Privacy Policy

This policy only applies to website services of FAW-Volkswagen Automotive Co., Ltd. (hereinafter collectively referred to as “us” or FAW-Volkswagen Audi Official Website”).
Latest update of privacy policy: August 5, 2020
Privacy policy version: 2.0.1

FAW-Volkswagen Automotive Co., Ltd. (hereinafter collectively referred to as us or FAW-Volkswagen Official Website”) is a legally incorporated enterprise with the registered address at [No. 5 Anqing Road, Changchun, Jilin Province]. We view your personal information and privacy protection as our top priority.
This privacy policy is intended to help you understand what types of data we collect, why we collect such data, what we do with such data, and how we protect such data.
1.In this privacy policy, we will explain to you in turn the scope of personal information collected by us (sensitive personal information may be collected for certain functions), purposes and ways of data collection, and possible consequences of refusing to offer personal information. We undertake to collect and make use of user information by strictly following legal, legitimate, and necessary principles.
2.In this privacy policy, we will explain to you how we protect safety of personal information, store personal information, and handle personal information of minors.
3.You may access, correct, or delete your personal information via the channels provided herein. You may also exercise your rights with the aid of functions of our website like complaint, consultation, and user feedback.
4.We will strictly confine the use or sharing of your personal information to the purposes defined herein. In the case of any use or sharing beyond these purposes, we will inform you and acquire your explicit consent in advance.

This policy contains the following parts:
I.Definition and scope of personal information;
II.How do we collect and use your personal information?
III.How do we use cookie and similar techniques?
IV.How do we share, transfer, and disclose your personal information?
V.How do we store and protect your personal information?
VI.Your rights;
VII.How do we handle personal information of minors?
VIII.How do we migrate your personal information across borders?
IX.Applicable laws and dispute settlement;
X.How do we update this policy?
XI.How to contact us?

I.Definition and scope of personal information

Personal information refers to various information that is recorded electronically or otherwise and can be used in combination with other information for identification of natural persons. For the purpose of this privacy policy, personal information includes basic information (name, birth date, gender, personal phone number, email address, etc.); online identity information (account tied to personal information, IP address, personal digital certificate, etc.); personal education & work information (profession, title, employer, educational degree, etc.); online personal activity records (website browsing record, click record, etc.).

Sensitive personal information refers to personal information that, once divulged, illegally offered, or misused, may endanger personal and/or property safety, and may easily lead to damage to physical or mental health or discriminatory treatment. For the purpose of this privacy policy, sensitive personal information includes other relevant information (system account, IP address, email address, and passwords therefor).

Anonymized information refers to information that has received such irreversible technical treatment that disables identification of any subject of personal information. Anonymized information is not regarded as personal information.
Other information that does not contribute to identification of natural persons or determination of their activities is not regarded as personal information.
The above definitions and explanations of “personal information”, “sensitive personal information” and “anonymization” are quoted from GB/T35273 Personal Information Security Specification.

II.How do we collect and use your personal information?

We will collect and use your personal information according to the business functions and purposes set forth herein:
Website business functions are divided into basic and extended functions. We will describe in details personal information collected for different business functions, method and purpose of information collection, and how the information is used.

1.Personal information collected and used for basic business functions

Personal information collected and used for basic business functions mainly refers to information required by us for providing you with core basic functions related to social intercourse and car sale services. Collection of such information is a prerequisite for availability of these services. If you refuse to disclose the information, you may be unable to get access to corresponding products/services.
· When you register an account, we need to obtain your mobile phone number and password to complete your account registration procedure.

2.Personal information collected and used for extended business functions

Extended business functions are additional functions or services offered to you by Audi Official Website. They are intended to make available better products or services or improve our products or services. Fulfillment of such functions also necessitates collection and utilization of certain personal information.

If you are unable to or refuse to authorize use of such personal information by us, it is possible that we will not grant you access to corresponding extended functions, though use of core basic functions of Audi Official Website will not be impacted.

You may cancel authorization for use of your personal information by different extended functions separately.
· When you use the test drive function, we will collect choices you have made including interested dealer, interested model, and interested test drive time. We will use your name and mobile phone number in addition to the above choices. We will share such information with your interested dealer, who will then contact you, agree on a test drive schedule with you, and provide you with test drive service;
· When you use the second-hand car purchase function, we will collect choices you have made including interested dealer and interested model. We will use your interested purchase time, your name and mobile phone in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired second-hand car purchase service;
· When you use the second-hand car sale function, we will collect choices you have made including interested dealer and the model of your car. We will use your interested sale time, your name and mobile phone in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired second-hand car sale service;
· When you use the second-hand car trade-in function, we will collect choices you have made including interested dealer, the model of your car, and interested model. We will use your interested trade-in time, your name and mobile phone in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired second-hand car trade-in service;
· When you use the second-hand car assessment booking function, we will collect choices you have made including interested dealer and the model of your car. We will use your interested assessment time, your name and mobile phone in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired second-hand car assessment service;
· When you use the dealer base price function, we will collect choices you have made including interested dealer, interested model, and interested service time. We will use your name and mobile phone number in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired dealer base price service;
· When you use the model brochure request function, we will collect choices you have made including interested car series and interested model. We will use your name and mobile phone number in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired model brochure request service;
· When you use the car purchase information function, we will collect choices you have made including interested dealer, interested model, and interested consultation time. We will use your name and mobile phone number in addition to the above choices. We will share such information with your interested dealer, who will then contact you and provide you with desired car purchase information service;
· When you use the large customer car purchase function, we will collect choices you have made including interested model and interested purchase time. We will use your name and mobile phone number in addition to the above choices. We will share such information with corresponding service provider, who will then contact you and provide you with desired large customer car purchase service;
· When you use the landing page lottery function, we will collect and use your name, phone number, address, and interested dealer. We will share such information with your interested dealer, who will then contact you and provide you with desired service;
· We constantly improve our products and services through internal audit and data analysis and research. Your choices and feedback at Audi Official Website are of great value to such improvement. In order to track your feedback, Audi Official Website may contact you with the personal information you have provided, and keep pertinent records. We will use collected information as input to our product/service analysis so that we and our related parties can optimize our products and services. Your information will also help us design product/service operation schemes, facilitate our product/service evaluation, maintenance, and improvement, contribute to our development of new products/services, and enable us to support customers more satisfactorily.
· By accepting the provisions herein, you agree to authorize us to obtain from FAW-Volkswagen’s service suppliers, licensed dealers, and your social media (platforms) and telecom operators (hereinafter abbreviated as “Information Collectors”) your other personal information (including name, birth date, gender, ethnic group, address, personal phone number, and email address), personal identity information (ID card), online identity information (account tied to personal information), personal education & work information (profession, title, educational background, and academic degree), personal online activity records (website browsing record, software use record, and click record), and information on frequently used personal devices (hardware serial number, device MAC address, and unique device identification code). You agree that we make use of the above information and other information which you allow us to collect and obtain according to provisions herein for improving quality of relevant products/services and user experiences and in our product/service promotion programs.

3.Exceptions to prior consent/authorization

Please note that in the following circumstances, your prior consent/authorization is not required for collection of your personal information:
· Cases directly related to national defense or homeland security;
· Cases directly related to public security, public health, or major public interests;
· Cases directly related to criminal investigation, prosecution, trial, or judgment execution;
· Your life or major legal rights such as property rights need to be protected but it’s difficult to obtain your consent;
· Your personal information collected is disclosed to the public on your own;
· Your personal information is collected from legally disclosed information such as legal coverage or government statement;
· Your personal information is necessary for providing a product or service you’ve requested;
· Your personal information is necessary for maintaining safe and reliable operation of a product or service you are using, e.g., for handling product/service failures;
· Other cases as required by laws and regulations.

III.How do we use cookie and similar techniques?

3.1We use cookies, labels, scripts, and similar terminal data collection and storage techniques.
· Cookie is a mechanism that supports information storage and retrieval on clients from servers (or scripts). Cookie files are small in size. They can be stored in your computers or mobile devices.
· When you use our website, we may collect and store information with the aid of cookies or similar techniques. Such information may be related to your preferences or devices, and are rarely used directly for personal identification.
· Cookie technique is intended to create more convenient and safer access experiences, to improve products, services, and user experiences, or to discover and prevent against safety risks in a timely manner for higher service quality. Such cached information mainly includes user personal settings and temporary website operation parameters.
· You may keep or delete cookies depending on your preferences. All software-stored cookies can be removed. Your corresponding personal information will be deleted together with the cookies.
· We take strict measures to ensure safe use of cookies and avoid any inconvenience to you.
3.2Log file
· Like most websites and mobile applications, we collect certain information and save it in log files. Such information may include Internet policy (IP) address, Internet service provider (ISP), operation system, date/time stamp and/or click stream data. We will not link any automatically collected data to your other information. We take strict measures to ensure safe use of relevant techniques and avoid any inconvenience to you.
3.3Website analysis
· We may use website access analysis software to gain a better understanding of online traffic conditions. Such function may record information like your website access frequency, events in the website, and performance. We will not link any information stored in the analysis software to any personal information you submit at the website. We take strict measures to ensure safe use of relevant techniques and avoid any inconvenience to you.

IV.How do we share, transfer, and disclose your personal information?
1.Sharing

Because some of our services are provided by licensed partners, FAW-Volkswagen may supply your personal information to third parties like partners. We undertake that we only share your personal information on a legal, legitimate, necessary, specific, and explicit basis.

Our licensed partners have no right to use personal information shared by us for any purposes other than those permitted by this policy. If any licensed partner plans to use your personal information for any unspecified purpose, we will acquire your authorization/consent again.

Prior to sharing of information with a third party, we will evaluate its data security capabilities and enter into a data confidentiality or non-disclosure agreement containing stringent provisions, requesting implementation of confidentiality and security measures regarding use of such information as instructed by us and as required by this privacy policy. If we share or supply your personal information to any party not belonging to the following types, we will acquire your explicit consent in advance.
The third parties we may share your personal information with based on authorization include:
· Data analysis service suppliers, including Adobe, Miaozhen Systems, and QuickA+. In order to improve or promote our products/services, we will adopt relevant products or services offered by data analysis suppliers. We will supply them with necessary personal information. We will only perform user portrait analysis based on group data, and will not portray any individual user separately.
· Associated companies of FAW-Volkswagen. The product, R&D, and operation functions related to our website are distributed in FAW-Volkswagen and its associated companies, among which FAW-Volkswagen Sales Co. Ltd. plays a major role. In order to improve our products or services or provide you with new products or services, we will share your personal information with associated companies of FAW-Volkswagen. Such companies are only limited to associated organizations with a control or affiliation relation with FAW-Volkswagen.
· Licensed dealers of FAW-Volkswagen. When you use the test drive function as described in Section II of this privacy policy, will we send your name, contact information, interested model, and interested test drive time to the licensed dealer of FAW-Volkswagen you have chosen so that you can get access to desired test drive service.

2.Transfer

We will not transfer your personal information to any companies, organizations, or individuals other than associated companies of FAW-Volkswagen, except in the following circumstances:
· We’ve obtained your explicit authorization or consent before such transfer;
· FAW-Volkswagen is required to transfer such information according to laws, regulations, legal procedures, or compulsory government order or judicial ruling;
· We transfer such information in line with the provisions of other legal documents (such as this policy) signed by you;
· In cases involving merger, acquisition, or insolvency liquidation, if transfer of personal information is necessary, we will procure that any company or organization receiving your personal information will be bound by this privacy policy, otherwise we will request that company or organization to obtain authorization/consent from you again.

3.Public disclosure

We will not disclose your personal information to the public, except in the following circumstances:
· We’ve obtained your explicit consent to such disclosure;
· Legal disclosure: We may disclose your personal information to the public as required by laws, legal procedures, proceedings, or compulsory government order.
Obtaining authorization and consent from relevant subjects is not required for public disclosure of personal information in the following circumstances:
· Cases directly related to national defense or homeland security;
· Cases directly related to public security, public health, or major public interests;
· Cases directly related to criminal investigation, prosecution, trial, or judgment execution;
· Life or major legal rights such as property rights of an information subject need to be protected but it’s difficult to obtain consent of the subject;
· The personal information collected is disclosed to the public by the information subject;
· The personal information is collected from legally disclosed information such as legal coverage or government statement;

V.How do we store and protect your personal information?
1.Storage site

Your personal information will be stored within the territory of the People’s Republic of China. Except in cases where data transmission to foreign countries is required when you use FAW-Volkswagen products/services overseas, if cross-border data transmission is needed, we will clearly inform you of the purpose, receiving party, and security measures for such transmission, and obtain your prior authorization/consent.

2.Storage period

2.1 As long as you use services of our website, we will maintain your personal information.

2.2 After you have applied for deletion of your personal information or cancellation of your account, we will keep your personal information for a minimum period as required by laws and regulations. In this period, we will not make any commercial use of your personal information. Upon expiry of such period, we will anonymize your personal information.
3.Security measures

FAW-Volkswagen adopt adequate security measures and technical means in compliance with recognized industrial standards to store and protect your personal information, preventing it against loss, misuse, unauthorized access, theft, tampering, or destruction.

3.1 We use the following security measures to protect your personal information:

a.Encryption-based transfer protocols are adopted for data transmission;
b.Data access rights are strictly controlled and supervised, especially those concerning batch data operations;
c.Systems to be brought online are subject to security tests including vulnerability scan and penetration test. All risks discovered are adequately addressed;
d.Data backup and recovery and data availability tests are performed regularly;
e.A data security monitoring and audit system is put in place for comprehensive data security control.

3.2 We also take other safety precautions for your personal information:

a. A corporate confidentiality and information security committee centrally coordinates information security work and implements various information security measures. Internal personal information protection rules are also stablished and adopted throughout our company;
b. Any online system launch or any major functional modification is preceded by an evaluation of impact on safety of personal information (including user personal data);
c. A non-disclosure agreement is signed with the whole staff of our company and all members of outsourcing contractors. Data access rights are assigned in strict accordance with work responsibilities.
d. Information security education and training sessions are held regularly for the whole staff of our company and all members of outsourcing contractors.

3.3 Security accident handling

a. In order to properly address potential safety risks such as personal information leakage, destruction, or loss, we have established complete safety test procedures, internal handling procedures (including those for emergency response), and correction measures for systems to be brought online.
b.After occurrence of any security event, we will inform you of the event and risks concerned in a timely manner, together with security measures we have taken or will take and recommendations for mitigating the risks;
c.We will inform all users affected by the event of latest conditions of the event by means of pushed notification or telephone. If it is not possible to notify all users separately, we will make a public statement at our platform to alert users.

VI.Your rights

FAW-Volkswagen fully respects your personal information, and do all we can to assist with your personal information management. We ensure that you can exercise the following rights in your personal information:

1.Access and change your personal information

1.1 Access your personal information. You may log into your account and view your personal information via the Personal Center at the website. You may also contact customer service center of FAW-Volkswagen (4008-171-666) for consultation. We will respond to your request within 30 working days.
1.2 Change your personal information. When you plan to update your personal information or discover any error in your personal information collected and stored at the website, you have the right to correct or modify it. You may access Personal Center – Change Personal Information to correct or modify your personal account information, change your password, and change your mobile phone number. You may also contact the customer service center of FAW-Volkswagen (4008-171-666) for consultation or send email to service@audi.cn. We will respond to your request within 30 working days or a period required by laws or regulations after confirmation of your request.

2.Change the scope of your authorization/consent or cancel your authorization/consent

We protect user right to cancel authorization/consent through the following measures:
You may contact the customer service center of FAW-Volkswagen (4008-171-666) or send email to service@audi.cn to change your authorization/consent.
After you cancel your authorization or consent, we will not use corresponding personal information. This may prevent us from providing you with previously authorized services. Your cancellation of authorization or consent will not impact any treatment of your personal information based on authorization before the time of cancellation.

3.Delete your personal information

In any of the following circumstances, you may contact us with the information provided in Section XI “How to contact us?” of this privacy policy to request deletion of your personal information:
· We have treated your personal information in an illegal way;
· We have collected or used your personal information without your consent;
· We have treated your personal information in violation of any agreement reached with you;
· You have decided to stop using our services or have cancelled your account;
· We have terminated services or operations.
If we grant your request for deletion of your personal information, we will, through reasonable effort, request any other entities that have received your personal information to delete such information promptly unless otherwise specified in laws or regulations or unless such entities have obtained authorization/consent from you separately. After we delete your personal information from relevant services, such information in our backup systems may be removed in the next backup updating operation instead of being removed immediately.
If we plan to terminate relevant services or operations, we will notify you at least thirty days in advance, and delete or anonymize your personal information after such termination.

4.Account cancellation
You may contact us with the information provided in Section XI “How to contact us?” of this privacy policy to request cancellation of your personal account.
Unless otherwise specified in laws or regulations, after cancellation of your account, we will not provide you with services any more,

and will keep your personal information for a period as agreed herein. Upon expiry of such period, we will anonymize your personal information.

5.Complaint consultation and customer response

In order to protect safety of your personal information and that of others, you may need to submit a written document or show your identity by other means when filing a request. We may first check your identity before handling your request.

We will reply to your request within 15 working days. If you are dissatisfied with our reply, you may lodge a complaint with the information provided in Section XI “How to contact us?” of this privacy policy.
If you are dissatisfied with our reply, especially when you believe that the way we treat your personal information has caused damage to your legal rights, you may also take further actions such as filing a complaint with competent national personal information regulation authority or initiating legal proceedings at a local court with jurisdiction where FAW-Volkswagen is located;

In principle, we will not charge you for reasonable requests, provided that certain cost may be charged for repeated requests beyond reasonable limit. We may refuse to grant any request that is repeated frequently without justified reasons, requires application of too many or too complicated technical means (such as development of a new system or a fundamental change to current conventions), puts legal rights of others at risk, or is essentially impractical (such as backup of tape-stored information).
In the following circumstances, we may be unable to grant your request due to provisions of laws or regulations, but will inform you of the reason for our refusal within 15 working days:
· Cases directly related to national defense or homeland security;
· Cases directly related to public security, public health, or major public interests;
· Cases directly related to criminal investigation, prosecution, trial, or judgment execution;
· There is sufficient evidence that the subject of the personal information abuses or misuses his/her rights deliberately;
· Granting your request will cause major damage to legal rights of other individuals or organizations;
· Cases involving commercial secrets.

VII.How do we handle personal information of minors?

FAW-Volkswagen attaches great importance to protection of information of minors.
Our products, websites, and services are primarily targeted at adults. Without the consent of parents or custodians, minors are not allowed to create their own personal accounts. If you a minor and your custodian disapproves any provision of this privacy policy, you should stop using this software immediately.
If we find any personal information of a minor is collected without first obtaining verifiable consent his/her custodian, we will delete relevant information as soon as possible.
If a custodian finds that we’ve collected personal information of a minor under his/her custody without first obtaining his/her consent, he/she may contact us with the information provided in Section XI “How to contact us?” of this privacy policy, and we will delete relevant information as soon as possible.

VIII.How do we migrate your personal information across borders?

In principle, all personal information and data collected and generated by us in the People’s Republic of China will be stored in the territory of China. If any cross-border migration of your personal information is required, we will first obtain your authorization/consent separately;

IX.Applicable laws and dispute settlement
1.Applicable laws

Implementation and interpretation of this policy and settlement of any dispute arising therefrom shall be governed by the laws of the People’s Republic of China, without regard to any conflict of laws.

2.Dispute settlement

Any dispute between you and FAW-Volkswagen concerning provisions of this policy or their implementation shall be first settled through friendly negotiation. If such negotiation fails, the parties agree to bring a lawsuit at a local court with jurisdiction where the defendant is located.

X.How do we update this policy?

This policy will be revised at times depending on adjustments or updates of business models. Such revisions shall form integral parts of this privacy policy and have retrospective effect.
Without your explicit consent, we will not withdraw or reduce any rights granted to you under this privacy policy. In the event of any change to this privacy policy, we will inform you through email, letter, telephone, pushed notice, or other means.

If any major change is made, we will inform all users in a more noticeable way, including but not limited to email, pushed notice, and pop-up notification.

For the purpose of this policy, major changes include but not limited to the following:
· A major change of our service model, such as purpose of treating personal information, type of personal information used, and the way of using personal information;
· A major change of our ownership structure or organizational structure, such as owner change due to business adjustment, bankruptcy, or M&A;
· A major change of your rights in treating your personal information and the way to exercise such rights;
· A change of our department in charge of security of personal information or its contact information or complaint channels;
· A personal information safety impact evaluation report suggests high risks.
We will place the old version of the policy on file for your reference.
This privacy policy shall remain valid as long as the website is operated or available for use, and will become invalid upon permanent termination of such operation or use. After this privacy policy becomes invalid, we will keep protecting your rights in personal information according to national laws and regulations.

XI.How to contact us?

If you have any doubt, opinion, or suggestion about this privacy policy, or any opinion or suggestion about collection, use, sharing, access, deletion, or correction of your personal information during use of FAW-Volkswagen products or services, you may contact use with the following information:

Customer service line: 4008-171-666
Audi online customer service (webpage version)
Email: service@audi.cn

Special note: FAW-Volkswagen reminds you that if your feedback involves your personal information, especially sensitive information, do not divulge such information directly in telephone calls or email. We will seek further communication with you while guaranteeing safety of your personal information.
In some cases, in order to protect safety of your personal information, you may need to submit a written document or show your identity by other means when filing a request. We will respond to your request within 15 working days after receiving your feedback and checking your identity.