok.com/safety/de-de/privacy-and-security-on-tiktok/

Marketing measures (Facebook Custom Audiences)
In the context of our marketing measures via the "Facebook Custom Audiences" service, there is joint responsibility with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2. This relates to the processing of event data for the targeting of advertisements, for the improvement of ad delivery and personalization of functions and content, as well as the delivery of commercial and transaction-related data, if applicable.
The essence of the concluded agreement (including information on the implementation of your data subject rights) can be found here:https://www.facebook.com/legal/controller_addendum
Further information on the processing of personal data by Facebook, the legal basis on which Facebook bases the processing and the exercise of data subject rights vis-à-vis Facebook can be found athttps://www.facebook.com/about/privacy

 

IX. Definition of terms

The terms used in this privacy policy (e.g. data categories, purposes and legitimate interests, as well as terms from the GDPR) are explained in the "Definition of terms" section.

From the GDPR
This privacy policy uses the terms of the legal text of the GDPR. You can view the definitions (Art. 4 GDPR), for example, at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679 .

Further definitions

Data Categories
When we specify the categories of data processed, this refers in particular to the following data:

 

Purposes of data processing
In the following sections, to improve comprehensibility and readability, we indicate the purposes pursued as purpose categories. In some cases, there may be overlaps with our "legitimate interests" (see definitions below). This is in the nature of things.

Unless otherwise stated, the purposes are to be understood as follows:

Legitimate interests
In the following sections, we state our legitimate interests within the meaning of Art. 6 (1) (1) (f) GDPR as categories to improve comprehensibility and readability. In some cases, there may be overlaps with our "purposes" (see the definitions above). This is in the nature of things.

Unless otherwise stated, the stated legitimate interests are to be understood as f Promotion of sales activities: e.g. promotion of our sales by analyzing and evaluating the demand of our customers, analysis of the interests and buying and demand behavior of our prospects, users and/or customers.

Categories of recipients
In the following section, we list the categories of recipients that we use in our privacy policy:

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