Privacy notice for online platforms

1. Area of application and definitions

This privacy information shall apply to online products and services such as e.g. Internet pages and the products and services they contain (hereinafter referred to as “Online Platform”), operated by the companies below (“companies operating under the ADAC brand”), hereinafter referred to as “ADAC”:

  • ADAC e.V.
  • ADAC regional clubs:
    - ADAC Berlin-Brandenburg e.V.
    - ADAC Hansa e.V.
    - ADAC Hessen-Thüringen e.V.
    - ADAC Mittelrhein e.V.
    - ADAC Niedersachsen/Sachsen-Anhalt e.V.
    - ADAC Nordbaden e.V.
    - ADAC Nordbayern e.V.
    - ADAC Nordrhein e.V.
    - ADAC Ostwestfalen-Lippe e.V.
    - ADAC Pfalz e.V.
    - ADAC Saarland e.V.
    - ADAC Sachsen e.V.
    - ADAC Schleswig-Holstein e.V.
    - ADAC Südbaden e.V.
    - ADAC Südbayern e.V.
    - ADAC Weser-Ems e.V.
    - ADAC Westfalen e.V.
    - ADAC Württemberg e.V.
  • ADAC SE and
  • the companies below affiliated to ADAC SE:
    - ADAC Versicherung AG and ADAC Autoversicherung AG
    - ADAC Finanzdienste GmbH
    - ADAC Medien und Reise GmbH
    - ADAC TruckService GmbH & CO. KG
    - ADAC Service GmbH

hereinafter collectively referred to as “ADAC”, excepting the companies using data protection information that differs from this privacy notice.

If you are a member of ADAC e.V., the data protection information for members shall additionally apply. If you have taken out ADAC insurance, the ADAC Versicherung AG data protection information for policy holders shall additionally apply. Moreover, our apps e.g. for smartphones have dedicated privacy information. In the event of any conflict between these terms and conditions and the statements in our privacy notice for the Online Platform, the dedicated privacy information shall prevail, including, without limitation those for members and policy holders. 

“We”, “our” and “us” as used herein shall mean the relevant controller as defined in Clause 2.

2. Controller’s name and address

The controller in the sense of the General Data Protection Regulation and the Member States’ various national data protection legislation as well as other data protection provisions is the company indicated in the site notice as the operator of the relevant Online Platform.

In addition to using the contact details in the site notice, you can contact us by
phone: +49 89 76 76 0
e-mail: adac@adac.de

3. Data protection officer’s name and address

You can contact our data protection officer at Data Protection and Data Security:

Datenschutz und Datensicherheit (DSS)
Hansastrasse 19
80686 Munich / Germany
Fax: +49 89 76 76 53 62
E-mail: dsb-mail@adac.de

In addition, you can address your contact for data protection matters of ADAC Autoversicherung AG* here:

Allianz Versicherungs-AG
10900 Berlin/Germany
c/o An den Datenschutzbeauftragten
E-mail: sachversicherung@allianz.de 

*ADAC Autoversicherung AG is an Allianz Group company.

You will find the contact data of the ADAC regional clubs’ data protection officers on the Online Platform of the relevant regional club.

4. Purposes, legal bases and duration of data processing

Whenever you visit our Online Platform, we process the data connected to your visit only in a way to exclude any direct identification of your person. Where we process your data combined with other information and cannot therefore fully exclude any direct identification of your person, we will process your data under a pseudonym.

4.1 Pseudonymised data processing

The description below of processing pseudonymised data, i.e. of information that cannot be directly associated with your person, is not required by law for the conclusion of this contract. Rather, it serves the purposes mentioned below. You can of course also use the ADAC Online Platform without accepting cookies. (Cookies are small text files stored on the user’s device. These text files help to analyse user behaviour of web page visitors and subsequently use this information for targeted product recommendation and interest-based advertising.) However, to be able to use exclusive member offers on our website, you need to consent to the placement of cookies.

4.1.1 Online Platform analysis

To analyse our Online Platform, we use web analytics tools. Cookies help us to process data of Online Platform users in order to gain information about the use of our Online Platform (e.g. number of visits, number of users, etc.).

The legal basis is Art. 6(1)(f), GDPR, with our interest being to optimise our Online Platform on the basis of the information gained and offer a more user-friendly and interesting platform. To protect your rights and interests, however, we only use pseudonymised data in the form of temporary cookies. In addition, the IP address of your visit of the Online Platform will be instantly anonymised and we only produce aggregated statistics.

Tracking with Google Analytics

To analyse the website usage, we use the Google Analytics tool by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For the analysis we use cookie text files which are stored on your end device.

The information generated by the cookies is usually transmitted to a Google server in the USA and stored there. Google Inc. uses the collected information on our behalf to analyse the website usage and website activities and to provide services connected to the use of the Internet. For this purpose, we signed a processing contract with Google Inc.

The basis is our legitimate interest in data processing pursuant to Art. 6(1)(f), GDPR.

To use the Google Analytics tool, we enabled the IP anonymisation feature. This feature shortens the IP addresses of users from EU member states and from the European Economic Area prior to the transfer to the USA. Only in exceptional cases will full IP addresses be transmitted to a US-based Google server and shortened there. This prevents such data tracing back to your IP address. The IP address collected by Google Analytics from your browser will not be combined with other Google data.

The Google Tag Manager described below controls the activation of Google Analytics on our web pages.

All data we transmit will be automatically deleted after 14 months. Once a month, we automatically delete data whose retention period has expired.

For further information about how Google Inc. uses your data click here:
https://support.google.com/analytics/answer/

 

Google Tag Manager

This website uses Google Tag Manager to control and administer website tags triggering the activation of Google Analytics and other marketing tags as described below. Google Tag Manager neither uses cookies nor does it collect any personal data. It only serves to trigger other events that might collect data (e.g. Google Analytics). You can find further information about Google Tag Manager here:  
https://www.google.de/tagmanager/faq.html

Tracking through Google AdWords

As AdWords customers, we use Google conversion tracking, an analytics tool by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google AdWords places a cookie on your device (conversion cookie) if you were directed to our website through an advertisement. These cookies expire after 30 days and do not serve to identify the person of the user. If the user visits certain pages on our platform and the cookie has not yet expired, Google and we can see that the user clicked on the ad and was redirected to our page. Each Google AdWords customer receives a different cookie. This is why cookies cannot be tracked through the AdWords customers’ web pages. The information gathered by conversion cookies serves to compile conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers receive information on the total number of users who have clicked on their ad and and have been directed to their website which has a conversion tracking tag installed. However, they receive no information that can be used to identify the user. 

For the avoidance of doubt, we shall not use any data collected by web controlling tools to personally identify the visitors of ADAC’s websites.

You can deactivate or adjust your ad settings for Google search engine ads at any time. For details please refer to:
https://www.google.com/settings/ads/

Another option is to block third-party cookies on Network Advertising Initiative’s deactivation page: http://www.networkadvertising.org/choices/

More information on data privacy terms for Google advertising is available here:
http://www.google.de/policies/technologies/ads/

For Google’s general privacy policy refer to:
http://www.google.de/policies/privacy/

Tracking with Google Remarketing

We use the remarketing technology of Google Inc. (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; “Google”). Past visitors to our website who were interested in our online services will see targeted ads while browsing on Google’s partner sites. Ads display is triggered through cookies.

If you do not want to receive interest-based advertising through Google AdWords, Google Remarketing and DoubleClick, you can block Google’s use of cookies for these purposes at:
https://www.google.com/settings/ads/

Another option is to block third-party cookies on Network Advertising Initiative’s English deactivation page or adjust your browser settings. 

By using our services you agree to your data collected being processed by Google in the kind and manner described above and for the aforementioned purpose. For the avoidance of doubt, Google has its own privacy policies which are independent from our policies. We accept no responsibility or liability for these policies and procedures. Before using our website, please make yourself familiar with Google’s privacy policies.

More information on data privacy terms for Google advertising is available here:
http://www.google.de/policies/technologies/ads/ For Google’s general privacy policy refer to:
http://www.google.de/policies/privacy/

Tracking with Bing Ads Universal Event Tracking

As a Bing Advertising customer, we use Bing Ads Universal Event Tracking which is a conversion tracking system by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft places a cookie on your device (conversion cookie) if you were directed to our website through a Microsoft Bing advertisement. 
These cookies expire after 30 days and do not serve to personally identify the user. If the user visits certain pages on our platform and the cookie has not yet expired, Microsoft and we can see that the user clicked on the ad and was directed to our page. Each Bing Advertising customer receives a different cookie. This is why cookies cannot be tracked through Bing Advertising customers’ web pages.
The information gathered by conversion cookies serves to compile conversion statistics for Bing Advertising customers who have opted for conversion tracking. 
Bing Advertising customers receive information on the total number of users who have clicked on their ad and have been directed to their website which has a conversion tracking tag installed. However, they receive no information that can be used to identify the user. 

 

In addition, you can opt out of online behavioural advertising by Microsoft here:
https://account.microsoft.com/privacy/ad-settings/signedout

Another option is to block all interest-based advertising by Microsoft and other participating companies here:
http://www.youronlinechoices.com/de/praferenzmanagement/

You will find further information about the usage and data protection guidelines concerning this product here:
https://privacy.microsoft.com/de-DE/privacystatement/

Provider ad agents GmbH

Our advertising partner ad agents GmbH is in charge of collecting data for the delivery of AdWords advertising. This is done using web analytics services by Google (Google AdWords, Google Remarketing and Google Analytics) as well as Microsoft (Bing Ads Universal Event Tracking).

We use the web analytics tool to measure the success of marketing campaigns by/for ADAC e.V., ADAC Finanzdienste GmbH, ADAC Versicherung AG, the ADAC regional clubs and ADAC TruckService GmbH & Co. KG.

Provider XAD

Our advertising partner XAD spoteffects GmbH is in charge of collecting data for the delivery of advertising. This is done using the Matomo web analytics service (Piwik).

We use the web analytics service to measure the success of marketing campaigns by/for ADAC Autoversicherung AG and ADAC Versicherung AG.

4.1.2 Advertising and personalisation

To distribute online ads to our Online Platform, we use services of the providers below which place cookies for this purpose.

Our aim is to tailor the purpose, type and frequency of advertising to the interests of visitors and to measure the success of potential advertising campaigns. This allows us to send and integrate ads that are interesting to you and that are placed accordingly and sent or displayed more or less frequently. By doing so, we can tailor our products and services making them more attractive for recipients and we can conduct advertising campaigns more efficiently. To protect your rights and interests, however, we only use pseudonymised data in the form of temporary cookies.

The basis is Art. 6(1)(f), GDPR (legitimate interest).

Provider ADITION

Our advertising partner Mediascale GmbH & Co. KG is in charge of collecting data for the delivery of advertising. This is done using ADITION technologies AG’s web analytics service.

We use the web analytics tool to measure the success of marketing campaigns by/for ADAC e.V., ADAC Finanzdienste GmbH, and the ADAC insurance companies.

Provider Affiliate

On its Online Platform, ADAC Finanzdienste GmbH uses the partner programme of financeAds GmbH & Co. KG, Karlstr. 9, 90403 Nuremberg. financeAds uses tracking cookies that are in line with the data protection provision as applicable from time to time. Such cookies do not store any personal data but rather anonymised tracking IDs. They serve to inform the website on generated leads/sales. You can find further information at:
https://www.financeads.net/ueberuns/cookies/


For further information on the data protection provisions, click here:
https://www.financeads.net/aboutus/datenschutz/

Tracking with the web analytics service of Matomo (Piwik)

Matomo uses cookies, i.e. text files which are stored on your computer and analyse your use of our website. The information generated by cookies about your use of this website will be transmitted to and stored on a server operated by our advertising partner XAD spoteffects GmbH. The data are stored in the Netherlands. 
Matomo will use this information to analyse the user’s website usage, to compile website activity reports for the website operator and to provide additional services in connection with the website and Internet usage.

Provider AB Tasty

We use the AB Tasty web analytics service of AB Tasty SAS, 3 impasse de la Planchette, F-75003 Paris (“AB Tasty”) to conduct A/B and/or multivariate testing to continuously enhance our online offers. AB Tasty collects statistical information, tracking visitors. Such information includes usage data (browser used, number of pages viewed, number of visits, order of pages visited, duration of the visit, interaction such as putting items into/emptying the shopping basket, recording the usage of individual web pages (excl. during check-out and registration), etc.) which are anonymised and evaluated statistically. At no time will it be possible to trace the data back to a specific person or an individual purchase. In addition, AB Tasty also records geo-location data (regional details of your location) based on your IP address. After recording the geo-location data right after your visit to the site, your IP address will be deleted immediately. A personalised pattern is created to display contents you may find interesting. The pattern is encrypted and cannot be traced back to you. Cookies are stored to store information about visitors and recognise repeat visitors. Such cookies are deleted automatically after a maximum of 13 months. 

4.1.3 Social plug-ins

Our Online Platform contains social plug-ins to networks such as Facebook, Google+, Twitter, etc. (third-party portals). This will enable you to easily share information from our Online Platform that you find interesting with friends on third-party portals. The use of such third-party portals shall be subject to the terms of use and data protection of the relevant portals.

Only where you use this feature proactively and voluntarily, i.e. by clicking on the plug-in, will the relevant third-party portal have access to your Online Platform usage data. As a result, the legal basis for this is the consent you gave to the provider of the third-party portal (Art. 6(1)(a), GDPR). Upon registration, the portal providers provided you with data privacy information and information on which data are used for what purpose if you use the social plug-in. We do not transfer any information that would allow any direct identification of your person. As far as we receive data from the third-party portal provider, these are aggregated data that do not reveal your identity.

Based on Art. 7(3), GDPR, you are entitled to withdraw your consent with effect for the future. To do so, simply click on the social plug-in and deactivate the relevant feature.

Third-party portals are not run by us but by the relevant portal operators. They are responsible for their portals and process data on the basis of their terms of use. If you use such third-party portals, you need to accept these conditions upon registration. The third-party portal terms of use also contain information about which data will be transferred to us through social plug-ins if you use any such feature on pages outside third-party portals including our portal. For more information on the data protection provisions of third-party portals on our Online Platform click here:

4.1.4 Duration of data processing

The cookies used in the above cases are valid for a defined period of time. The duration is in line with the above purposes and the relevant features.

If a feature is limited to a session, the cookie expires no more than 60 minutes after your visit (session cookie). In other cases, cookies expire after 60 days (persistent cookies). A special persistent cookie is used for registered and not registered users of the fuel price calculator feature to store the entered fuel prices and average consumption data. These cookies will be deleted after 365 days.

After you make use of your right of withdrawal, we can no longer link the cookie and your end device. In this case, your data are anonymous.

This also applies, if you delete a cookie. In this case, we can no longer link the pseudonymised data collected for the cookie to this cookie. Any collected data can therefore no longer be traced to a person or end device, i.e. they are anonymous.

4.2 Data processing in connection with a registration

After you registered on our platform, in addition to the above pseudonymised data we will also process data that unambiguously identify you. The description below of processing personal data, i.e. of information that can directly be linked to your person, is not required by law, but serves to enable you to use the platform. We will process your data for the purposes listed below.

4.2.1 Registration

When you register on our Online Platform, we process the data you enter to create a user account, to administer you as our contracting party in our systems and to provide ADAC products, to recognise you when you login and to be able to display your data again. The same applies, if you use features of our Online Platform that can be used after login only (e.g. discussion forums).

The legal basis is the contract on the use of the Online Platform, Art. 6(1)(b), GDPR, since the processing of such data is required to perform the contract on the use of the portal. This also applies to the processing necessary for taking steps prior to entering into a contract.

If data are required for performing the contract (mandatory information), we will inform you accordingly. If you share data that are not mandatory for the registration, the processing of such data will be based on your consent pursuant to Art. 6(1)(a), GDPR. Based on Art. 7(3), GDPR, you are entitled to withdraw your consent at any time with effect for the future. To do so, just log onto your user account and delete the data. Another option is to inform us at adac-online@adac.de that we are not to use the information any more.

Moreover, we process your personal data entered during registration to comply with our legal requirements, including, without limitation, under tax and commercial law as well as under any acts supplementing or modifying criminal laws as well as under the provisions on public safety and order. The legal basis for this is Art. 6(1)(c), GDPR.

4.2.2 Login

We set a session cookie for registered users. This cookie is required to recognise you upon login as a registered and logged-in user of the platform. You will not be required to log in every time you access the site again. The legal basis here is the contract, Art. 6(1)(b), GDPR. This cookie expires 60 minutes after you end your session.We also offer a feature

called “comfort login”. Upon comfort login we will set a persistent cookie to identify you also after the duration of your session. The legal basis here is your consent given by actively using the comfort function (Art. 6(1)(a), GDPR). You can delete this cookie at any time through “logout information for the comfort login feature” or the site settings. Otherwise, this cookie will be automatically deleted after 60 days.

4.2.3 Duration of data processing
Personal data in connection with your registration will be erased once they are no longer necessary for the purpose for which they were collected. For data collected during registration, this is the case when the registration is cancelled or modified. Where this concerns registration for the performance of a contract to which the user is a party or in order to take steps prior to entering into a contract, the data are erased once they are no longer necessary for the performance of the contract.

The requirement to store the contracting party’s, i.e. your, personal data may survive the conclusion of the contract to ensure compliance with contractual or legal obligations (i.e. accounting, tax documentation).

4.3 Data processing in connection with “Mein ADAC” (my ADAC)

At Mein ADAC, ADAC members or customers can view and change their personal data and contract information stored by ADAC. The data are used for the purpose and in the framework of performing the contracts. For further details, refer to the aforementioned data protection information for members and/or ADAC Versicherung AG policy holders.

4.3.1 Vehicle and trailer data

In addition to the data described in Clause 4.3 above, you can make available your vehicle and trailer data (e.g. make, model, type of fuel, trailer dimensions) required to report a breakdown for any later usage of one of our breakdown assistance apps (“Breakdown Assistance App” & “On-line Breakdown Assistance”). The legal basis is the legitimate interest pursuant to Art. 6(1)(f), GDPR.

We process the following data for the purposes as follows:

  • Vehicle (nick)name/picture for fast identification at Mein ADAC 

Vehicle data

  • Type of vehicle/licence plate number/make/model series/model/colour/body version for the road patrol to find you more easily at the site of the breakdown
  • World Manufacturer Identifier (WMI) so that you need not complete the data sets for the make, model series, model, body version, body type and type of fuel
  • Type of fuel to determine the suitable patrol vehicle 

Trailer data

  • Type of trailer/type of connector/date of first registration to determine the suitable patrol vehicle
  • Make/model/licence plate number for the road patrol to find you more easily at the site of the breakdown
  • Number of axles/height/length (outside)/width (outside)/gross vehicle weight to verify cover and entitlement as well as to determine the suitable patrol vehicle 


Processing and disclosure

If you use our breakdown assistance apps Breakdown Assistance App & On-line Breakdown Assistance, your vehicle and/or trailer data made available at Mein ADAC are automatically transmitted to the breakdown assistance apps and used exclusively for ADAC breakdown assistance services. ADAC may make the data available to the service partners involved, if applicable, but never to third parties.
For further details, refer to the data protection information for users of the aforementioned breakdown assistance apps.

Storage period and erasure

We will erase your vehicle and trailer data once they are no longer necessary for the above-mentioned purposes. We may need to keep personal data for as long as any claims can be brought against ADAC e.V. (legal period of limitation: three to thirty years). In addition, ADAC e.V. will store personal data to the extent and for as long as required by law. Our relevant requirements to produce evidence of compliance and retain data are set forth, among others, in the German Commercial Code (Handelsgesetzbuch), General Fiscal Code (Abgabenordnung) and Money Laundering Act (Geldwäschegesetz). To comply with this legislation, we may be required to retain data up to ten years.
In addition, you may delete your vehicle and trailer data at any time at Mein ADAC. If you do so, they will no longer be automatically used to report a breakdown through the aforementioned breakdown assistance apps.

4.4 Data processing in a data warehouse

We also analyse pseudonymised usage data of visitors and registered users of our Online Platforms in a database (data warehouse). The basis is our legitimate interest in data processing pursuant to Art. 6(1)(f), GDPR.

The purpose of such processing is that ADAC can analyse, identify and evaluate which of our products and services, and to which extent, are generally or specifically of use to you and which might be of interest to you. These analyses and prognoses are performed with pseudonymised data, i.e. data that can no longer be associated with a person. In addition, the data are processed divided into rough clusters or categories. These are then merged for use by ADAC into anonymous statistics that contain no identifying information. We also combine the generated clusters with your user data to be able to offer new or supplementary products or services that match with your data.
Such processing is automatic, but the findings or any automated decision on sending advertising to you will not produce any legal effect. In fact, you also have the possibility to obtain the advertised ADAC products using different distribution channels.

The pseudonymised data in the data warehouse will be automatically deleted 24 months after collection, unless earlier erasure is required for any reason.

4.5 Contact, chat and FAQs

4.5.1 Contact

If you contact us by contact form, telephone, e-mail or social media, we will use the data you entered to deal with your enquiry. We use the SSL (Secure Socket Layer) security protocol to transfer your data collected through the public data network to the respective DP system of the relevant ADAC company or ADAC partners responsible for effecting the transaction and store such data for contract management, claims handling, order processing and invoicing purposes.

We exclusively use your data for the specific purpose of handling your applications, orders or requests. The legal basis for this is Art. 6(1)(b), GDPR. The legal basis for the processing of data transmitted as part of a request is Art. 6(1)(f), GDPR.

Your data will be deleted once your enquiry is processed, unless legal record-keeping requirements apply.

4.5.2 Chat and FAQs

On some of our web pages you can use chat or FAQ features. For both features we use a service partner who processes your entries on our behalf. 
If you use the chat feature to ask a question, an application (chatbot) provides an automated answer. The system works with keyword-based answers, provides links for relevant websites, recommends contacting a different channel or switches your request to live chat. It is neither necessary nor solicited that you enter personal data in a chat. If the chatbot or the live chat team are unable to answer your question, you have the option to leave your e-mail address so that an ADAC expert can get back to you with a reply. Your e-mail address will only be used to provide you with an answer and deleted after we replied. 
We use cookies to identify related chats. These cookies will be deleted after 25 hours at the latest. Using our chat feature without these cookies is not possible. All questions you ask in a chat will be stored for a maximum of 14 days in order to train the system and provide better replies to future chat questions. After that, they will be irrevocably deleted. In the above context we do not analyse personal data. User data such as chat duration, time stamps of the messages, number of dialogues and approximate location of the users will be stored for statistical purposes only. 
If you use the FAQs feature we will not collect or process any personal data. Our service partner will only analyse the questions you entered in order to optimise the answers. Our service partner will process your data to reply to your request and for internal purposes, e.g. control and enhancement of business and service processes (Art. 6(1)(b), GDPR).

4.6 Newsletter

On our website you have the option to subscribe to a free newsletter. The legal basis for such processing of your data is your consent, Art. 6(1)(a), GDPR.

In connection with data processing for sending newsletters we do not transfer any data to third parties. The data are used exclusively for sending the newsletter.

You can withdraw your consent to using your data for sending newsletters at any time in line with Clause 5 below. The data will be erased once they are no longer necessary for the purpose for which they were collected. User e-mail addresses will be stored as long as the newsletter subscription is active.

4.7 Data processing on other Internet sites

We not only operate our Online Platform but are represented on other portals e.g. social networks (such as the Facebook fan page) or YouTube (third-party portals). Our aim is to increase awareness of us and be available for you to contact us also outside our Online Platform.

However, we are not the operators of such third-party platforms. Rather, we can only use them in the form made available by the relevant operators. If you visit us on these portals you will have accepted the terms of use of the relevant sites and received information about data processing and data transfer, if any.

Depending on the type of processing you accepted in the consent you gave to the portal operator, the purpose of such third-party portal is that we receive certain information about you (e.g. that you are fan of our Facebook page or subscribed to our YouTube channel) when you interact with us. The legal basis is your contract with the portal operator pursuant to Art. 6(1)(b), GDPR, or your consent to the voluntary transfer of your data to us, Art. 6(1)(a), GDPR. You interact with us on such portals of your own volition. If you sign a contract with us on such portals, we will inform you that the provision of data is required for the purpose of the contract which otherwise cannot be entered.

If you provide us with additional information (e.g. a message on the portal), this is either in performance of the contract with us (Art. 6(1)(b), GDPR) or, by doing so, you give us your consent by your own volition (Art. 6 (1)(a), GDPR).

We also use any information we receive to analyse the visits and the feedback to our presence on the platforms and, as a consequence, enhance our presence. The basis is Art. 6(1)(f), GDPR. In this context, however, we only use pseudonymised data and the anonymous statistics generated with such data.

Facebook fan page

Operating a fan page on the Facebook platform, we and Facebook are responsible for the processing of personal data performed on the fan page on our behalf.

The fan page serves to directly contact our members and other Facebook users, proactively communicate with them and inform them on a regular basis about products and services and interesting news concerning ADAC e.V., ADAC SE and their affiliated companies as well as the ADAC foundation and its affiliated companies. We also give you the possibility to enter into contact with us directly by visiting our fan page and submit enquiries to us.

We collect and process the personal data you provide on our fan page for the purpose of communicating with you. Our Facebook fan page uses the Facebook Insights tool. This tool allows us to statistically analyse the use of our fan page on the basis of defined criteria. Through the Facebook Insights tool, Facebook provides us with anonymised statistics about persons that are linked to our page or visit our page. These anonymised statistics help us to better understand the interests and wishes of our fan page users, provide targeted and enhanced product offers and improve our service quality. In addition, we can use the Insights feature for market research and opinion polling which is required for positioning our products and services. To produce the statistics we need, Facebook Insights places cookies on the end devices of our users. Cookies are text files that a web server can generate through the browser on your end device. Cookies are used to identify your end device for a defined period of time. You can configure browser settings to see when cookies are placed or block cookies. Also, you can have your browser delete cookies already placed.

The cookies set by Facebook record the data required for our statistical analysis. The provision of your personal data through cookies is not based on any legal or contractual requirement. If you are a Facebook user, you gave your consent to this processing by Facebook when you registered.

Facebook analyses the data captured by cookies and provides them to us in the form of anonymised statistics. At no time of your visit to our fan page are we able to identify your person through the Insights tool or the statistics it delivers. The legal basis for Facebook’s data collection and processing of your personal data on our behalf through the Facebook Insights tool for the above statistical purposes is Art. 6(1)(f), GDPR.

Please note that Facebook Insights and the entire Facebook fan page are a service provided by Facebook Inc.

As the provider of the fan page and the Facebook Insights tool, Facebook collects and evaluates the personal data required for our statistics and is thus able to associate such data with your person.

We do not know, however, precisely which data Facebook collects for providing anonymised Insights statistics to us and for which purposes other than preparing page statistics Facebook processes such data. Moreover, please note that we have no control over Facebook’s processing of personal data which exceeds our own statistical purposes and our scope as described above. For instance, Facebook might use the data collected and processed for us and for other purposes to create usage profiles and, potentially, link them to your private profiles on Facebook or other platforms. All responsibility for this extended processing lies with Facebook.

Also, Facebook may transfer data into the USA. However, Facebook has adhered to the EU-US Privacy Shield aimed at promoting data protection. Further information at: 
https://www.privacyshield.gov/EU-US-Framework

When and in which form Facebook corrects, ports or deletes or how long they store personal data is only known to them. We have no control whatsoever here.

To get information about data processing-relevant processes and the handling of your personal data and about your rights as a data subject as defined in the General Data Protection Regulation, please contact Facebook at the address below. In addition, you can consult the privacy notices that apply to the use of Facebook services.

Contact Facebook Inc.:
Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland

Facebook’s full privacy notices are available here:

https://www.facebook.com/policy.php
https://www.facebook.com/help/186325668085084

4.8 Customers solicit customers

ADAC Finanzdienste GmbH and ADAC Versicherung AG have contracted Tellja GmbH, Solmsstrasse 12, 60486 Frankfurt am Main, with the implementation of their “customers solicit customers” programme. For this purpose, this company processes personal data under its own responsibility. ADAC Finanzdienste GmbH and ADAC Versicherung AG have no control over or responsibility for such data processing by Tellja GmbH.

You can informally object to such processing of your personal data by letter to Tellja GmbH, Solmsstr. 12, D-60486 Frankfurt am Main or e-mail to support@tellja.de.

Tellja GmbH’s privacy notice is available at https://www.tellja.de/de/disclaimer.html.

4.9 Further information on the duration of data storage

In addition to the storage duration or deletion times we described above when explaining the specific processing purposes, we generally delete personal data as soon as there is no longer good reason for us to continue storing them.

We may also store personal data if this is required by Union or Member State laws or regulations, laws or other provisions to which we as the controllers are subject. Unless required to retain the data for the conclusion or performance of a contract, the controller will make the data unavailable or erase them upon expiry of the storage periods defined in the above-mentioned legislation.

5. Right to object and unsubscribe from newsletter

If you voluntarily provide data or use features of the platform that you can delete or deactivate yourself, you can make changes online at any time. After that we will no longer collect and process your data. If you withdraw your consent, we will no longer process your data for the purpose you consented to. Moreover, we delete data where there is no other legal basis for continuing to process such data (e.g. performance of a contract).

Where we process your personal data relying on a legitimate interest, Art. 6(1)(f), GDPR, you can object to such processing at any time. We will then no longer process your personal data unless we prove compelling legitimate grounds for the processing which override your interests, rights and freedoms, or continued processing is required to establish, exercise and defend legal claims. 

Otherwise, you can contact us at any time stating “Werbewiderspruch“ (objection to advertising) or “Widerspruch/ berechtigte Interessen” (objection/legitimate interests)

  • by mail to ADAC e.V., Mitgliederservice, Hansastrasse 19, 80686 München/Germany
  • by fax to: +49 89 76 76 63 46
  • by e-mail to: mitgliederservice@adac.de

If you subscribe to our newsletter, you can unsubscribe at any time with effect for the future. To do so, please use the contact data given in the relevant newsletter or the contact options mentioned above.

6. Categories of recipients

We will transfer your personal data to third parties only with your express prior consent if such transfer is required prior to entering or in performance of a contract you have entered with the third party or with us, or else where we are required by law to do so.

However, we will transfer your data to recipients within ADAC (see definition in Clause 1), the ADAC regional club at your residence, ADAC mobility partners as well as agents/agencies engaged for contract formation and implementation and member relations.

In addition, we will transfer data to third-party portals such as social networks (cf. Clauses 4.1.3. and 4.6) if you use such third-party portals in connection with our platform (e.g. via social plug-ins) and consented to the transfer of data.

Finally, the categories of recipients below receive data in order to carry out the processing as described above:

  • Accounting
  • Customer Service
  • Service partners working on our behalf (e.g. hosting providers, tracking and analysis providers, etc.)

7. Transfer to third countries

Where we transfer personal data to service partners who are subject to our directives and are located outside the EU or the European Economic Area (EEA), the transfer occurs if the EU Commission has confirmed that the relevant country has an adequate level of data protection, or pursuant to the principles of the Privacy Shield and on the basis of the EU Commission’s standard contractual clauses.

8. Your rights under the GDPR

In addition to the above-mentioned right to withdraw consent for and object to data processing (see Clause 5), the GDPR gives you the rights below, which you can assert against us as the controller of your personal data:

  • Right of access
  • Right to rectification
  • Right to restriction of processing
  • Right to erasure
  • Right to be informed
  • Right to data portability

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you believe that the processing of your personal data infringes the GDPR.

 

Version: December 2019