Last updated 07/2022
In this Privacy Policy, we, AMAG Group AG, explain how our subsidiaries (AMAG Import Ltd, AMAG Automobil- und Motoren Ltd, AMAG Leasing AG, AMAG Services AG, AMAG Parking AG, AMAG Corporate Services AG, AMAG First AG and mobilog Ltd) and partners (hereinafter individually or collectively referred to as AMAG) collect and process personal data.
AMAG places a high priority on the security of your data. For this reason, we process your personal data only in accordance with the data protection laws that apply to us.
Unless stated otherwise, the controller for data processing within the meaning of data protection is AMAG Group AG.
Please send data protection enquiries to:
AMAG Group AG
Legal & Compliance
Data protection
Alte Steinhauserstrasse 12
6330 Cham, Switzerland
Or by e-mail to privacy@amag.ch
Our representative in the EEA in accordance with Art. 27 of the GDPR is: AMAG (Vaduz) AG, Austrasse 37, LI-9490 Vaduz.
When you visit our website, or when you use our services, or when you apply for a job with us, your personal data is collected and processed. This affects the following data in particular and is undertaken in the following situations for the purposes listed below.
We use the personal data collected by us to conclude and execute contracts with you, in particular for vehicle sales, repairs, financing and leasing of vehicles and for the purchase of products and provision of services by our suppliers and their subcontractors, as well as to comply with our legal obligations. In addition, we process personal data to the extent that this is in our legitimate interests.
Please note that data processing by our brand partners may be carried out under their own data protection responsibility, over which we have no influence. More information about data protection can be found in the privacy policy of the relevant brand partner.
When you visit our website, we and the service providers commissioned by us will process your personal data for operational and performance purposes, as well as to optimise and further develop our service.
When you access the website, our system will automatically collect data and information. This includes:
• Information about the type of browser and the version used
• The user’s operating system;
• Information about the type of device;
• The user’s internet service provider;
• The user’s IP address;
• Date, time and duration of the access;
• Websites from which the user’s system accesses our website;
• Websites that are accessed by the user’s system via our website.
We process this data under our legitimate interest in the optimal provision of our website, in particular for analysis of how visitors use this website; the data is also evaluated for statistical purposes and for internal measures aimed at improving security and quality.
Cookies & analysis and tracking tools
We use “cookies” on our websites, with which your browser or your device can be identified. A cookie is a small file that is sent to your computer or automatically saved to your computer or mobile device by the web browser you use when you visit our website or install our app. At the beginning of your website visit, you can select the desired cookies in our preference centre and can give your consent to the processing or your data. You can object to the data processing at any time, with effect for the future, by adjusting the settings in your browser to prevent the storage of cookies, or by changing your consents that are saved in the preference centre.
You can find more information in our Cookie Policy.
Google Analytics
We use Google Analytics to analyse website usage and optimise advertising.
Google Analytics is a web analysis service operated and provided by Alphabet Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States). Google processes the data for website use on our behalf and contractually undertakes to take measures to ensure the confidentiality of the data processed. Since the USA does not have an adequate level of data protection according to the European Court of Justice, there are risks associated with the transfer of data (access to data by US authorities, lack of legal remedies) and corresponding EU standard data protection clauses have been concluded as safeguards for data processing.
The following data is recorded during your visit to the website:
• Pages viewed
• Your behaviour on the pages (e.g. length of time spent, clicks, scrolling behaviour)
• Technical information, such as browser, internet provider, device and screen resolution
• Source of your visit (i.e. via which website or advertisement you came to us)
Your IP address will be anonymised.
The recorded data is stored together with a randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after two months. Other data is stored in aggregated form for an indefinite period.
If you do not agree to this data being collected, you can prevent it through the one-off installation of the browser add-on to disable Google Analytics or by rejecting cookies via our cookie settings.
Google Maps
Our websites may include the Google Maps service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as “Google”). The integration of Google Maps creates a direct connection to the Google servers and to your browser. This makes it possible to display the Google Maps map. By integrating and using the Google Maps map, your IP address and information about the use of the maps by your browser are transmitted to Google for independent data processing. Google also processes the search terms entered by you on the Google Maps map (e.g. location, postcode or name of dealer) as well as your current location, provided that you have given your express consent via the Google Maps application. The Google Maps map also integrates Google Fonts. These are fonts provided by Google. In order to display the Google Fonts on the Google Maps map, a connection is also established from your browser to the Google server and your IP address is transmitted by your browser to Google for independent data processing. Further information about data processing and the possible transfer of personal data by Google to third countries (e.g. the USA) can be found in Google’s privacy policy (Datenschutzerklärung – Datenschutzerklärung & Nutzungsbedingungen – Google) .
Adobe Analytics
This website uses the web analytics service Adobe Analytics provided by Adobe Systems Software Ireland Limited (4–6, Riverwalk Drive, Citywest Business Campus, Cooldown Commons, Dublin 24, D24 DCW0, Ireland) to evaluate user access to this website. The data is processed on the basis of the consent given by you in the cookie settings.
Cookies are stored on your end device for the purpose of evaluation and information is collected about this, which is also stored on the servers of our processor Adobe Systems Software Ireland Limited (“Adobe”). Access to the information by Adobe Systems Incorporated, based in the United States, cannot be excluded and corresponding EU standard data protection clauses have been concluded as appropriate safeguards for data processing in non-European countries.
The information stored on Adobe servers cannot be directly linked to a person, as Adobe Analytics uses the settings “Before Geo-Lookup: Replace visitor’s last IP octet with 0” and “Obfuscate IP-Removed”. The setting “Before Geo-Lookup: Replace visitor’s last IP octet with 0” ensures that the IP address is anonymised before this so-called geolocation by replacing the last octet of the IP address with zeros. The user’s approximate location is added to the tracking package, which still contains the complete IP address, for statistical analysis. Before storing the tracking package, the IP address is replaced by a single fixed IP address – this is referred to as a generic IP address – if the setting “Obfuscate IP -Removed” is configured. This means that the IP address is no longer included in the saved dataset.
Microsoft Bing Ads
We may use conversion tracking on our websites, provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft Bing Ads stores a cookie on your computer if you have accessed our website via a Microsoft Bing ad. This allows us and Microsoft Bing to see that someone has clicked on an ad, been redirected to our website and reached a pre-determined target page (conversion page). We only find out the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No personal information about the identity of the user is disclosed.
If you do not want information about your behaviour to be used by Microsoft as explained above, you can refuse to allow the necessary cookies to be set – for example, by changing your browser setting that generally disables the automatic setting of cookies. You can also prevent the collection of the data generated by the cookie and relating to your use of the website and the processing of this data by Microsoft by using the following link: https://account.microsoft.com/privacy/ad-settings/signedout?lang=en-GB to confirm your objection. Further information about data protection and the cookies used by Microsoft and Bing Ads can be found on the Microsoft website at https://privacy.microsoft.com/en-gb/privacystatement
Hotjar
We use the Hotjar analysis tool on our websites to analyse your user behaviour. Your data is processed on the basis of your consent given in your cookie settings.
Hotjar uses cookies and tracking codes to collect your user data on our websites on our behalf. The following information is collected:
• the IP address of the device,
• the type of device,
• the size of the device’s screen,
• the geographical location,
• the language used on the website,
• the referring domain and
• date and time of the website visit.
Your data is stored on servers in Ireland.
Social media
For social media, we use the so-called “Shariff” solution. By using Shariff, you yourself can decide whether and when data is transferred to the operators of the relevant social networks. When you access our websites, generally no data is therefore automatically transferred to social networks such as Facebook, YouTube and Twitter. Only when you yourself actively click on the relevant button will your web browser make a connection with the servers of the relevant social network. Only by clicking the icon do you consent to your web browser connecting to the servers of the relevant social network and transferring usage data to the relevant operator of the social network.
When you contact us via our website or want to use our online services, you may register with us. We or third parties commissioned by us will then process information about you in our customer database, which depending on the service may include:
• Name and contact data,
• Address data,
• Vehicle data,
• Preferred garage and brand,
• Payment details,
• Insurance data,
• Credit score data and
• Interests.
We will do so in order to provide you with the service as offered. The processing is undertaken on the basis of your consent, a contractual relationship or our legitimate interest.
Under some circumstances, your data will be disclosed to the following categories of recipients:
- Contractual and business partners
- Manufacturers
- IT service providers
- Marketing service providers
You can use the following online services:
Online registration
If you want to use our online services via our websites, you can do this by creating a user account. We offer the following options:
Registration / logging in using the AMAG ID
You can use your AMAG ID to sign into a wide range of AMAG Group Ltd services. It serves as a central user account in which you can manage your identity data, account data, consent and notification settings. The following personal data is required for registration:
• Title
• First name
• Last name
• E-mail address
• Password (when opening a user account)
Registration / logging in using Volkswagen ID
If you use your Volkswagen ID, the service you have selected will be linked to your Volkswagen ID user account. This link only occurs if you have given your consent (Art. 6(1)(1)(a) GDPR). Further information about data processing in the context of the Volkswagen ID can be found in the privacy policy at https://vwid.vwgroup.io/data-privacy.
Registration / logging in using SwissID
You have the option of registering or logging in to OneLog using your SwissID – a standardised, nationwide Swiss login offered by SwissSign Group AG (hereinafter referred to as “SwissSign”). If you do so, we will be sent the personal data required for registration or login from SwissSign Group AG (title, first name, last name, e-mail address).
If you use your SwissID, OneLog AG has no influence on the scope of data collected by SwissSign. Further information about the purpose and scope of the collection, the further processing and use of your data by SwissSign Group AG, as well as your rights and settings options for protecting your data, can be found in SwissSign Group AG’s privacy policy.
Please note that some of the affiliated companies request and process additional personal data from you so that they can provide you with their digital services. You can find a more detailed description of this in the respective company-specific data protection regulations.
Contact form & live chat
You have the option to contact us using a contact form or by e-mail and to send an enquiry to us. In this context, we will process your name and contact details, in order to make contact with you and to process your enquiry.
As an alternative to the contact form, you have the option to contact us using live chat. In this context, we will process the personal data that you transfer to us as part of the live chat (such as your first and last names, address, e-mail address, telephone number etc.) as well as your IP address, in order to process your enquiry.
Comments function in forums
If you wish to register for the forums on our website drive-electric.ch, you can choose from the registration or login options listed above. For use of the forums, the following additional data is collected:
• User name
• Photo/avatar (optional)
Online appointment
If you use our “Make your appointment online” service, your contact and vehicle data will be forwarded to your preferred garage for the purpose of arranging the appointment.
Newsletter
If you subscribe to our newsletter, we and/or the service providers commissioned by us will process your contact data on the basis of your consent. You are able to unsubscribe to the newsletter at any time by using the unsubscribe link in the newsletter.
Test drive
If you use our “Book a test drive” online service, then we will forward your contact data to your preferred garage for the purpose of arranging an appointment.
Car purchase
If you purchase a vehicle via our website, then we and/or the service providers commissioned by us will process your contact, address and payment data to create and fulfil the sales agreement.
Car subscription
If you take out a vehicle subscription via our website or via a dealer, then we and service providers commissioned by us will process your contact, address, credit rating and payment data to create and implement the subscription agreement.
Our subscription vehicles are equipped with an adapter from autoSense. For more information, see “autoSense”.
You can find information about our “Clyde” subscription service and the privacy policy for Clyde at: https://clyde.ch/en/privacy-policy
Claims report
If you use our “Claims report” online service, then we and service providers commissioned by us will process your data to handle your claim. We will collect the following categories of data from you:
• Name, address, contact data
• Vehicle data, driving licence data (if “driving licence identification” is used)
• Claims report
AMAG shop
If you use our AMAG online shop, we process your name, address and contact details for the purpose of processing the payment and shipping the ordered goods, as well as information about the payment itself.
We or third parties commissioned by us will process your personal data in our customer database, in order to provide our services to you and to carry these out. The processing of your data is undertaken in connection with the initiation or implementation of a contract, our legitimate interest and your consent.
Under some circumstances, your data will be disclosed to the following categories of recipients:
- Contractual and business partners
- Manufacturers
- banks
- Insurance
- Credit agencies
- IT service providers
- Marketing service providers
- Platform providers for vehicle data
Leasing
If you lease a car or e-bike from us, we and/or service providers commissioned by us process your data to create and implement the leasing contract.
As part of the credit check that we are legally obliged to undertake, we and the service providers commissioned by us will also process the following data from you:
• Personal details (last name, first name, birth date, marital status, number of children)
• Income (salary, alimony, pension, name of employer)
• Expenses (rent, work-related expenses, church tax)
In addition, we will obtain the following additional information about you from our service providers such as CRIF and ZEK/IKO for the credit check:
• Existing leasing obligations
• Existing credit obligations (incl. annualisation for 36 months)
• Credit score for concluded or ongoing obligations
• Payment experiences
• PEP, Crime, Sanction
The credit check is an automated decision-making process.
Location
Our vehicles and e-bikes are equipped with autoSense adaptors or chips from the manufacturers. Vehicles and e-bikes can be located by the manufacturer to facilitate retrieval and detection in the event of theft.
Identification procedure
As part of the unique identification required under law, we and third parties commissioned by us will process your identification data (ID document). We offer you a digital identification option for this purpose.
ROCKON
Online and video identification is carried out by ROCKON Digital Evolution AG (Splügenstrasse 11, 2nd floor, 8002 Zurich, Switzerland; “ROCKON”) and on the basis of your consent. For both processes, AMAG transfers your data (first name and surname, date and place of birth, nationality, e-mail address, gender, mobile phone number, place of residence, preferred language) to ROCKON. For video identification, a secure connection is established between ROCKON and your device, which enables the required direct visual contact. A ROCKON employee will match the identity details you have provided to us on the basis of your ID. In order to prove that the video identification process has been carried out properly, the employee must be able to access the camera on your device and take photos of you and the front and back of your ID or front of your passport and, if applicable, your residence permit. These photos will be sent to AMAG Leasing AG. The conversation will be recorded and saved. At the beginning of the video identification, the ROCKON employee will ask for your explicit consent to the creation of the photos and the recording of the conversation. ROCKON will delete the data no later than 20 days after transferring it to AMAG Leasing AG.
Chauffeur Drive
You can contact us by e-mail or phone and send us an enquiry. In this context, we will process your name and contact details, in order to make contact with you and to process your enquiry.
As an alternative to the contact form, you also have the option of contacting us via the “price enquiry”. In this context, we will process the following personal data in order to be able to inform you about the price of the requested service.
· Name
· E-mail
· Telephone
· Vehicle selection
· Required service
· Dates & Location
· Description of the desired journey
The following personal data is processed in connection with the booking of our Chauffeur Drive service
· Passenger name
· Passenger telephone number
· Name of the person making the booking + telephone number (e.g. assistance)
· Address
· Telephone number
· e-mail address
We process this data to create and fulfil the contract with you.
Parking
If you rent a parking space in our multi-storey car parks (long-term rental), we will process your name, contact details, licence plate and vehicle details in order to conclude a contract with you regarding the long-term rental, issue you the parking card which you use to identify yourself when entering and leaving the car park, and for accounting purposes. If you cancel your long-term rental, we will delete your data once the statutory retention periods have expired.
Service
We and/or third parties commissioned by us will normally process the following data categories from you if you use our garage services:
• Name
• Address data
• Contact data
• Vehicle data
• Invoice data
• Insurance data
This data is required to implement the service you have booked and for communication with you.
Service camera
As part of your service order, the manufacturer’s “service camera” is used to make video recordings of your vehicle, in order to provide even more transparent processing of servicing and repair services to you. To transfer the recording to you, we will process your contact data such as e-mail address or SMS number. The video recordings will be processed directly by the manufacturer and provided to us for the duration of the service.
Replacement vehicle
If you obtain a replacement vehicle from us, then we will process your name and address and contact data. The autoSense adapter installed in the vehicle also records technical data such as mileage and possible technical faults and transmits this data to us via autoSense for the purpose of regular maintenance and troubleshooting. In this context, we do not receive any data that allows geotracking or for conclusions to be drawn to your driving behaviour.
autoSense
Our subscription and replacement vehicles are equipped with an adapter from autoSense.
Please see the corresponding rental and subscription conditions to find out what autoSense data is specifically transmitted for which purpose.
You can find more information about the autoSense privacy policy provisions at https://en.autosense.ch/datenschutz.
Totalmobil!
If you purchase a new or used vehicle from the Volkswagen, Audi, SEAT, CUPRA, ŠKODA and VW Commercial Vehicles brands, your vehicle will automatically be insured free of charge with Totalmobil!. We will transfer your contact and vehicle data to Touring Club Suisse (TCS), which will be available to you as a service provider in the event of a claim.
Aquacar
If you purchase a vehicle from us or use one of our services, your technical vehicle data will be stored in the database of AMAG Corporate Services AG. This data may be viewed by prospective buyers in the event of a vehicle sale – provided you have given your consent. You can find more information about AQUACAR at www.aquacar.ch.
Tuning/sale of parts
If you purchase parts or tunings for your vehicle via our dealers or service partners, then on the basis of the contract we will process the personal data that is relevant to the sale or service such as contact data, vehicle data and payment data and we will forward these to the service providers used by us to provide the service.
Recording of phone calls
Calls to our customer centre are recorded for training and quality purposes.
We are legally obliged to carry out sanction checks on private individuals and companies. In this context, we and a service provider commissioned by us will process your name in order to compare it with the relevant sanction lists (SECO, CFSP, EURUDU EU, EURUKM EU, OFAC).
We do not proactively use WhatsApp as a communication tool. If you would still like to communicate with us via WhatsApp, please be aware that personal data (name, contact information) will be transmitted to WhatsApp Inc. in the USA. The US does not currently have an adequate level of data protection. Please see the corresponding privacy policy to find what data WhatsApp processes for what purpose.
If you apply for a position at AMAG through our job portal, then we will process the following personal data from you as part of and for the purpose of the application process:
• Name
• Contact data
• Date of birth
• Cover letter
• Curriculum vitae (CV)
• References/certificates
Data will be disclosed only within AMAG to those who are responsible for the application process.
If no contract is signed with you, we will erase your data unless you have granted your consent for continued storage.
We process your data for marketing purposes (newsletters, competitions, events, service information, new products, company information etc.) only if you have given your consent for this or a legitimate interest exists.
You may revoke your consent at any time with effect for the future by sending an e-mail to privacy@amag.ch.
To improve the quality of our service, service providers commissioned by us to conduct opinion surveys will contact you after a contract or servicing contract is signed.
We or third parties commissioned by us will also receive your personal data from other sources, if these are authorised to disclose your details, for purposes of customer contact and acquisition and for the provision of services. These sources may be:
• Public sources
• Address brokers
• Mobility service providers
To provide our services, we need to transfer personal data both within the company and externally. This involves, in particular, the following parties:
• Our service providers (within the AMAG Group and to the extent permitted by law also externally, e.g. banks or insurance companies), including processors (e.g. IT providers);
• Dealers, service partners, suppliers, subcontractors and other business partners;
• Authorities, official agencies or courts in Switzerland and abroad;
• the general public, including the visitors to websites and social media;
• Communication partners;
• competitors, organisations in the industry, associations, other organisations and other bodies;
• purchasers of or parties interested in purchasing business areas, companies or other parts of the AMAG Group;
• other parties in potential or actual legal proceedings;
• Other companies and holdings of the AMAG Group;
all hereinafter collectively referred to as the “recipients”.
Where necessary for the provision of our services, personal data will be transmitted to the aforementioned bodies in Switzerland and the EU. If we transfer data to a third country, we will provide an adequate level of protection, as prescribed by law, through use of appropriate contracts and/or measures (based in particular on the standard contractual clauses of the European Commission). You can obtain a list of the relevant service providers and processing locations for your personal data upon request by sending an e-mail to privacy@amag.ch.
We process and store your personal data for as long as it is required to meet our contractual and statutory obligations or as long as it is required for the purposes pursued by the processing, i.e. for the entire duration of the business relationship (from the initiation and execution of a contract to its termination and the warranty period, as well as a subsequent service phase) and apart from that in accordance with the statutory obligations regarding retention and documentation. It is possible in this regard that personal data will be retained for the period during which claims may be asserted against us, or if we are otherwise obliged by law to retain such personal data, or legitimate business interests require that the personal data be retained (e.g. for evidentiary and documentation purposes). In principle, as soon as your personal data is no longer required for the purposes indicated above, it will be erased to the extent possible or rendered anonymous. Generally, shorter retention periods apply in respect of operating data (e.g. system protocols or logs).
We take appropriate technical and organisational measures to protect your personal data against unauthorised access and misuse.
In the course of our business relationship, you must provide us with the personal data required to enter into and conduct a business relationship, and to perform the related contractual obligations (as a rule, you do not have a statutory obligation to provide us with data). Without these data, we will generally not be in a position to conclude a contract with you (or with the body or person you represent) or to implement it. In addition, our websites can only be used if certain information to ensure the free flow of data (e.g. IP address) is disclosed.
As a data subject, you have the following rights:
Right of access
You have the right to obtain information about the processing of your personal data.
A request for information is generally free of charge. A fee may be charged where the request entails a particularly extensive amount of work, the request for access to information is excessive or notorious, unless there is a legitimate interest. If you will incur costs, we will notify you in advance.
The exercise of these rights requires that you provide clear proof of your identity (e.g. by means of a copy of an identification card if your identity is otherwise unclear or cannot be verified). To assert your rights, you may contact us at the address indicated in section 2.
Right of rectification
You have the right to request the rectification of inaccurate or incomplete personal data about you.
Right to erasure
You have the right to request the erasure of your data under certain circumstances. Under this right, you may, for example, request the erasure of your data, provided this is no longer necessary for the purposes for which it was collected. You may also request erasure if we are processing data on the basis of your consent and you revoke this consent.
Please send your requests to:
AMAG Group AG
Legal & Compliance
Data protection
Alte Steinhauserstrasse 12
6330 Cham, Switzerland
Or by e-mail to privacy@amag.ch
Right of withdrawal
You have the right to withdraw your consent at any time with effect for the future. Please send your right of withdrawal to: privacy@amag.ch
Complaints
Furthermore, every data subject has the right to assert their claims in a court of law or to file a complaint with the responsible data protection authority. The responsible data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch/edoeb/en/home.html).
In Liechtenstein the data protection authority of the Principality of Liechtenstein (https://www.datenschutzstelle.li) is responsible.
We may amend this Privacy Policy at any time without prior notice. The applicable version of the Privacy Policy is the latest version as published on our website. If the Privacy Policy forms part of an agreement with you, we will notify you of any updates to it where this is possible without undue expense.
