Important information. Please read:
- This Privacy Notice is provided by Volkswagen Group United Kingdom Limited trading as TPS ("TPS", "we", "us" or "our") who is a controller for the purposes of the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 (collectively the "Data Protection Laws") in its capacity as the promoter of the promotion this Privacy Notice relates to ("Genuine Heroes Promotion"). This Privacy Notice explains our processing of personal data and special categories of data in relation to the Genuine Heroes Promotion. Separately, the terms and conditions of the Genuine Heroes Promotion ("Promotion T&Cs") can be found here [insert link]. For any questions or issues in relation to this Privacy Notice, please contact us at [insert email/phone number] or write to Legal Department, Volkswagen Group United Kingdom Limited, Yeomans Drive, Blakelands, Milton Keynes MK14 5AN.
- Participation in the Genuine Heroes Promotion - In order to register a participant's entry into the Genuine Heroes Promotion, we collect the following information from the participant and the Qualifying Business they represent. Qualifying Business and End User are as defined in the Promotion T&Cs.
- Participant/Qualifying Business information:
- TPS customer number
- Trading name
- Business address
- Business phone numberand business email address
- Name of contact point for participant and confirmation that they are aged over 18 and have the permission of their employer to participate
- Participant's confirmation for providing free-of-charge labour
- Description of the repair work required
- Commercial value of the free-of-charge labour to be provided
- Names of vehicle parts required
- Estimated value of vehicle parts required
- Proposed time of repair
- End-User information:
- Contact details
- Vehicle make and age
- Vehicle registration number
- A short paragraph on how having the work carried out will personally benefit the End-User
Where participants provide us with personal data about the End-Users, the participants confirm that they have informed the relevant individuals about TPS' processing of their data (including by providing a copy of this privacy notice) and obtained the End-User's consent to enter into the Genuine Heroes Promotion and for TPS to process their data as described in this privacy notice.
Where the participant is an individual (e.g. sole trader), we are allowed to process the participant's personal data on the basis that it is necessary for our performance of the contract the participants have entered into with us (i.e. the Promotion T&Cs). If the participants do not provide personal data to us, we will not be able to carry out the contract (i.e. deliver the prize to the participant if they win).
Where the participant is a corporate organisation, we are allowed to process the personal data of the participant's employees provided to us because it is in our legitimate interest to do so i.e. we need the information to contact the participants on matters relating to the Genuine Heroes Promotion. Data subjects can object to the processing that we carry out on the grounds of legitimate interests. See paragraph 6 "Rights" below to find out how.
We are allowed to process the End-User's data (which may include a combination of their personal data and special categories of data) based on their explicit consent. End-Users are permitted to withdraw their consent at any point. However, please note that we cannot progress with the participant's entry in connection with an End-User if the End-User's consent is withdrawn.
- Winning the Genuine Heroes Promotion – Upon a participant winning the Genuine Heroes Promotion, TPS will make the participant's name and county available, as a winner, on TPS's website and/or to people requesting that information in accordance with the Promotion T&Cs and to comply with the requirements under the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the "CAP Code"). As provided in the CAP Code, winning participants can object to us publishing or making available this information or reduce the amount of information published or made available. In order to contact us on this, please use the details in paragraph 1 of this Privacy Notice. Please note that this does not affect our obligation to provide the relevant information and the winning entry to the Advertising Standards Authority, the UK's regulator of advertising, if required to do so.
We will also publish the trading name and picture of the winning participant and name and picture of the relevant End-User (including in print publications, online and on social media of our choice) for the purpose of promoting the Genuine Heroes Promotion, only upon receiving the consent from the winning participant and the End-User. Please note that the winning participant and the End-User can withdraw their consent at any point.
- How long do we hold the information – In relation to entries that are not successful, TPS will delete the information collected three months after the prizes have been awarded and distributed (or if there are any relevant complaints or issues relating to the promotion and if later, promptly after those complaints or issues have been resolved). In relation to entries that are successful, TPS will delete the information collected three months after the administration of the prizes, completion of all delivery arrangements connected to the prizes, and any related promotional activities (or if there are any relevant complaints or issues relating to the promotion and if later, promptly after those complaints or issues have been resolved).
- Who do we share the information with - TPS will not disclose or share the information collected as described in this Privacy Notice with any third party other than those who are engaged by TPS to administer the Genuine Heroes Promotion and fulfil the prizes. The information may be sent to countries outside of the European Economic Area where TPS's (or its third parties') processing equipment is located in another country but TPS ensures that any transfer happens in accordance with the law.
- Rights – The participants and End-Users have various rights as data subjects under the Data Protection Laws with regard to the personal data and special categories of data which TPS holds:
- a right to request a copy of the information;
- a right to require TPS to erase the data subject's information;
- a right to object to the process of the information;
- a right to restrict processing of the information;
- a right to withdraw consent;
- a right to correct the information; and
- the right to ask us to port (transfer) the information directly to the data subject or another organisation.
Note that if you exercise certain of these rights we will have to remove your entry (or the entry nominating you) from the Genuine Heroes Promotion and, if you are a winner (or the entry nominating you is a winning entry), you will not be able the claim or benefit from the prize.
To exercise any of these rights, please contact us using the details provided in paragraph 1 of this Privacy Notice. We may ask for proof of ID if required.
- If data subjects believe that TPS is not treating their personal data in accordance with the Data Protection Laws, they have a right to lodge a complaint with the Information Commissioner's Office. You can find more details at their website https://ico.org.uk/.