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”):
- 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 affiliated to ADAC SE:
- ADAC Versicherung AG and ADAC Autoversicherung AG
- ADAC Finanzdienste GmbH
- ADAC Autovermietung GmbH
- ADAC Medien und Reise GmbH
- ADAC TruckService GmbH & CO. KG
- ADAC Service GmbH
hereinafter collectively referred to as “ADAC”, unless one of the companies above uses data protection information that differs from this privacy notice.
If you are a member of ADAC e.V., the privacy notice 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” 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.
- ADAC e.V. site notice
- ADAC regional clubs:
- ADAC Berlin-Brandenburg e.V. site notice
- ADAC Hansa e.V. site notice
- ADAC Hessen-Thüringen e.V. site notice
- ADAC Mittelrhein e.V. site notice
- ADAC Niedersachsen/Sachsen-Anhalt e.V. site notice
- ADAC Nordbaden e.V. site notice
- ADAC Nordbayern e.V. site notice
- ADAC Nordrhein e.V. site notice
- ADAC Ostwestfalen-Lippe e.V. site notice
- ADAC Pfalz e.V. site notice
- ADAC Saarland e.V. site notice
- ADAC Sachsen e.V. site notice
- ADAC Schleswig-Holstein e.V. site notice
- ADAC Südbaden e.V. site notice
- ADAC Südbayern e.V. site notice
- ADAC Weser-Ems e.V. site notice
- ADAC Westfalen e.V. site notice
- ADAC Württemberg e.V. site notice
- ADAC SE site notice and the companies affiliated to ADAC SE
- ADAC Versicherung AG site notice and the
- ADAC Autoversicherung AG site notice,
- ADAC Finanzdienste GmbH site notice,
- ADAC Autovermietung GmbH site notice,
- ADAC Medien und Reise GmbH site notice,
- ADAC TruckService Gmbh & CO. KG site notice,
- ADAC Service GmbH site notice.
In addition to using the contact details in the site notice, you can contact us by
phone: +49 89 76 76 0
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)
80686 Munich / Germany
Fax: +49 89 76 76 53 62
In addition, you canget in touch with your contact for data protection matters of ADAC Autoversicherung AG*:
c/o An den Datenschutzbeauftragten
*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 a contract. Rather, it serves the purposes mentioned below.
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.). For details about the cookies we use please refer to the cookie settings (German only). Consents obtained via the cookie consent tool shall inure to the benefit of all controllers pursuant to Clause 1.
Based on Art. 21(1), GDPR, you are entitled to object to processing that is necessary for us to pursue our legitimate interests (Art. 6(1)(f), GDPR) with effect for the future at any time.
4.1.2 Advertising and personalisation
If we process your pseudonymised data, based on Art. 21(2), GDPR, you are entitled to object to such processing with effect for the future at any time.
4.1.3 Social plug-ins
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 operators 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 operator, 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.
- Facebook data privacy
- YouTube data privacy
- Twitter data privacy
- Instagram data privacy
- Snapchat data privacy
- LinkedIn data privacy
- Xing data privacy
- Foursquare data privacy
- TikTok data privacy
4.1.4 Integration of interactive Infogram graphics and diagrams
To visualise data and optimise your user experience, we embed interactive graphics and diagrams created using Infogram.com tools in our online platform. The features are provided by Infogram, 450 Bryant Street, San Francisco, CA 94107, USA. By integrating infographics in our online platform, we aim to make an optimal range of information available to the users of our products and services.
If you visit one of our pages featuring an embedded interactive Infogram diagram, the contents will be directly downloaded from Infogram – if and after you consented to infographics embedding. For this purpose, your device will be connected to an Infogram server.
Infogram will process the personal data below:
• IP address
• Browser information
• Operating system information
• Referrer URL
• Device information
In addition, embedding infographics will involve the placement of Infogram cookies on your device.
Infogram infographics will not be embedded unless you gave your prior consent. The legal basis for such processing is Art. 6(1)(a), GDPR.
For further information please refer to the Infogram privacy information.
Embedding Infogram infographics will involve data transfers to so-called unsafe third countries, i.e. countries outside the EU/EEA whose level of data protection is not equivalent to that in the EU. Your personal data might, in particular, be transferred to and stored in the USA. Please note that the European Commission classified the USA as a country with inadequate data protection.
You might not be able to view the Infogram infographics on our online platform, if you disagree with the processing of your data in connection with Infogram as a matter of principle. This will deactivate the Infogram service and prevent data transfers to this service and potential third countries. Please note that in this case you will not be able to utilise the embedded infographics.
Alternatively, you can also block access to Infogram features in your Internet browser or your firewall.
4.2 Data processing in connection with online registration and login
You can create a user account to use the member and customer areas at adac.de and in the ADAC apps. To generate your user account and login we will process data that can be traced back to you.
First, you need to sign in on one of our online platforms to save your personal login data for the user account. For this purpose, we process the following personal data:
- ADAC membership number or customer number
- First and last name
- Your personal password
We will process the data you entered for the purpose of
- creating a user account for you;
- identifying you as a member or customer (data cross-check) and authenticating you for your online access to exclusive products, services and benefits;
- managing your user account in our system and attending to you as user within ADAC.
- recognising you when you login and being able to display your data again.
We will not store your name and post code but use these data for the first cross-check only. We will store your membership/customer number, your e-mail address and the password (encrypted) for the login.
You can view, change or delete the data stored upon registration at any time as long as you are registered and have an active contract with ADAC. Just log in to the “Mein ADAC” (my ADAC) area using your personal login data or the “Passwort vergessen” (password forgotten) function on the login page.
The legal basis for this data processing is the first sentence of Art. 6(1)(b), GDPR, since the processing of such data is required to administer and perform (i.e. enable the use of products or services via the portal) the contract. For further details, refer to the data protection information for ADAC membership and/or ADAC Versicherung AG policy holders.
As a rule, we will store/process your data only as long as you are registered at www.adac.de. We will delete your registration data upon termination of your contractual relations with us as ADAC member or customer. Also, we will delete your data if you delete your own registration. To do so, just log in to the “Mein ADAC” area and delete your registration at “Login-Daten ändern” (change login-data). Another option is to inform us at email@example.com that we are not to use the information anymore.
In connection with the processing upon registration and login, we will pass on your personal data, i.e. your membership/customer number, e-mail address and your password (encrypted) to our service partner Microsoft Ireland Operations Limited where your data will be stored according to the current security standards. Microsoft will process and store your data on EU territory. However, we cannot exclude that Microsoft transfer data to group companies in the USA and/or to sub-processors having their seat in so-called “third countries” (i.e. countries outside the EU or the European Economic Area) that according to the EU Commission have no adequate level of data protection. Any transfer of data will be based on the standard contractual clauses pursuant to Art. 46(2) c), GDPR. The standard contractual clauses are available for download at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021D0914&from=EN, but you can also request the documents from us addressing the contacts in Clause 2 above.
To run the app on a secure basis, Service Microsoft Azure B2C also collect the personal and activity-related data upon registration:
date/time, activity ID, e-mail address, membership/customer number, name of the target application, registration status (success, failed, interrupted), IP address, location, name and ID of the service used for the application, Client app, operating system, device browser, correlation ID of the activity, user agent, Azure’s ID and name of the activity and the application, registration scopes and Client information.
The above data will be processed in the framework of security monitoring, threat analysis/mitigation and deleted after a maximum of 30 days. The legal basis for such processing is our legitimate interest in data processing pursuant to the first sentence of Art. 6(1)(f), GDPR.
ADAC Versicherung AG pays commission to its agents for the initiation and conclusion of an insurance contract. The commission is determined and paid out by ADAC Versicherung AG.
In this context, ADAC Versicherung AG determines “touchpoints”.
A touchpoint is defined as a contact between an ADAC member/customer and ADAC. This includes both personal contacts in an ADAC sales office and a visit to the insurance pages on the adac.de online platform. We collect information about these contacts in order to take into account, where applicable, the contributory effects on the initiation or conclusion of an ADAC insurance product when paying out internal ADAC commissions. We only collect information that a contact (touchpoint) with ADAC has taken place. In this context, we do not store any information about the content of the contact.
A touchpoint can still only be taken into account if we can identify you personally. This data processing can therefore only take place if you are logged into adac.de at the same time as your visit or have identified yourself at an ADAC sales office by using your membership card, for example. In all other cases, we do not collect any data relating to touchpoints.
We store this information for a period of 85 days. If an ADAC insurance product is concluded within this period, we take the touchpoint into account in ADAC’s internal commissioning of the companies involved.
Processes not considered touchpoints are, for example:
If you complete an insurance application while not logged in and without providing your member/customer number.
In connection with the log-in on adac.de, a page view with time stamp and member/customer number is stored separately and made available to the commission database.
The determination of contact points (touchpoints) in a sales process is an essential source of information for calculating commission. It enables ADAC Versicherung to track the advisory/sales services provided by the companies participating in the commission system and to ensure that the agreed commissions are paid in line with performance. In addition, ADAC Versicherung uses the touchpoints to exploit the cost-cutting potential in the commission environment and also ensures that the agreed commission settlement is carried out in accordance with the contract.
The legal basis for processing this data is our legitimate interest, Art. 6 para. 1 sentence 1 lit. f GDPR.
4.3 Data processing in connection with “Mein ADAC” (my ADAC)
At Mein ADAC, ADAC members or customers can access an overview of their ADAC contracts and ADAC products and view and change, if applicable, their personal data 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.
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 of the processing is Art. 6(1)(a), GDPR.
We process the following data for the purposes as follows:
- Vehicle (nick)name/picture for fast identification at Mein ADAC.
- 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
- 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 delete 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 (legal period of limitation: three to thirty years). In addition, ADAC 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.
ADAC credit card/ADAC Pay
- You will receive an overview of your active ADAC credit cards or ADAC Pay for your information
- The type of card, the truncated credit card number and the card holder will be visible
- You concluded the ADAC credit card and ADAC Pay contracts through ADAC with Landesbank Berlin AG. ADAC additionally provides support handling enquiries about ADAC credit card/ADAC Pay products and services.
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 legal basis for this is your consent, Art. 6(1)(a), GDPR. For details on the processing please refer to the cookie consent tool we use (cookie settings, German only).
In connection with the data warehouse, cookies, tags or web beacons are used. For details please refer to the cookie banner or the cookie settings at the bottom of each page on www.adac.de (cookie settings, German only).
4.5 Contact, chat and FAQs
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)(a), 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 smart FAQ features. For both features we use a service partner who processes your entries on our behalf.
If you use the smart 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)(f), GDPR).
In connection with the chat, cookies, tags or web beacons are used. For details please refer to the cookie banner or the cookie settings at the bottom of each page on www.adac.de (cookie settings, German only).
On our website you have the option to subscribe to a newsletter. Newsletter subscription is free of charge and optional. We use a double opt-in subscription process. This means that after your subscription we will send you an e-mail to the e-mail address indicated, asking you to confirm that you wish to receive our newsletter. If you do not confirm your subscription, your information will be blocked and automatically deleted after a month.
After you confirm your subscription, we will store and use your e-mail address to regularly send you our newsletter. The legal basis for such processing of your data is your consent according to Art. 6(1)(a), GDPR. The controller in relation to data processing for the purpose of sending the ADAC newsletter is ADAC e.V (cf. Clause 2).
The e-mail address you provided upon newsletter subscription will be exclusively processed for regularly sending our newsletter. If you are already a member/customer of ADAC, we will personalise the newsletter using the contact data (e-mail address, name) which you provided when signing up for membership/becoming a customer. If you are not yet a member/customer of ADAC, your other personal data (e-mail address, name) will exclusively be processed for providing the ADAC newsletter.
The data will be deleted 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.
In connection with data processing for sending newsletters we do not transfer any data to third parties.
To constantly enhance our newsletter service, we anonymously analyse your user behaviour after sending the ADAC newsletter.
For this purpose, we measure, for instance, the open and the click rates for individual content of the ADAC newsletter. These data are exclusively processed in an anonymised form and are not linked to your personal data. Hence they do not enable us to identify you as an individual directly.
You may revoke your consent to receive the newsletter at any time (contact data cf. Clause 5). Please note that your revocation exclusively has effect for the future. Your revocation does not affect any processing performed before the revocation. To unsubscribe from the e-mail newsletter, please click the link “Newsletter abbestellen”. Alternatively, unsubscribe by visiting (logging into) the website on which you subscribed to the newsletter. Otherwise, you can send us your revocation at any time stating your e-mail address and “Abbestellung Newsletter” (unsubscribe from newsletter) (contact data cf. Clause 5).
However, we will process your revocation and/or unsubscription as soon as reasonably possible. We will stop sending you the newsletter immediately upon unsubscription. If you unsubscribe from the ADAC newsletter or object to data processing by mail or e-mail, we are unable to guarantee immediate implementation.
For future reference, your consent and subscription as well as your revocation of the consent and/or unsubscription from the newsletter are stored for a two-year period after the revocation takes effect. In addition, we store personal data exclusively to enforce or defend legal claims or for the storage period as required by law.
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.
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 when you interact with us (e.g. that you are fan of our Facebook page or subscribed to our YouTube channel). 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 contact 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 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/service 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. They 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 the Facebook Insights tool and the entire Facebook fan page are services provided by Facebook Inc.
As the operator 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.
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
4.8 Customers solicit customers
ADAC Finanzdienste GmbH and ADAC Versicherung AG have contracted Tellja GmbH, Solmsstrasse 12, 60486 Frankfurt am Main, Germany, 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, Solmsstrasse 12, D-60486 Frankfurt am Main or e-mail to firstname.lastname@example.org.
Tellja GmbH’s privacy notice is available at https://www.tellja.de/de/disclaimer.html (in German only).
4.9 Car rental booking
If you want to use services that require the conclusion of a contract, we will ask you to disclose the necessary personal data we need for establishing and performing the contract (e.g. first name, last name, date of birth, e-mail address, preferred method of payment, if applicable, and holder of the account) and perhaps other data you might want to disclose such as flight number and airline. We will collect and process such information in the framework of the booking process. The legal basis for this processing is Art. 6(1)(b), GDPR, (performance of contract) and Art. 6(1)(a), GDPR, (consent).
We need this information to handle the booking for the reasons set out in the following. Please notice that when booking a rental car you conclude two contracts: one service contract with us and another contract with the provider of the rental car you selected. To be able to bring about the contract on your behalf, we need to transfer the data required for the contract to the provider. Below we explain which data we collect and which data we transfer to the provider you selected.
- We need your name and address to conclude the service contract. The provider needs your name and address for identification purposes.
- We need your e-mail address to send you the confirmation, the invoice and the rental car voucher we receive from the provider. We will disclose your e-mail address to the provider only if it is necessary that the provider contacts you directly by e-mail.
- We will use your telephone number to contact you in a matter of urgency such as, for instance, a wrong booking. We will pass on your telephone number to the provider you selected. It will be used, for instance, if the provider is informed that you left the rental car in a no stopping zone.
- We will ask for your date of birth to verify that you have the age for renting a car and, potentially, point out alternatives to you. We will also transfer your date of birth to the provider.
- For the payment of the rental car the provider needs your payment data: your credit card or your banking details. We will transfer such data to the provider or its authorised payment intermediary. We will use your payment data to collect the payment.
Please note that we will not permanently store your credit card data (card number, CSV and expiry date), but process them to send encrypted data to the provider you selected.
Online payment methods for payment of rental car bookings
If you select a prepayment rate, you can choose between two online payment methods: credit card (VISA/MasterCard) or PayPal.
In order to execute the payment and collect the credit card payments, we use BS PAYONE (PAYONE GmbH, Daniel-Goldbach-Str. 17-19, 40880 Ratingen, Germany), and PayPal (Europe) S.à r.l. et Cie, S.C.A. (R.C.S. Luxembourg B 118 349) for PayPal payments. We concluded a pertinent data protection agreement with both payment intermediaries.
The payment is being made under the responsibility of the relevant payment intermediary. Users enter their payment data directly on the payment intermediary’s encrypted website (e.g. via PayPal Login). We do not have access to such data. Our website only contains the information whether payment was successful or failed. Data transfers to the payment intermediary and transfers of pseudonymised data are encrypted.
The data protection provisions of the relevant payment intermediary apply for which we are not responsible and which are beyond our control.
Go to https://www.bspayone.com/DE/de/privacy for the privacy information of BS PAYONE (not available in English).
Go to https://www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE for the privacy information of PayPal.
4.10 Information on data protection in the recruitment process
The information below applies to the recruitment process on the career site at https://karriere.adac.de operated by ADAC e.V., ADAC SE, ADAC Stiftung (foundation) and their affiliated companies as well as the ADAC regional clubs. The controller as defined in Art. 4(7), GDPR, in relation to the collection, processing and use of your personal data is the company that posted the job vacancy.
Your data will be processed on our behalf pursuant to Art. 28, GDPR, and hosted by our service partner rexx systems GmbH, Süderstrasse 75-79, 20097 Hamburg, Germany. Both ADAC and this service partner use technical and organisational measures to protect your data against accidental or intentional manipulation, loss, destruction or third-party access. Our security safeguards are being enhanced on an ongoing basis in line with the technological developments.
Processing of personal data under the GDPR
When you visit our career site, our web servers store the IP address you received from your Internet service provider for two months in order to clarify potential cases of fraudulent use, the website from which you visit, the web pages you visited and the date and duration of your visit. After you entered your application data, by clicking “send” you transfer your personal data (first name, last name, address, telephone, e-mail and residence status) to us for the purpose of verification before entering a contract with you (legal basis: Art. 6(1)(b), GDPR). The data are protected by the SSL encryption protocol and transferred to a server of our service partner and – if the transfer was successful – stored in the central applicants database of ADAC SE. If after your registration you log on using the provided user information, this logon is protected by SSL encryption as well. Your application data can be accessed by the staff of the relevant human resources department of ADAC. In addition, your application data will be provided to the executive staff or an authorised representative of the recruiting ADAC department. Your application data will not be provided to other companies within ADAC unless with your written or electronically documented consent, and the data will never be shared with any companies outside ADAC. ADAC takes all reasonable steps to ensure that your application data and documents are treated confidentially and with care. Your application data and documents will be anonymised or deleted from the central applicants database six month after the end of the recruitment process, unless you provided us with your express written or electronically documented consent to saving the data for a longer period. The anonymised data will exclusively be used for statistical analysis.
If the recruitment process leads to employment, we will include your application documents, where necessary, to your personnel file on the basis of Art. 6(1)(b), GDPR, and Art. 26(1) of the German Federal Data Protection Act, to have information about your personality profile and qualifications. In such a case, your application documents will be deleted and destroyed not earlier than ten years after the end of the year in which your employment ended.
In addition, we offer you the possibility to pull profile information from your Xing or LinkedIn profile for the application. Should you want to use this possibility, you will be asked to sign in on the Xing or LinkedIn platform and allow ADAC to access your profile information.
If you apply on your own accord and selected “keine Angabe” (none) when queried in which region you seek employment, we will make your application documents available to all companies within the ADAC group. We will delete and destroy your application data two years after receiving your unsolicited application, however not before a period of six months elapsed after your or our final refusal of employment in relation to any recruitment processes in which your application documents were used. The purpose of processing is a potential contract (legal basis: Art. 6(1)(1)(b), GDPR).
Pool of candidates for “emergency paramedic/emergency medical technician” for ADAC Luftrettung gGmbH.
With your application, you register in the pool of candidates for employment with ADAC Luftrettung gGmbH. In your profile, you can save your potential fields of employment and your application documents.
With your registration, you accept that ADAC Luftrettung gGmbH collects, processes and uses your personal data for a maximum of three years after the end of the year your application was received. Any longer use of the data will be subject to the applicant’s consent in an electronic or written form.
ADAC Luftrettung gGmbH’s pool of candidates for employment serves for recruiting and filling vacancies in ADAC Luftrettung gGmbH on an ongoing basis, as well as supporting applicants, in particular informing them about vacancies and relevant events and trade fairs.
For certain roles, ADAC will host an assessment centre in the framework of the recruitment process. In this context, ADAC also collects and stores personal data, i.e. the results and evaluations from the assessment centre, for the purpose of selecting candidates for a specific position. The legal basis for this is Art. 6(1)(b), GDPR, to initiate and perform a contract.
You can sign up to our job agent. In this case you will receive e-mail notifications of upcoming vacancies to fill in the area you selected. Your e-mail address will be used exclusively for sending the job agent notifications. The legal basis for such processing of your data is your consent in line with Art. 6(1)(a), GDPR. You can revoke your consent at any time. Please use the unsubscribe link at the bottom of all info e-mails or contact us at email@example.com.
You may withdraw your consent to your personal data being processed in the framework of the recruitment process at any time. Please send an informal letter to the contact mentioned in the job advertisement or an e-mail to firstname.lastname@example.org stating the job title. Upon receipt of your letter or e-mail, the recruitment process will end for you and your personal data will be blocked (and their processing restricted) not later than within five working days and finally deleted after further six months (period required for the establishment, exercise or defence of legal claims).
Your privacy rights as a data subject
Cf. Clause 8
Your privacy and data security contact information
Cf. Clause 3
4.11 ADAC Maps – the route planner
You can use ADAC Maps to plan your travel routes accessing further useful information about e.g. traffic jams, toll charges and points of interests. In the above context, we process your personal data as set out below.
If you used your ADAC login, you can save your personal routes in the system for access at a later time. You can manually delete your saved routes at any time. Processed data:
- Membership no.
- Route start and end point
Fuel price calculation and customisation
For the purpose of calculating your vehicle’s fuel charges you can customise the fuel price setting. To prevent you from having that you have to repeat this setting for every route, this value will be saved in a cookie that autodeletes after 365 days. This cookie is technically relevant to provide this key functionality. For further details please refer to the cookie consent tool we use (cookie settings, German only).
We process the usage data to provide the service. It is justified in that the processing is required to perform the contract between you and us in accordance with Art. 6(1)(b), GDPR, on the use of the web function.
Anonymous analysis of routes
We analyse anonymised data of the calculated routes to ensure uninterrupted system function and improve ADAC’s line of products/services. This relates to route start and end points, the calculated duration and distance. No route can be traced back to you. The basis is our legitimate interest in data processing pursuant to Art. 6(1)(f), GDPR.
4.12 ADAC emergency key service
To perform the contract in relation to the emergency key service, we process your data below:
Types of personal data
- Salutation/title, first and last name, address, gender and phone number (together “master data”)
- Bank details
Your master data and bank details are required for concluding and performing the contract.
Purpose of processing and legal basis
- Pursuant to Art. 6(1)(b), GDPR, we process your master data and bank details to manage and perform the emergency key service.
- Pursuant to Art. 6(1)(c), GDPR, we process your master data and bank details to comply with our legal obligations including, without limitation, under tax and commercial law.
- Pursuant to Art. 6(1)(f), GDPR, we can process your master data and bank details in relation to the following purposes to pursue the named legitimate interests of ADAC e.V.:
- handling of legal or other issues (including potential issues) arising from the contractual relations, legal pursuit (judicial collection procedures and legal action) or defence
- market and opinion polling to pursue our commercial interests and enhance our products/services
Categories of recipients
ADAC is cooperating with:
- Emergency key service partners
- Service partners who organise the provision of the contractual services
- Service partners who store processed data
- Accountancy partners
We concluded a pertinent data protection agreement with these partners.
4.13 ADAC marinas guide/ADAC skippers portal
On the ADAC skippers portal we offer comprehensive information that might be of use for you as a skipper.
Processing of your data
In the framework of the service we offer we process your personal data as set out below:
- Members’ rating of harbours:
This gives you the possibility to post your experience for other members and read other members’ reviews.
Categories of processed data:
First name, last name, membership no., postcode and e-mail address, your review
Harbour reviews are posted on a voluntary basis and by ADAC members only. Reviews are verified by us based on the data mentioned above. Your comments are visible for all users of the ADAC skippers portal showing your first name and the first letter of your last name. Data processing is based on our legitimate interest pursuant to Art. 6(1)(f), GDPR.
- Purchase of the “Seenland” (lakeland) magazine:
Categories of processed data:
Your e-mail address we receive from you sending your order as well as your first name and last name and address (street, number, postcode, place) to deliver the magazine by mail.
Such processing is justified in that it is required to provide the service in line with Art. 6(1)(b), GDPR, (performance of contract).
- Boat market:
Categories of processed data:
Your name, your e-mail address and your customised request, your phone number (optional)
The transfer of your contact data collected on our ADAC skippers portal to boat24.com will be actively prompted by you. Marine Classified Media AG will then handle any liaison with the seller and potential further processing of your data under its own responsibility. ADAC will not store your contact data.
Data processing is based on our legitimate interest pursuant to Art. 6(1)(f), GDPR.
If you want to place an advertisement, you will be directed to the boat24.com platform via a link.
- Yacht charter comparison and booking portal:
If you want to enquire about or reserve or book a charter boat, you can use the contact form provided on our ADAC skippers portal.
Categories of processed data:
Your name, your address, your phone number, your e-mail address, your customised request (optional), customer number or company name
The transfer of your contact data collected on our ADAC skippers portal to bootsreisen24.de or chartercheck.com will be actively prompted by you for further attention. After that, CharterCheck GmbH will be responsible for the processing of your contact data. ADAC only processes your contact data for the purpose of referral. No other processing will take place.
Data processing is based on our legitimate interest pursuant to Art. 6(1)(f), GDPR.
- Share page via e-mail, Facebook, Twitter:
You can share interesting articles with friends by e-mail or on Facebook or Twitter under your own responsibility. Actively prompted by you, the selected communication channel will pop up and the website’s URL will be transferred to the communication channel.
- Google Maps:
On our website we use Google Maps. Google Maps is a service operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The Google Maps plug-in is embedded on our website by an iFrame. When loading this iFrame, Google might also collect and process data (including personal data). Therefore, we cannot exclude that Google transfers the information to a server in a third country.
We do not collect any data ourselves if you use Google Maps via our website.
Our purpose of embedding Google Maps is to be able to provide you with maps and nautical chart data and offer further information for your journey. By embedding Google Maps, we can also present places whereby you will not be restricted to individual map sections and can do your own research of, for instance, distances.
The legal basis for the processing of personal data described above is Art. 6(1)(f), GDPR. Our legitimate interest lies in the huge benefit Google Maps offers. Embedding this feature, we can present the maps and nautical charts you need and users can plan their own nautical routes or stopovers. Also, Google has a legitimate interest in the collected (personal) data in order to improve its own service.
Right to object
You have the right to object. You can send or inform us of your objection at any time (e.g. by e-mail to email@example.com). The provision of the personal data is neither prescribed by law nor by contract and is no condition precedent for concluding the contract. Also, you are not obliged to provide your personal data. However, if you do not provide your data you might not be able to use our website or all features provided.
For details about Google’s security and privacy settings go toGoogle privacy settings
While using Google Maps, Google will transfer data to group companies and/or sub-processors. In this context your personal data might be transferred to and stored in the USA. Please note that the European Commission classified the USA as a country with inadequate data protection. Any transfer of data into the USA will be based on the standard contractual clauses pursuant to Art. 46(2)(c), GDPR. The standard contractual clauses are available for download at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021D0914&from=EN, but you can also request the documents from us addressing the contacts in Clause 2 above.
4.14 ADAC Fahrzeugwelt (vehicle leasing platform, German only)
ADAC Fahrzeugwelt is an online platform operated by ADAC SE to facilitate leasing preconfigured new vehicles. Its offerings address ADAC members who want to order a new vehicle at fair conditions and with membership benefits online from our partner Mobility Concept GmbH, Grünwalder Weg 34, 82041 Oberhaching, Germany. Mobility Concept GmbH is a partner of ADAC and operate under its own responsibility.
Processing of your data
In the framework of the service we offer we process your personal data so that you can request an offer for a leasing car from our partner Mobility Concept GmbH and we can provide you with comprehensive member support.
- Requesting a leasing offer
So that you can enjoy your membership benefits and request an offer for a leasing vehicle from our partner Mobility Concept GmbH we collect your contact and identification data (membership number, first name, last name, e-mail address, phone number) as well as your vehicle and configuration selection (e.g. vehicle type, colour, mileage, term of the lease, down payment, optional add-on benefits such as, for instance, maintenance package) on our ADAC Fahrzeugwelt platform. To verify your entitlement we will check the provided membership data against our member database.
After collecting the data mentioned above, we will, prompted by you, digitally pass them on to our cooperation partner Mobility Concept GmbH (lessor) who will act under its own responsibility. Then you will be referred to the website of our partner Mobility Concept GmbH for further handling of your request.
The above processing of data by ADAC serves to provide the service we offer. The legal basis for this is Art. 6(1)(b), GDPR.
Any other processing of the data transferred by ADAC to Mobility Concept GmbH as well as the operation of the website of Mobility Concept GmbH and any further collection of data by Mobility Concept GmbH will be initiated by Mobility Concept GmbH under its own responsibility.
- Customer contact form
You can use the customer contact form provided on the website of ADAC Fahrzeugwelt to submit requests for direct response by ADAC or – where the query relates to a specific vehicle on offer – our partner Mobility Concept GmbH. In the latter case, we will pass on your request in your own interest to Mobility Concept GmbH.
With the customer contact form we collect your contact data such as salutation/title, first name, last name, e-mail address, membership number, offer number, phone number and your enquiry text for processing for the purpose of providing you with a response.
Mandatory fields relate to information that we need to contact you and reply to you (e.g. if you wish to be called back, we need your phone number, and if you wish to be contacted by e-mail we need your e-mail address). Optional fields are marked “optional”.
We process the above data to provide the service we offer. The legal basis for this is Art. 6(1)(b), GDPR.
The data will be processed by ADAC to the extent possible. If you have questions about the leasing offer itself or about specific service features, we will pass your enquiry on to our partner Mobility Concept GmbH in your own interest. Data processing is based on the legitimate interest pursuant to Art. 6(1)(f), GDPR.
- Data storage
Your data will be stored in an ADAC computing centre in Germany for a period of three years and then deleted for want of purpose.
4.15 Application for ADAC credit card
If you apply for a credit card from ADAC Finanzdienste GmbH, we process your personal data to handle your credit card application. We will transfer these personal data to our cooperation partner issuing the credit card: Landesbank Berlin, Alexanderplatz 2, 10178 Berlin, Germany, e-mail: firstname.lastname@example.org. The personal data below, if available, will be included in the application on Landesbank Berlin’s website:
- salutation/title, last name, first name
- address data
- date of birth
- phone number
- e-mail address
- banking details
- preferred type of credit card (colour)
To be able to handle your application for issuing you with the selected credit card product, we also transfer “key variables” to Landesbank Berlin. These are the elements of the credit card configuration you selected.
In addition to the personal data directly collected from you, we also transfer additional personal data about you to Landesbank Berlin. These additional personal data are required to verify your eligibility for being issued a credit card. This consists of the personal data below:
- information that you took out ADAC membership and the membership number
In addition to the personal data directly collected from you, we also transfer certain additional personal data about you to Landesbank Berlin in order to assess your credit risk. This consists of the personal data below:
- information that you took out ADAC Plus membership
- term of the membership
The above processing of your personal data has the purpose of providing the service you requested and implementing precontractual measures if required. The legal basis for this is Art. 6(1)(b), GDPR.
4.16 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 controller are subject. Unless required to retain the data for the conclusion or performance of a contract, the controller will make the data unavailable or delete them upon expiry of the storage periods defined in the above-mentioned legislation.
5. Right to object
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: email@example.com
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 4.7) 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:
- Customer Service
- Service partners working on our behalf (e.g. hosting providers, tracking and analysis providers, etc.)
- Rental partners
- Payment intermediaries
7. Transfer into 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), your data will be processed in such third country on the basis of the EU Commission’s standard data protection clauses only and if dedicated measures are in place to ensure an adequate level of data protection (e.g. adequacy decision by the EU Commission or appropriate safeguards, Art. 44 et seq., GDPR).
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.
Last updated: October 2022