Privacy Policy for ADAC Emergency Locksmith Service

1. Overview and Scope

The following Privacy Policy applies to the ADAC Emergency Locksmith Service, in particular to the intake of cases, the provision of emergency locksmith services, and other services provided as part of the emergency locksmith service, as well as to the handling of complaints and claims (quality management).

This privacy policy contains the information required under Articles 13 and 14 of the General Data Protection Regulation 2017/679/EU ("GDPR") and explains how your personal data is processed. All content is addressed to and applies to all genders (f/m/d). Where grammatically masculine, feminine, or neuter personal pronouns are used, this is solely for the sake of readability.

General information about the processing of your personal data on adac.de can be found under Privacy Policy for Online Platforms. For information regarding the processing of your personal data in connection with an existing ADAC membership, please refer to the Privacy Policy for ADAC Membership.

2. Name and contact details of the data controller

The data controller within the meaning of the GDPR is:

Allgemeiner Deutscher Automobil-Club e.V. ("ADAC")
Hansastraße 19
80686 Munich
Phone: (089) 7676-0
Email: adac@adac.de

3. Name and contact information of the Data Protection Officer

You can contact the ADAC’s Data Protection Officer at:

Allgemeiner Deutscher Automobil-Club e.V.
Data Protection Officer (DPO)
Hansastraße 16
80686 Munich
Email: dsb-mail@adac.de

4. Processing of Your Personal Data (Data Categories, Data Sources, Purposes, Legal Bases, Retention Period)

4.1 Case acceptance and provision of the emergency locksmith service

The processing of personal data in connection with the emergency locksmith service may, depending on the user’s choice, take place via telephone (Service Center), the “ADAC Emergency Locksmith Service Online” web service, or downstream central IT systems.

In doing so, the ADAC processes the following categories of your personal data, among others:

Master and case data

  • Title – optional,

  • First name and last name,

  • Membership number,

  • Membership tier or customer status,

  • Phone number,

  • Email address,

  • Mailing address,

  • Alternative billing address

  • Date of birth,

  • Indication of speech or hearing impairment (queried when requesting web-based assistance),

  • Door type (apartment door, front door, room door, basement door, garden door/gate, garage door, other),

  • Nature of the problem (e.g., door was closed, door was locked)

  • Incident details (e.g., date, time),

  • For scheduled service calls: date and time

  • Photographic documentation of the door opening,

  • Customer receipt (incident details, signature of the person requesting assistance),

  • Location data of the incident site (automatic detection, manual selection, or entry),

  • Comment field for additional remarks regarding the damage incident/request for assistance.

Bank details

Your personal and banking information is required for the conclusion and performance of the contract.

ADAC processes this personal data for system-supported case intake, including coverage and claim verification, location determination, the subsequent organization and provision of the emergency locksmith service, and any related follow-up services.

In order for us to provide the emergency locksmith service, you must be reachable by phone (e.g., for follow-up questions or updates). We process the phone number(s) you provide when reporting a claim exclusively in connection with that specific claim. This information will not be added to your ADAC membership records.

In order for us to provide the emergency locksmith service, you must be reachable by phone (e.g., for follow-up questions or updates). We process the phone number(s) you provide when reporting a claim exclusively in connection with that specific claim. This information will not be added to your ADAC membership records.

The location of the incident is absolutely necessary for organizing and providing the emergency locksmith service. The location can be determined using device-based location services (Emergency Locksmith Service Online, web browser), provided you have previously allowed the use of your location data on your device. If you do not wish to use device-based location services, you can manually search for and select the location of the incident or manually enter a mailing address.

If a claim is reported by phone through our Service Center or via the digital voice assistant (Voicebot) and the location of the incident could not be determined, we offer device-based location tracking. To do this, we will send an SMS message containing a web link to an ADAC website to your device, provided you have previously consented to receiving SMS messages.

If you provided us with an email address when reporting the claim, the web link will be sent to that email address (optional).

To handle business transactions, ADAC may also engage service providers and partners on a case-by-case basis (for more information, see Section 5).

Processing of Third-Party Data

To the extent that we receive data from third parties, such as relatives, companions, or fellow travelers (e.g., phone number, date of birth, name, address), in connection with the emergency key service, we also process this data to the extent necessary for providing an effective and organized emergency key service.

Sensitive Data

  • Health data (e.g., indication of speech or hearing impairment in the "Emergency Key Service Online" section)

  • Sensitive data that you provide to us via the comment function

Under certain circumstances, we may request and/or receive special categories of personal data (“Sensitive Data”) about you. Special categories of personal data require particular protection. According to Article 9 of the GDPR, this sensitive data includes, among other things, health data. In the context of the emergency locksmith service, this applies in particular to health data related to a special rate (severe disability) or the processing of a claim.

In particular, providing information about a speech or hearing impairment allows us to contact you in writing (via email or text message) if we have any questions. You may revoke the consent you have provided for this purpose at any time with future effect. You can revoke your consent by clicking the pencil icon next to “Personal Data” at the end of the online form under section 5, “Summary.” By unchecking the box for health data (“I have a speech and/or hearing impairment”), you can retract your information. Additionally, you can also send your revocation via email to datenschutz.ug@adac.de.

Ultimately, locally stored data remains on the device until it is manually modified or deleted.

Legal Basis

  • Pursuant to Art. 6(1)(b) GDPR, we process your master data, case data, and bank details for the processing and performance of the contractual service "ADAC Emergency Locksmith Service";

  • In accordance with Art. 6(1)(c) GDPR, we process your master, case, and bank data, as well as service-related data depending on the case, to fulfill legal obligations, particularly those arising from tax and commercial law. In this context, data may also be disclosed to the competent authority in accordance with legal regulations.

  • In accordance with Article 6(1)(a) and Article 9(2)(a) of the GDPR, we may also process sensitive data on a case-by-case basis with your consent, or where necessary, to enable you to submit a written request for assistance and communicate via text message or email due to a speech or hearing impairment.

  • In accordance with Article 6(1)(b) of the GDPR, we process data from third parties with their own entitlement to services for the processing and performance of the contractual service "ADAC Emergency Locksmith Service." To the extent that we do not already process data from third parties on the basis of Article 6(1)(b) of the GDPR, we process this data based on our overriding legitimate interest in providing the emergency locksmith service as emergency assistance.

  • During processing, your data may be disclosed (see also Section 5):
    The legal basis for the transfer of your data to other recipients and for the conduct of our business operations is Article 6(1)(b) or (f) of the GDPR;
    for the necessary transfer to government agencies or authorities, the legal basis is the fulfillment of a legal obligation pursuant to Article 6(1)(c) of the GDPR; Furthermore, we will only disclose your personal data to third parties if you have given your explicit consent pursuant to Article 6(1)(a) of the GDPR, where applicable in conjunction with Article 9(2)(a) of the GDPR in the case of sensitive data.

  • Pursuant to Article 6(1)(f) of the GDPR, we may process your personal, case, and banking data, as well as service-related data, based on the overriding legitimate interest of ADAC e.V.:

    • Processing legal or other matters (including potential matters) arising from the contractual relationship, for the purpose of legal enforcement (judicial dunning procedures and legal proceedings), or to defend against claims.

    • To facilitate communication in the event of a claim or to expedite the processing of the claim. This processing is foreseeable for the data subject and in their interest.

    • Direct marketing to fulfill our own economic interests.

    • For market and opinion research through surveys following an emergency locksmith service. The goal is to increase customer satisfaction and optimize our services. The respondents’ answers are not linked to a specific individual. This processing is foreseeable for the data subject.

    • Further development of emergency locksmith services as well as existing service processes and systems to achieve security, efficiency, and improvements.

4.2 Order Processing for Emergency Locksmith Services

In the event of an emergency locksmith service, ADAC additionally processes the following categories of your personal data for order processing:

  • Information regarding prior damage

  • Photographs of the situation and the property

  • Confirmation of acknowledgment of the notice regarding the risk of damage caused by opening the door (signature of the member/customer)

  • Photographs of the door before and after opening

  • Confirmation of the condition assessment (no damage or specific damage) after the door is opened (signature)

The ADAC processes this personal data in order to provide you with order processing for the emergency locksmith service as part of the ADAC emergency locksmith service.

Processing is carried out on the legal basis of Art. 6(1)(b) of the GDPR.

4.3 Complaint and Claims Processing

In order to process complaints and claims, ADAC also processes the following:

  • Photographs of the incident scene and the damage,

  • Data from cost estimates, service records, and repair invoices (on a case-by-case basis)

  • Payment details of the claimant or their representative

  • Correspondence and communications from the complainant (by mail, electronically)

4.4 Obligation to Provide Data

We require some of the personal data we request in order to fulfill contractual or legal obligations. If you do not wish to provide us with such personal data, this will limit our ability to provide our services to you. We will notify you of this in such a case.

4.5 Change of Purpose

If, in addition to the existing purposes, other purposes for data use arise, we will assess whether these additional purposes are still within the scope of the original collection purposes and are compatible with them. If this is not the case, we will inform you of such a change of purpose. If there is no other legal basis for the further use of the data, we will not process the data without your consent.

5. Recipients of Your Personal Data

To fulfill the purposes described in Section 4, ADAC transfers your personal data to the following recipients:

  • Service providers:
    In particular, call centers that handle the organization of contractual services, IT companies and service providers that store the processed data, ADAC mobility partners, ADAC emergency locksmith service partners, ADAC Versicherung AG, service providers of ADAC Versicherung AG, other third-party companies in connection with the provision of assistance or invoice processing, and partners for market and opinion research (to optimize our services).
    These parties process your personal data in accordance with our instructions on behalf of ADAC as our data processors pursuant to Article 28 of the GDPR.
    In some cases, we may also process your personal data jointly with other service providers. In such cases, we are jointly responsible for the processing of your data with the other service provider(s) in accordance with Article 26 of the GDPR. To the extent that we process your personal data under joint responsibility, we will inform you of this in this Privacy Policy and explain the details of the collaboration.

  • Other recipients:
    Public authorities (e.g., law enforcement agencies), attorneys, auditors, courts, experts.

6. Duration of Data Processing

Your personal data will be deleted as soon as it is no longer required for the purposes stated. After that, any personal data that is no longer needed will be deleted. However, personal data may be retained for the period during which claims can be asserted against ADAC. In addition, personal data will be stored to the extent and for as long as ADAC is legally obligated to do so. Corresponding obligations regarding proof and retention arise, among other things, from the German Commercial Code and the German Fiscal Code.

7. Existence of automated decision-making in individual cases (including profiling)

ADAC does not use purely automated decision-making processes in accordance with Article 22 of the GDPR.

8. Your Data Protection Rights

  • Right to access your personal data stored by us pursuant to Article 15 of the GDPR. In particular, you may request information regarding the purposes of processing, the categories of personal data, the categories of recipients, the planned retention period, and the source of any data not collected directly from you;

  • Right to rectification of inaccurate data or to have incomplete data completed in accordance with Art. 16 GDPR;

  • Right to erasure of your data stored by us in accordance with Art. 17 GDPR, provided that there are no statutory or contractual retention periods or other legal obligations or rights requiring further storage;

  • Right to restriction of processing of your data pursuant to Art. 18 GDPR, provided that you contest the accuracy of the data, the processing is unlawful but you oppose its erasure, the ADAC no longer needs the data but you require it to assert or defend legal claims, or you have objected to the processing pursuant to Art. 21 GDPR;

  • Right to data portability pursuant to Art. 20 GDPR, i.e., the right to receive data provided by you and stored by us about you in a commonly used, machine-readable format, or to request the transfer of such data to another controller;

  • Right to withdraw your consent pursuant to Art. 7 GDPR;

  • Right to lodge a complaint with a supervisory authority
    Member State of your habitual residence, your workplace, or the place where the alleged infringement occurred (Art. 77 GDPR). The data protection supervisory authority responsible for the ADAC is:
    Bavarian State Office for Data Protection Supervision (BayLDA).

  • Right to object pursuant to Art. 21 GDPR regarding the processing of your personal data based on Art. 6(1)(f) GDPR or Art. 6(1)(e) GDPR, provided there are grounds arising from your particular situation. If you object, the ADAC will no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.
    You may also object at any time to the processing of your data for market research and opinion polling purposes. In this case, your personal data will no longer be processed for this purpose.
    You can send your objection to us at any time by mail or email:
    Address: ADAC e.V., Member Services, Hansastraße 19, 80686 Munich,
    Email: datenschutz.ug@adac.de – Subject line: "Objection: Emergency Locksmith Service, Market and Opinion Research."
    The ADAC also processes your personal data for direct marketing purposes. If you do not wish to receive marketing communications, you have the right to object at any time. The ADAC will honor your objection going forward, meaning it will no longer process your data for direct marketing purposes.

You may submit your data protection request to exercise your rights in any format. To make the process easier for both you and us, please contact us via email at datenschutz.ug@adac.de, ideally including your membership or customer number, or write to the following address:

ADAC e.V., Member Services, Hansastraße 19, 80686 Munich.

As of: May 2026