1. Privacy Notice

Effective Date: January 1, 2023

Thank you for choosing VWFS Protection Services, Inc. (“we”, “our”, or “us”). We are committed to protecting your personal information and your right to privacy. This Privacy Notice is designed to inform you about how We collect, use, and share the personal information with which you have entrusted us.

Please note that our services are intended exclusively for residents of the United States of America. Additionally, our services are not intended for children under 18, and we do not knowingly collect personal information from individuals under 18.

If you have interacted with us, or inquired about, requested, or obtained a protection product or service with us, we will use and share any information that we collect from or about you in accordance with applicable law, as described here and in our Privacy Notice below. If you have interacted with us, or inquired about, requested, or obtained a protection product or service with us, we will use and share any information that we collect from or about you in accordance with applicable law, as described here and in our Privacy Notice below.

2. How We Collect Information/Sources of Information

We collect personal information when you purchase or use our products and services, use or visit our websites, or otherwise interact with us. These sources could include:

• You or Your Vehicle: When you inquire about, purchase or use our products and services
• Cookies and online technologies: When you use our website
• Dealerships: When you inquire about, purchase or use our products
• Service Providers: Companies acting on our behalf, who act under contract to help us provide the business services you have requested and help us run our business
• Affiliates: Other Volkswagen group companies with which you may have a relationship
• Third Parties: Entities that may provide independent products or services to you

3. Information We Collect

The types of personal information we collect, use, and share depend on the product or service you have with us. When you inquire about, purchase or use our products and services, we may collect the following personal information from or about you:

• Basic Identifiers: Personal identifiers or contact information, such as your name, email address, postal address, or other similar identifiers
• Sensitive personal information (SPI): Information such as your social security number, driver's license number, passport number, or other similar sensitive information
• Commercial Information: Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet Activity: Other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet Website, application, or advertisement
• Geolocation Data: Estimation of the real-world geographic location of an object
• Sensory Data: Audio, electronic, visual, thermal, or similar information
• Inferences: Inferences drawn from any of the above information

Personal information does not include publicly available information, or information that has been de-identified so that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer.

4. How We Use Your Information

We may use your information for several business purposes, including:

• Auditing: Monitoring and verifying the performance of transactions and consumer interactions to ensure success and compliance with legal, regulatory, contractual, or other standards/requirements
• Debugging: Identifying and repairing errors that impair existing intended functionality
• Short-Term, Transient Use: Executing one-time transactions, or acting as an intermediary to facilitate transactions
• Performing Services on Behalf of Our Business: Including to provide you with products and services you request; support your vehicle, products and services; diagnose, repair and track service and quality issues; communicate with you about your vehicle, products or services; install and configure changes and updates to your services; authenticate users of our products and services; or verify your eligibility for certain programs or benefits and marketing
• Internal Research: For technological development and demonstration
• Quality Assurance: For our own internal business purposes, such as to evaluate the usage of our products and services; improve, upgrade or enhance the quality of our products and services and develop new products and services; operate our websites and digital properties, as well as customize the content; and maintain internal records
• Marketing: To market our products and services or those of our affiliates and business partners.
• For Legal or Security Reasons: Such as to comply with legal requirements; protect our rights; protect the safety or rights of the Volkswagen Group of Companies and our customers or others; detect, prevent, and mitigate security incidents, malicious, deceptive, fraudulent, or illegal activity; detect, prevent, and mitigate misuse of products or services; and to prosecute those responsible for that activity

We may also use or disclose your information in a de-identified or aggregate manner.

5. To Whom We Disclose Your Information

We may disclose your information for any of the purposes described above with the following parties:

• Banking: Those who assist us in processing your transactions.
• Insurance Services: Those who assist us in processing any claims you may have on your accounts.
• Collection Services: Those who assist us in processing your transactions and enforcing our contracts with you.
• Authorized Dealerships: Independent companies that sell our products or related offerings, and are licensed to operate such businesses using the trade names, trademarks, and service marks owned by us or our affiliates.
• Volkswagen Group of Companies: The group of companies related to us by common control or ownership.
• IT Service Providers: Provide information technology systems/solutions/services and to help protect the safety and security of your personal information
• Sales and Marketing Service Providers: Deliver advertising or marketing communications on our behalf and help us manage the effectiveness of our operations and advertising campaigns
• Customer Support Service Providers: Assist us in providing a service or support need for customer interactions
• Government Agencies: Those governmental entities who provide services to us, including postal services for mailing invoices or correspondence, tax services, or others.
• Legal & Compliance Service Providers: Those who assist us in maintaining regulatory compliance.
• Vehicle Information Service Providers: Those who assist us in acquiring information about your vehicle that is required for us to service your account, including vehicle history reporting services or others.
• Financial Services Providers: Those who assist us with accounting and financial operations services.
• Workforce Management Service Providers: Those who assist us in processing and managing employee information
• Vehicle Protection Service Providers: Those who assist us in administering vehicle protection programs
• Risk Management Service Providers: Those who assist us in assessing and managing corporate risk

We do not disclose your information to third parties for those third parties own marketing purposes.

6. Security and Retention

We use reasonable technical, physical, and administrative security measures designed to minimize risks associated with data loss, misuse, unauthorized access, unauthorized disclosure, and alteration. To this end, we use firewalls, data encryption, access controls, and secured files and buildings to protect your personal information. However, it is important to recognize no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure.

While we are committed to securing our systems, you are responsible for securing and maintaining the privacy of your passwords and the account information you share with us.

Your information will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as to demonstrate our business practices and contractual obligations or provide you with information about our products and services in case of interest

7.External Links

Our websites may contain links to other websites, including social networks, advertisers, VW Dealer websites, VW brand websites, other Volkswagen Group websites, including websites operated by VW AG, and websites belonging to other third parties. Some of these sites may share a similar “look and feel” to our website. Please be aware that we are not responsible for the privacy practices of other websites. We encourage you to read the privacy notices provided by other websites before you provide information to them.

8. Updating Your Personal Information

Keeping your account information up-to-date is very important, and we rely on you to verify that the personal information we maintain about you is accurate and current. You can review, update, or delete certain account information by using the Contact Us option provided below.

9. Our Use Of Cookies And Similar Technologies

We may use cookies and similar technologies such as web beacons (also known as web tags, pixel tags, or clear GIFs) as necessary to provide our services, to secure our services, to optimize our services, and to improve your user experience. You may refuse to accept these technologies by activating the appropriate setting on your browser or mobile device. However, if you do so, you may be unable to access certain parts of our websites.

The information collected automatically helps us to improve our websites and to deliver a better and more personalized service, including by enabling us to:

• Verify your identity;
• Keep you logged in during your visit;
• Identify irregular site behavior;
• Prevent fraud and improve security;
• Recognize you when you return to our websites;
• Store your preferences and customize your online experience;
• Understand how you use our websites;
• Market our products and services, and jointly market the products and services of our and other businesses;
• Measure the effectiveness of our newsletters and advertising campaigns; and
• Estimate overall usage volumes and patterns.

Do Not Track

Some web browsers provide options to inform websites or internet services that you do not wish to have your activities tracked by cookies or similar technologies (commonly called "Do Not Track" or “DNT” signals). As there is not yet an industry or legal standard for recognizing or honoring DNT signals, we currently do not respond to such signals. We await the results of work by governments and industry to determine the appropriate form and manner of any DNT response is appropriate and what form it should take.

In the interim, you can refer to your browser’s help instructions to learn more about cookies and other technologies, and limit their use on your browser.

10. Children’s Privacy

Our products and services are not intended for minors. We do not knowingly collect personal information from individuals under the age of 18. We request that such individuals do not provide personal information to us.

For more information about the Children’s Privacy, visit the FTC website: www.ftc.gov

11. Contact Us

Should you have other questions or concerns about this Privacy Notice, you can contact us at:

• Volkswagen Drive Easy Customers (844) 368-6414
• Audi Pure Protection Customers (844) 368-6416
• Ducati EverRed Customers (844) 368-6418
• Quality Protect Plan Customers (844) 368-6420

Your State Privacy Rights

Depending on where you live, you may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information.

Right to Delete

You may have the right to request that we delete personal information about you that we have collected from you. This right is subject to exceptions that allow us to retain data; for example, to service a contract or for our internal business purposes. We will not delete data subject to an exception. We will also maintain a record of the Request to Delete as permitted by law.

You can submit a Request to Delete by visiting (privacy.vwgoa.com) and following the instructions in the web form or by calling (833) 950-1851.

For a Request to Delete, in order to verify your identity, match you to our records, and to reduce fraud, will ask you for your personal information or information about you. You will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable for us to process your request. We may also use third party verification companies to help us verify your identity. If we are unable to find you in our records, or match the data you provide with what we have in our records, we will notify you.

Right to Know

You may have the right to request that we disclose personal information that we have about you. You can request either or both of the following types of reports:

• Categories Report that provides you with the categories of personal information we have about you, and for each category: the categories of sources from which the personal information was collected; the business or commercial purpose for which we collected the personal information; and for each category of personal information, and the categories of Service Providers to which we disclosed the category of personal information for a business or commercial purpose.
• Specific Pieces Report that provides you with the specific pieces of personal information that we have about you.

For a Request to Know seeking a Specific Pieces Report, in order to verify your identity, match you to our records, and to reduce fraud, we will ask you for your personal information or information about you. You will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also ask you to provide a signed declaration, under penalty of perjury, that you are the person whose personal information is the subject of the request. We may also use third-party verification companies to help us verify your identity. If we are unable to verify your request for a Specific Pieces Report, we will treat it as a request for a Categories Report.

For a Request to Know seeking a Categories Report, you will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also use third party verification companies to help us verify your identity. If we are unable to verify your request for a Categories Report, we will direct you to the data handling practices in our online privacy notices.

You can submit a Request to Know by visiting (privacy.vwgoa.com) and following the instructions in the web form or by calling (833) 950-1851. You may be able to submit a Request to Know twice in a 12 month period and the report will be provided free of charge.

Right to Correct

You may have the right to request that we correct inaccurate personal information that we maintain about you.

For a Request to Correct, in order to verify your identity, match you to our records, and to reduce fraud, will ask you for your personal information or information about you. You will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable for us to process your request. We may also use third party verification companies to help us verify your identity. If we are unable to find you in our records, or match the data you provide with what we have in our records, we will notify you.

You can submit a Request to Correct by visiting (privacy.vwgoa.com) and following the instructions or by calling (833) 950-1851.

Use of Authorized Agent

If you are making any of the requests above as an authorized agent, we may require written authorization from the consumer. Additionally, we will seek to verify the consumer’s identity in the manners stated above (depending on the request type). To make a request as an authorized agent please call (833) 950-1851.

Additional Information

We will maintain records of requests that are made that include the date of request, nature of request, manner in which the request was made, the date of our response, the nature of our response, and the basis for any denial of the request if it is denied in whole or part.

You are not required to create an online account with us in order to exercise your rights. However, for your convenience, we may offer you the option to create an account, so you may more easily exercise your rights in the future.

Non-discrimination

In accordance with applicable law, we will not discriminate against you for exercising your privacy rights.

Disclosure of Personal Information

We disclosed all of the categories of personal information listed in the chart below for a business purpose in the past 12 months. We disclosed these categories of personal information for the purposes described in Section 4 above.

Below please find a chart detailing the categories of information we collect and with whom it was disclosed for a business purpose. We do not “sell” or “share” personal information as defined under applicable law.

Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes outside of providing the requested products and services; detecting security incidents; resisting malicious, deceptive, fraudulent, or illegal actions; ensuring the physical safety of natural persons; short-term transient use; our service providers’ performance services on our behalf; verifying and maintaining the quality or safety of our products and services; or for making inferences about you.