Privacy Policy - Porsche Newsroom

Privacy Policy for Porsche Newsroom by Porsche Middle East and Africa FZE

We, Porsche Middle East and Africa FZE (hereinafter referred to as "we" or "PME"), are happy about your interest in our Newsroom (hereinafter referred to as the "Newsroom"). We take the protection of your personal data very seriously. Your personal data is processed only within the scope of the legal provisions of the United Arab Emirate's Federal Data Protection Law (“PDPL”), and applicable regulations including the General Data Protection Regulation (hereafter "GDPR"). In this Privacy Policy, we provide you with information about the processing of your personal data and your rights as a data subject in the context of the steps taken by PME to process your request. For information on the processing of personal data in other areas, please refer to the respective specific privacy policies.

This Privacy Policy applies to all employees, customers, visitors, third parties, and others (hereinafter referred to as "you" or the "user") who access or use our websites, customer and employee portals and social media pages.

The intent of this Privacy Policy is to inform you about the following:

What information we may gather about you and the purpose for gathering it.
How we may use the information gathered from you and who do we share it with.
Your rights to privacy when it comes to your personal data.

If we refer to this Privacy Policy from external social media profiles, the following explanations apply only insofar as the processing takes place in our area of responsibility and insofar as no more specific and therefore prior information on data protection is provided in the context of such social media profiles.

1. Controller and data protection officer

Responsible for the data processing as controller in terms of data protection law is:

Controller for data processing in accordance with the data protection legislation is:

Porsche Middle East and Africa FZE
Plot-29-911, Dubai Silicon Oasis
Dubai, United Arab Emirates
P.O. Box 341356
Telephone (+971) 4 3569 911
Service License No. 25
www.porsche.com

If you have any questions or suggestions regarding data protection, please feel free to contact us. You can reach our data protection officer as follows:

Porsche Middle East and Africa FZE
Plot-29-911, Dubai Silicon Oasis
Dubai, United Arab Emirates
P.O. Box 341356
Telephone (+971) 4 3569 911
Email privacy@porsche-me.ae
Service License No. 25
www.porsche.com

With regard to data processing in connection with the Newsroom, we are jointly responsible as joint controllers with the Group Companies of Porsche AG listed below (if used in this Privacy Policy, “we” therefore also stands for that Group Companies that are jointly responsible). With respect to the joint processes, we jointly determine the purposes and means of processing. In an agreement on joint controllership, we have determined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. It was determined how an appropriate level of security and your rights as a data subject can be ensured, how the information duties under data protection law can be fulfilled jointly and how potential data protection incidents can be monitored. This also includes ensuring that reporting and notification obligations are fulfilled. In case you contact us, we will coordinate in accordance with the agreement in order to respond to your inquiry and to guarantee your rights as a data subject.

2. Subject matter of data protection

The subject matter of data protection is the protection of personal data. This is all information relating to an identified or identifiable natural person (so-called data subject). This includes information such as name, postal address, email address or telephone number, as well as information that necessarily originates within the context of contact when processing your respective request, such as complaints, data quality related enquiries, enquiries about the Porsche Sales Organization or Porsche Marketing campaigns. This also includes other information that may be generated when using the Newsroom, in particular information about the beginning, end and extent of use as well as the transmission of your IP address.

A. How do we collect personal data?

PME will generally collect your personal data directly from you. This is achieved through your interactions, electronic, telephone communications or our security systems. We collect personal data indirectly from you through our business partners, suppliers, marketing agencies and other third parties.

Most of the personal data collected by PME is provided by you voluntarily for example when you register on the Porsche website or attend an event and is therefore collected with your consent. The remaining personal data may be collected for the protection of public interest and the interests of data subjects, the protection and the defence of our rights, property, or safety or that of our clients and visitors of PME, the compliance with regulations applicable to PME, or the performance of contractual obligations.

3. Purposes and legal basis of data processing

The use of personal data during a form of making contact regarding the related enquiry is partially permissible without registration. Even when you use the website without registering however, personal data can be processed. In the following, you will find an overview of the purposes and legal basis of data processing in connection with the Newsroom. In any case, we process personal data in accordance with the legal requirements, even if in individual cases a different legal basis should be relevant than that stated below.

The provision of personal data by you may be required by law or contract or may be necessary for the conclusion of a contract. We will point it out separately if you are obliged to provide personal data and what possible consequences the non-supply would then have (e.g., a loss of claims or our position not to provide the requested service without providing certain information). The use of the Newsroom is generally possible without registration. The use of individual functions may require prior registration. Even if you use the Newsroom without registration, personal data may still be processed.

3.1 Performance of a contract and pre-contractual measures

We process your personal data if this is necessary for the performance of a contract to which you are a party or for the implementation of pre-contractual measures taken in response to your request. The purposes of processing include enabling the use of our specific products and services within the scope of the Newsroom. Please also note the details in the respective documents describing our products and services further to this Privacy Policy.

The Newsroom include, but not limited to, these are the following functions:

Magazine Orders and Subscriptions

To order a magazine or subscription, e.g., Christophorus magazine, the following data is requested: title, first name, last name, address, e-mail address and, if applicable, payment data. In the case of a credit card payment, the card number, validity date of the card, holder name and card verification number are also collected. On a voluntary basis, you can also provide additional information; however, this information is not required for the execution of the order. The personal data you provide in the context of the order will be used by us for the execution and processing of orders placed and payment transactions.

Live Chat

In certain areas of the Newsroom, we offer contact and advice via live chat. With the help of the live chat, you can communicate with one of our consultants via text messages. When you access and use the live chat, your browser automatically transmits the following data at the beginning of use for technical reasons, which we store separately from other data that you may transmit to us: date and time of access, duration of the visit to our online offer, type of browser including version, operating system used, amount of data sent, type of event, IP address (shortened/altered). If you also provide us with additional personal data via the live chat, this is done on a voluntary basis.

Saving a configuration as a Pass in the Wallet app

Once you have configured your desired Porsche model in the Car Configurator, you can use a QR code or link to save the selected configuration as a Pass in the Wallet app of your end device (available on Apple's iOS and Android). A Porsche code is stored in the Pass, which can be used to display your configuration directly in the Car Configurator or to communicate it to your Porsche Centre. No registration or login with a user profile is required to use this function. The process can be repeated for further configurations. In the settings on the back of the Pass, you can decide whether the Pass should be updated if necessary and whether push notifications relating to the Pass can be sent to you. Such push notifications will generally contain information about updates and news related to your saved configuration. Per configuration, a separate Pass will be offered for you to save. Please note that the required Wallet app is not offered by Porsche AG and may need to be installed separately. The Pass is saved within the functionalities of iOS or Android via a device-related ID. It is generally not possible for us to determine your identity via the Pass. For statistical purposes, we record how often Passes with certain configurations are saved and deleted. We process your personal data in order to provide you with the desired functions. Insofar as you have given us your consent to also use the push notifications for other Porsche offers when saving the Pass, the data processing is carried out on the basis of Article 4 PDPL. You can revoke your consent at any time with effect for the future by selecting the corresponding unsubscribe link on the back of the Pass. Insofar as we record how often Passes with certain configurations are saved and deleted or insofar as we align the sending of other Porsche offers with your configuration in order to safeguard our interests in the further development of products and services as well as in customer segmentation, e.g. by calculation and evaluation of affinities, preferences and customer potential..

3.2 Compliance with legal obligations

We process your personal data to comply with legal obligations to which we are subject. These obligations may arise, for example, from commercial, tax, money laundering, financial or criminal law. The purposes of the processing result from the respective legal obligation; as a rule, the processing serves the purpose of complying with state control and information obligations.

3.3 Safeguarding of legitimate interests

We also process your personal data to pursue the legitimate interests of ourselves or third parties, unless your rights, which require the protection of your personal data, outweigh these interests. The processing to safeguard legitimate interests is carried out for the following purposes or to safeguard the following interests.

Further development of products, services and support offers as well as other measures to control business transactions and processes;
Improvement of product quality, elimination of errors and malfunctions, among other things by means of analysis of vehicle data and customer feedback;
Processing of data in a central prospective customer and customer care platform as well as upstream and downstream systems for customer retention and sales purposes;
Needs analysis and customer segmentation, e.g. calculation and evaluation of affinities, preferences and customer potential;
Handling of non-contractual inquiries and concerns;
Handling of warranty and goodwill cases;
Risk management and coordination of recall actions;
Ensuring legally compliant actions, prevention of and protection against legal violations (especially criminal offences), assertion of and defence against legal claims, internal and external compliance measures;
Ensuring availability, operation and security of technical systems as well as technical data management;
Answering and evaluation of contact requests and feedback;
Processing warranty and goodwill cases as well as non-contractual prospect and customer inquiries and concerns.

3.3.1 Retrieval of the online offer

When you call up the Newsroom, data relating to your end device and your use of the online offer are processed and stored in a so-called log file. This concerns in particular technical data such as date and time of access, duration of the visit, type of terminal device, operating system used, functions used, amount of data sent, IP address and referrer URL. We process this data to ensure technical operation and to determine and eliminate faults. In doing so, we pursue the interest of permanently ensuring technical operability. We do not use this data for the purpose of drawing conclusions about your person.

3.3.2 E-Mail-analyses

When we send emails for customer and prospect management, we may use commercially available technologies such as tracking pixels or click-through links. This enables us to analyse which or how many emails are delivered and/or rejected and/or opened. The latter is done in particular using tracking pixels. It will not be possible to fully measure the opening rate of our emails using tracking pixels if you have deactivated the display of images in your email program. In this case, the email will not be displayed completely. However, we are still able to track whether an email has been opened if you click on text or graphic links in the email. By using click-through links, we can analyse which links in our emails are clicked and derive what interest there is in certain topics. When you click on the corresponding link, you are guided through our separate analysis server before the target page is called up. Based on the results of the analysis, we can make emails more relevant, send them in a more targeted manner or stop them from being sent. If you do not want such data to be collected and tracked, do not click on text or graphic links in emails.

3.3.3 Studies and surveys

As part of the further development of products, services and support offers, you may be selected from time to time to participate in a study or survey when visiting our Newsroom. Participation is voluntary. We process your personal data if this is necessary for the initiation, implementation and evaluation of a study or survey. This also includes the further processing of the results. The processing is carried out to generate insights into individual customer satisfaction or general preferences and ideas of (potential) customers. In this respect, please also refer to the description of the study or survey and the accompanying information beyond this Privacy Policy. We do not use the collected data for the purpose of drawing conclusions about your person or your identity. Data directly related to your identity will only be processed if you provide it on a voluntary basis as part of the study or survey. If a company other than Porsche AG (to be checked) is responsible for processing your data, this will be indicated accordingly. We may use agencies bound by instructions as order processors to carry out the studies and surveys (see Section 8).

3.3.4 Social Media Widgets and External Links

Our websites may include links to social media platforms such as Facebook, Twitter, YouTube, and others as well as external links to other websites. These links may collect information about you by providing you with their services, setting cookies or employing other tracking technologies. Your interactions with those websites and features are governed by the Privacy Policy of the companies that provide them.

3.4 Consent

If you give your consent, it is always for a specific purpose; the purposes of processing are determined by the content of your declaration of consent. The data processing is based on Article 4 PDPL. You may revoke any consent you have given at any time, without affecting the legality of the processing that has taken place on the basis of the consent until revocation.

If you have given your consent, the companies listed in the declaration of consent can use the data on this basis, e.g. for individual customer and prospective customer support and contact you for these purposes via the communication channels you have requested. Your data will be used in this context to offer you an inspiring brand and customer care experience with Porsche and to make communication and interaction with you as personal and relevant as possible. Which of your data is actually used for individual customer and prospective customer support depends in particular on which data has been collected on the basis of orders and consultations (e.g. when buying or servicing Porsche products) and which data you have provided (e.g. your personal interests) at the respective contact points (e.g. at the Porsche Center).

3.4.1 Newsletter

The subscription for press releases may require you to follow a link to another website: https://newsroom.porsche.com/en.html

3.4.2 Press releases

The subscription for press releases may require you to follow a link to another website: https://pmepress.porsche.com/prod/presse_pag/PressBasicData.nsf/press/PAGenWelcome0?OpenDocument

3.5 Change of purpose

If we process your personal data for a purpose other than that for which the data was collected, beyond the scope of a corresponding consent or a mandatory legal basis, we will take into account, the compatibility of the original and the now pursued purpose, the nature of the personal data, the possible consequences of further processing for you and the guarantees for the protection of the personal data.

3.6 Profiling

We do not use automated decision-making processes to prepare, establish and forge business relationships. Profiling is only performed within the framework of the processing purposes described in this document to protect our justified interests.

4. Access authorizations in the end device

To the extent functions of the Newsroom require the granting of authorization to access your end device (e.g. access to location data or photos), the granting of these authorizations is voluntary. However, if you wish to use the corresponding functions, you must grant the appropriate authorizations, otherwise you will not be able to use these functions. The permissions remain active as long as you have not reset them in your device by deactivating the respective setting.

5. Cookies and comparable technologies

We use cookies and comparable technologies in connection with the Newsroom which serve to communicate with your end device and exchange stored information (hereinafter collectively referred to as "Cookies"). These Cookies are primarily used to make the functions of the Newsroom usable. General examples in which the use of Cookies is technically required in this sense are the storage of a language selection, login data or a shopping or watch list. Accordingly, technically required Cookies may be used by us to enable the processing described in section 3.1 and to ensure the proper and secure operation of the Newsroom. The data processing is then carried out, as it is necessary to implement the functions you have selected or to protect our legitimate interest in the functionality of the Newsroom.

Insofar as we should also use Cookies in order to analyse the use of the Newsroom and to be able to target it to your interests and, if necessary, to provide you with interest-based content and advertisements, this is done exclusively on the basis of your voluntary consent. You will then have the opportunity to make the appropriate settings within the Newsroom via the consent management. You may revoke any consent you have given at any time with effect for the future. Further information on Cookies and their function in detail as well as on setting and revocation options can be found directly in the corresponding areas of the consent management. Please note that we only make available the consent management in the context of the Newsroom if, in addition to the above-mentioned technically required Cookies, consent- based Cookies are to be used.

If you do not wish to use Cookies in general, you can also prevent their storage by adjusting the settings of your end device accordingly. Stored Cookies can be deleted at any time in the system settings of your terminal device. Please note that blocking certain types of Cookies can lead to impaired use of the Newsroom.

6. Integrated third-party services

Insofar as we integrate services of other providers within the scope of the Newsroom in order to provide you with certain content or functions (e.g. playing videos or route planning). This is because the data processing is then necessary to implement the functions you have selected or to protect our legitimate interest in an optimal range of functions of the Newsroom. Insofar as Cookies may be used within the scope of these third-party services, the statements under Section 5 apply. Please also refer to the Privacy Policy of the respective third-party provider with regard to the third-party services.

Services of other providers which we integrate or to which we refer are provided by the respective third parties. We have no influence on the content and function of the third-party services and are generally not responsible for the processing of your personal data by their providers, unless the third-party services are completely designed on our behalf and then integrated by us on our own responsibility. Insofar as the integration of a third-party service results in us establishing joint processes with its provider, we will define with this provider in an agreement on joint controllership how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. Insofar as Cookies are to be set on the basis of your consent, you will receive further information on the responsibility for setting these Cookies and any associated third-party services in the corresponding area of the consent management.

Unless otherwise stated, profiles on social media are generally only included in the Newsroom as a link to the corresponding third-party services. After clicking on the integrated text/image link, you will be redirected to the offer of the respective social media provider. After the redirection, personal data may be collected directly by the third-party provider. If you are logged in to your user account of the respective social media provider, the provider may be able to assign the collected information of the specific visit to your personal user account. If you interact via a "share" button of the respective social media provider, this information can be stored in the personal user account and published if necessary. If you want to prevent the collected information from being assigned directly to your user account, you must log out before clicking the included text/image link.

7. Sources and categories of data in case of third party collection

We also process personal data that we receive from third parties or from publicly accessible sources. Below you will find an overview of the corresponding sources and the categories of data obtained from these sources.

Group companies, Porsche dealers and service companies: [specific data, e.g. information on the products you use and on your interests];
Cooperation partners and service providers: [specific data, e.g. creditworthiness data from credit agencies].

8. Recipients of personal data

It may sometimes be necessary for us to share your personal data with other PME business partners around the Middle East region and/or Europe. We have procedures and safeguards in place to ensure the protection of personal data. These procedures include contractual obligations to ensure that all such entities safeguard your personal data and use it only for the purposes that we have specified and communicated to you.

Internal recipients: Within PME the only people who have access are those who need it for the purposes referred to above in each case.

External recipients: We only forward your personal data to external recipients outside PME if this is necessary for administering or processing your request, if another legal authorization exists or if we have your consent to forward the data.

External recipients can be:

a) Processors

Group companies in Porsche AG or external service providers that we use to provide services, for example for provision of the infrastructure and operation of the Contact Centre as well as maintenance of this offering on behalf of Porsche AG. We carefully select and regularly inspect these processors to make sure that the security and confidentiality of your personal data are safeguarded. The service providers may use the data only for the purposes we have specified.

The Porsche Contact Centre is operated on our behalf by:
Porsche Digital GmbH, Groenerstrasse 11/1, 71636 Ludwigsburg

b) Public bodies

Authorities and public institutions, such as tax authorities, public prosecutors, or the courts, to which we (must) transfer personal data for legally binding reasons or to safeguard legitimate interests.

c) Private bodies

Porsche dealers and service companies, cooperation partners, service providers or persons to whom the data is transferred based on consent, or to execute a contract with you or to safeguard legitimate interests, for example, Porsche Centres and Porsche Service Centres, financing banks, providers of other services or transport service providers.

9. Data processing in third countries

If a data transfer takes place to entities whose registered office or place of data processing is not located in a member state of the European Union, another state party to the Agreement on the European Economic Area or a state for which an adequate level of data protection has been determined by a decision of the European Commission, we will ensure prior to the transfer that either the data transfer is covered by a statutory permit, that guarantees for an adequate level of data protection with regard to the data transfer are in place (e.g., through the agreement of contractual warranties, officially recognized regulations or binding internal data protection regulations at the recipient), or that you have given your consent to the data transfer.

You can obtain from us a copy or reference to the availability of the guarantees for an adequate level of data protection in relation to the data transfer. Please use the information provided under Section 1.

PME is part of the Porsche Group which means your personal data may be transferred and stored in the United Arab Emirates and other countries outside your country of residence. If these transfers are necessary to provide you with our services generally for the proper performance of your contract or with associated professional service firms (data storage facilities or online storage located within or outside the United Arab Emirates) we will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law and fully managed to protect your privacy rights and interests.

In addition, if we may be required to transfer your personal data to public or governmental authorities according to the applicable laws, we undertake to guarantee the same level of protection of your personal data.

10. Storage duration, erasure of data

We store your personal data, if there is legal permission to do so, only as long as necessary to achieve the intended purposes or as long as you have not revoked your consent. In the event of an objection to processing, we will delete your personal data, unless further processing is still permitted by law. We will also delete your personal data if we are obliged to do so for other legal reasons. Applying these general principles, we will usually delete your personal data immediately;

after the legal permission has ceased to apply and provided that no other legal basis (e.g. commercial and tax law retention periods) intervenes. If the latter applies, we will delete the data after the other legal basis has ceased to apply;
if your personal data is no longer required for the purposes we pursue and no other legal basis (e.g. commercial and tax law retention periods) intervenes. If the latter is the case, we will delete the data after the other legal basis has ceased to apply.

PME is mindful of the importance of your personal data being stored on its systems and therefore works on safeguarding that data as well as deleting it securely when no longer required.

Personal data collected from the interactions, electronic or telephone communications, websites and social networks are being stored on our servers located within the country governed by appropriate security techniques to protect and preserve the data.
We will destroy the personal data immediately upon the completion of the purpose of its collection through secure methods and techniques.
We might require keeping your personal data even after the purpose of its collection has ended in the following three cases:
If there is a legal justification for us to keep it for a specified period by law, regulation, or for security reasons.
If the personal data is closely related to a case before a judicial authority and its retention is required for this purpose.
If all personal elements have been anonymized.

11. Rights of data subjects

The right to obtain information from the controller (right to be informed).: You have the right to obtain information from us about the data that we have stored about you.

Right to rectification and erasure: You can demand that we correct incorrect data and, if the legal requirements are met, delete your data.

Restriction of processing: You can demand that we restrict the processing of your data, provided that the legal requirements are met.

Data portability: If you have provided us with data on the basis of a contract or consent, you may, if the legal requirements are met, demand that the data you have provided us with are handed over in a structured, common and machine-readable format or that we transfer it to another controller.

Objection: You have the right to object at any time to data processing by us based on the safeguarding of legitimate interests for reasons arising from your particular situation. If you make use of your right to object, we will stop processing the data unless we can prove compelling reasons for further processing worthy of protection which outweigh your rights and interests.

Objection to direct marketing: If we process your personal data for the purpose of direct marketing, you have the right to object to our processing of your data for this purpose at any time. If you exercise your right to object, we will stop processing your data for this purpose.

Revocation of consent: If you have given us your consent to process your personal data, you can revoke it at any time with effect for the future. The legality of the processing of your data until revocation remains unaffected.

Right to lodge a complaint with a supervisory authority: You can also lodge a complaint with the competent supervisory authority if you believe that the processing of your data violates applicable law. You can contact the supervisory authority responsible for your place of residence or your country or the supervisory authority responsible for us.

Your contact with us and the exercise of your rights: Furthermore, you can contact us free of charge if you have questions regarding the processing of your personal data and your rights as a data subject. Please contact us at privacy@porsche-me.ae or by letter mail to the address provided under Section 1 or here. Please make sure that we can definitely identify you. If you revoke your consent, you can alternatively choose the contact method that you used when you gave your consent.

12. Links to third-party offerings

Services delivered by other providers that may be referred to within the scope of contact to process your request have been and are structured and provided by third parties. Third-party services can be:

Support service providers of Porsche Sales & Marketplace GmbH
Support service providers of Porsche Deutschland GmbH
Support service providers of Porsche Lifestyle GmbH & Co. KG
Other service providers

We do not have any influence over the structure, content, or role of these third-party services. We explicitly distance ourselves from all content in all third-party offerings. Please contact the providers of these third-party offerings as required for the rele-vant information.

13. Security

The security and confidentiality of your Personal Data is important to PME, and we protect the integrity and confidentiality of your personal data. Therefore, when using external service providers acting as processors, we require that they adhere to the same standards as us. Regardless of where your personal data is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure. In addition, we will take appropriate steps to protect the personal information you share with us. We maintain administrative, technical, electronic, and physical safeguards compliant with the applicable laws to protect the personal data you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, we cannot be certain that the prior would not happen and cannot be held responsible for unauthorized or unintended access that is beyond our control. The security measures are reviewed periodically by us to keep pace with business, technology, and regulatory changes.

14. Effective date

The latest version of this Privacy Policy applies. Version 1 - This version dates from [20.08.2024].