DATA PROTECTION POLICY & LEGAL NOTICE
The exacting demands you place on Rolls-Royce Motor Cars products and services, as well as the customer care we provide, as a Rolls-Royce Motor Cars partner are our guiding principle for handling your data. We aim to create and maintain the basis for a business relationship with our customers and interested parties characterised by trust. We attach particular importance to the confidentiality and integrity of your personal data. We will therefore process and use your data with due care, for the intended purpose or in accordance with your consent and in compliance with the statutory data protection provisions.
In the following sections, this data protection notice describes how we, Procar Automobile GmbH & Co. KG, as a Rolls-Royce Motor Cars partner, collect, process and use personal data from customers and interested parties.
WHO IS THE RESPONSIBLE PARTY FOR DATA PROCESSING OPERATIONS?
Procar Automobile GmbH & Co. KG (hereinafter referred to as “Autohaus”, “Rolls-Royce Motor Cars Partner” or “We/Us”), Bayerische Allee 1, D-50858 Cologne, Germany, is the controller within the meaning of the EU General Data Protection Regulation (“GDPR”) in respect of processing your personal data. Procar Automobile GmbH & Co. KG has its registered office in Cologne. The administrative headquarters for the company is located in Velbert.
As an authorised Rolls-Royce Motor Cars dealer and authorised Rolls-Royce Motor Cars garage, we are an authorised Rolls-Royce Motor Cars partner and a legally and economically independent company, and are not part of Rolls-Royce Motor Cars Limited.
We use the Rolls-Royce Motor Cars brand as a licensee for the sale of Rolls-Royce Motor Cars, original Rolls-Royce Motor Cars parts and accessories as well as brand-related maintenance and repairs.
We are the data controller for your data that are collected and processed by Us via this website, your contacts with us at the dealership and as part of customer care and in the context of our direct marketing activities.
We shall also process your data if they are made available to Us by Rolls-Royce Motor Cars Limited if and to the extent that the necessary data protection requirements are met.
You can obtain information about data processing by Rolls-Royce Motor Cars Limited online here in Rolls-Royce Motor Cars Limited's Data Protection Notices.
Our contact details are:
Procar Automobile GmbH & Co. KG
Bayerische Allee 1
D-50858 Cologne
+49 2051 9110 - 500
datenschutz@bmw-procar.de
Please contact our data protection officer if you have any questions about data protection.
TÜV SÜD Pluspunkt GmbH,
c/o Data Protection Officer of
Procar Automobile GmbH & Co. KG., Cologne
Wiesenring 2
D-04159 Leipzig
DSB@bmw-procar.de
WHEN DO WE COLLECT AND PROCESS PERSONAL DATA?
We collect and process your personal data in the following cases, including
When you contact us directly, e.g. via this website or at the dealership.
When you purchase products directly from Us (e.g. vehicles or parts and accessories).
When you buy services directly from us (e.g. when We service or repair your vehicle).
When you request information about our products and services (e.g. sending brochures or price lists).
When you respond to our direct marketing activities, for example when you complete a reply or competition card or when you submit your details online on this website.
When Rolls-Royce Motor Cars Limited permissibly provides Us with data about you if and to the extent that the necessary data protection requirements are met.
If third parties permissibly provide us with personal data about you.
In that respect please help Us keep your details up to date by informing us of any changes to your personal data, in particular your contact details.
WHAT DATA ABOUT YOU MAY BE COLLECTED?
The following categories of personal data may be collected by way of the many services and contact channels described in these Data Protection Notices:
Contact data ► Name, address, telephone number and, e-mail address.
Interests ► Information provided by you about your areas of interest, e.g. vehicles of interest to you, hobbies and other personal preferences.
Other personal data ► Information made available by you about date of birth, education, household size or professional situation.
Contract data ► Customer number, contract number.
Website use and communications ► Information about how you use the website and whether you open or forward communications from Us, including data collected via Cookies and other tracking technologies. For more information please see our Cookie Policy here.
Transaction and interaction data ► Information about purchases of products and services from our dealership and online shop, interactions with us (your enquiries and complaints) and participation in our market research studies.
Credit and identity information ► Information to establish your identity, e.g. driving licences or registration certificate part 1; also information about transactions, any payments not made to Us; plus information about cases of fraud, criminal offences, suspicious transactions, politically exposed persons and sanctions lists in which your data are included.
Information on vehicle functions and settings ► Information about the functions and current settings of your vehicle (identified by the vehicle identification number), e.g. Rolls-Royce Motor Cars TeleServices, if you have entered us in the system as the desired Rolls-Royce Motor Cars partner.
Technical vehicle data ► Data generated or processed in the vehicle.
Operating data in the vehicle
Control units process data to operate the vehicle.
These include, for example,
Vehicle status information (e.g. speed, movement deceleration, lateral acceleration, wheel rotation number and display of seat belt use),
Ambient conditions (e.g. temperature, rain sensor and distance sensor).
Such data are usually volatile and are not stored beyond the operating time and are only processed in the vehicle itself. Control units often contain data memories (including the vehicle key). These are used to temporarily or permanently document information about the vehicle condition, component stress, maintenance requirements as well as technical events and faults.
The following are stored depending on the technical equipment:
Operating states of system components (e.g. fill levels, tyre pressure and battery status),
Malfunctions and defects in important system components (e.g. lights and brakes),
System reactions in special driving situations (e.g. deployment of an airbag, activation of the stability control systems),
Information about events causing damage to the vehicle,
In the case of electric vehicles, state of charge of the high-voltage battery and estimated range.
In special cases (e.g. when the vehicle has detected a malfunction) it may be necessary to store data that would actually only be volatile.
If you make use of services (e.g. repair services or maintenance work), the stored operating data can, where necessary, be read and used in conjunction with the vehicle identification number. The reading may be performed from the vehicle by our employees or third parties (e.g. breakdown services). The same applies to warranty cases and quality assurance measures.
The reading is usually performed via the legally required connection for OBD (“on-board diagnosis”) in the vehicle. The read operating data document the technical conditions of the vehicle or individual components, and provide support in respect fault diagnosis, compliance with warranty obligations and quality improvement. Such data, in particular information about component stress, technical events, operating errors and other faults, are transmitted to Rolls-Royce Motor Cars Limited for this purpose in conjunction with the vehicle identification number, where applicable. Furthermore, Rolls-Royce Motor Cars Limited is subject to product liability. Rolls-Royce Motor Cars Limited also uses operational data from vehicles for this purpose, for example for recall campaigns. Such data may also be used to investigate customer claims for warranty and subsequent improvement.
Fault memories in the vehicle may be reset by a service company as part of repair or service work or at your request.
For further information about processing data in the vehicle, please refer to your vehicle owner's manual or the Rolls-Royce Motor Cars Limited Data Protection Notices here.
Vehicle location data ► Details about the location of your vehicle or mobile device. We may receive limited vehicle location data where this is necessary for the purposes of executing a contract (e.g. as part of the Rolls-Royce Motor Cars Mobile Service Roadside Assistance).
FOR WHAT PURPOSES ARE YOUR DATA PROCESSED?
Data collected in conjunction with entering into contracts or the rendering of our services are processed for the purposes set out below. First of all below is an explanation of the legal bases for processing personal data:
We shall only process your data if an applicable legal provision permits Us to do so. We shall, in particular, process your data on the basis of Article 6 and Article 9 of GDPR as well as on the basis of consent in accordance with Article 7 GDPR. In doing so, We shall render the processing of your data subject to the following legal bases, among others. Please note that this is not a complete or exhaustive list of legal bases, and that these are merely examples which are intended to make the legal bases more transparent.
Consent (Article 6(1), Sentence 1, Point a), Article 7 GDPR, or Article 9(2), Point a), Article 7 GDPR): We shall only process certain data on the basis of your previously granted explicit and voluntary consent. You have the right to withdraw your consent at any time with effect for the future.
Executing a contract / pre-contractual measures (Article 6(1), Sentence 1, Point b), GDPR): We require access to certain data to initiate or execute your contract with Us.
Honouring a legal obligation (Article. 6(1), Sentence 1, Point c), GDPR): We are subject to a number of legal requirements. We are required to process certain data to comply with these requirements.
Safeguarding justified interests (Article 6(1), Sentence 1, Point f), GDPR: We shall process certain data to safeguard our interests or the interests of third parties. However, this only applies if your interests are not overridden in an individual case.
A. HONOURING THE CONTRACTUAL OBLIGATION IN THE CONTEXT OF DISTRIBUTION, MAINTENANCE AND REPAIR OF VEHICLES (ARTICLE 6(1), POINT B) GDPR)
We collect, process and use personal data as part of the sales processes or during maintenance or repair at our dealership.
As part of the sales process We use personal data to process the purchase contract, perform test drives and forward information in conjunction with your vehicle purchase.
The following categories of data are processed as part of these activities:
Contact details (surname, first name, address, e-mail address, etc.)
Bank details where applicable
We use your personal data to contact you usually during the course of contract processing (e.g. vehicle order, workshop/repair order) or to process a request formulated by you (e.g. quotation or test drive request). For all aspects of contract processing or the handling of a request, We shall contact you without separate consent, e.g. in writing, by telephone, via messenger services or by e-mail depending on the contact details you have stated.
As part of the maintenance and repair processes or services with us, technical data of the vehicle that are relevant to the vehicle service are read from the installed electronic control units using special diagnostic devices. Such data are processed and used in the workshop by trained technicians to diagnose and rectify any malfunctions. Such technical vehicle data essentially consist of
Vehicle master data (e.g. vehicle identification number, vehicle type, production date and vehicle equipment),
Vehicle condition data (measured values such as mileage),
Error memory entries (e.g. malfunction of direction indicator),
Load collectives,
Software statuses and
Service and workshop data (e.g. service requirements, work performed, spare parts installed, warranty cases and
workshop logs).
The above information may be accessed by Rolls-Royce Motor Cars Limited to assist Us with technical or other challenges regarding our performance.
Technical vehicle data are deleted at the end of the vehicle's life cycle.
We may also receive limited data to locate the vehicle where this is necessary for the purposes of executing a contract (e.g. as part of the Rolls-Royce Motor Cars Mobile Service Roadside Assistance). The data will be used by Us exclusively for the purpose of executing the contract.
B. FULFILMENT OF OUR SALES, SERVICE AND ADMINISTRATIVE PROCESSES IN CO-OPERATION WITH BMW AG (ARTICLE 6(1), POINT A, B, F) GDPR)
The transfer of data to Rolls-Royce Motor Cars Limited is necessary to perform sales, service and administrative processes. This is the case when We transfer data
For the purpose of investigating warranty/guarantee claims
To process vehicle orders and services
For questions relating to specific repair work
For marketing campaigns or market research
To process contractual agreements between Us and Rolls-Royce Motor Cars Limited
For product liability and product monitoring in respect of possible product recalls
For product and quality improvement
The following data categories are transferred for these processes depending on the relevant legal basis:
Contact details
Identification data
Vehicle master data
Vehicle condition data
Error memory entries
Service and repair garage data
C. CUSTOMER SUPPORT (ARTICLE 6(1), POINT B, F) GDPR)
We use your personal data to contact you during the course of processing the contract as described above (e.g. vehicle order, workshop/repair order) or for processing a request formulated by you (e.g. quotation, test drive requests, enquiries and complaints). For all aspects of contract processing or the handling of a request, We shall contact you without separate consent, e.g. in writing, by telephone, via messenger services or by e-mail depending on the contact details you have stated.
We shall also contact you if your vehicle is affected by a so-called technical action or a recall. In light of the fact that technical actions are usually measures of high importance (e.g. avoiding danger to passengers, avoiding damage to the vehicle), We shall contact you or Rolls-Royce Motor Cars Limited using the contact details you have made available.
We also process your personal data on this basis to further optimise your experience with us, e.g. to clearly identify you when you contact Us.
D. PROMOTIONAL COMMUNICATION AND MARKET RESEARCH BASED ON CONSENT (ARTICLE 6(1), POINT A) GDPR)
If you have separately given your consent to further use of your personal data, your personal data may be used in accordance with the scope described in the consent, for example for advertising purposes (selected offers for products and services) and/or market research, and may be passed on to certain affiliated companies of Procar Automobile GmbH & Co KG and Rolls-Royce Motor Cars Limited. Details of this can be found in the respective declaration of consent, which you may revoke at any time.
If you have granted the relevant consent to promotional communication, We shall collect and process:
Contact details, e.g. name, address, e-mail and telephone number
Additional personal information / preferences, e.g.
Company name, your relationship with that company if you use a company vehicle or are our contact for that company
A possible date when you will require a new vehicle and your interest in Rolls-Royce Motor Cars vehicles and services and your requests for information and test drives etc.
Vehicle identification number and other attributes associated with it
Interests and hobbies
Status of your data protection consent form and selected or preferred communication channel
Identification data, e.g. customer number and contract number
Customer history, e.g.
Vehicle purchase data including model, configurations, date of purchase, date of registration, registration number, date of order, date of delivery, owner and list price
Service order data including scope of activities performed and spare parts installed
Campaign history and response to direct marketing measures
Participation in events
Enquiry and complaints history
Error memory entries
Service and repair garage data
In the data protection consent form you also specify the communication channels (e.g. post, telephone or e-mail) by way of which We may contact you.
Data processing for advertising purposes usually applies in Germany. Under no circumstances shall personal data be transferred to a country outside the EU.
E. COMPLIANCE WITH LEGAL OBLIGATIONS TO WHICH WE ARE SUBJECT (ARTICLE 6(1), POINT C, F) GDPR)
We shall also process personal data where there is a legal obligation to do so.
Collected data shall also be processed in the context of guaranteeing that IT systems are operational. Guaranteeing in this sense is understood to include the following activities:
Backup and recovery of data processed in IT systems,
Logging and monitoring of transactions to check the correct functioning of the IT systems,
Detecting and preventing unauthorised access to personal data,
Incident and problem management to rectify faults in IT systems.
We are subject to a variety of other legal obligations. To comply with these obligations, We process your data to the extent necessary and, where applicable, forward such data to the responsible authorities as part of statutory reporting obligations.
Furthermore, We may process your data in the event of a legal dispute if the legal dispute necessitates the processing of your data.
F. DATA TRANSFER TO SELECTED THIRD PARTIES
Data will be forwarded to the following companies, inter alia, if and to the extent that the necessary data protection requirements are met:
If you have previously granted us your express consent to share your data with affiliated companies of our group of companies for advertising or marketing purposes. This applies to
Procar Automobile Finanz-Holding GmbH & Co. KG
Kopernikusstr. 6
+49 2051 9110 - 500
datenschutz@bmw-procar.de
Procar Versicherungsservice GmbH
Bayerische Allee 1
D-50858 Cologne
+49 2234 915 - 170
datenschutz@bmw-procar.de
To Rolls-Royce Motor Cars Limited, e.g. to update your address and vehicle, if and to the extent that the necessary data protection requirements for this are met and you have not objected to the use of your data for the purpose of written communication in the knowledge of a right to object, as well as contact details and personal data (e.g. date of birth, driving licence class, hobbies and interests) if your consent to advertising purposes permits this or also vehicle data used by Rolls-Royce Motor Cars Limited, in particular for the purpose of product monitoring and development.
To carefully selected and vetted service providers and business partners with whom We work to provide products and services to you. We will only do this as part of the strict conditions of data processing by order or with your explicit consent.
To other third parties (e.g. public authorities) where We are legally obliged to do so.
