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A: Privacy policy

With this privacy policy (last updated: 07/2025) we would like to inform you about the type, scope and purpose of the personal data we collect and process. Furthermore, data subjects are informed about the rights to which they are entitled.

This data protection declaration applies exclusively to services provided by Exclusive Cars Vertriebs GmbH, but not to data processing by third parties. For data processing by Exclusive Cars Vertriebs GmbH in connection with websites and applications, you will find corresponding information on the respective website or application.

Responsible for the data processing mentioned below is the

Exclusive Cars Vertriebs GmbH
Ketzergasse 120
1230 Vienna
+43 1 86688-0
wien@exclusivecars.eu

1. data security

Exclusive Cars Vertriebs GmbH has taken suitable technical and organisational measures to protect your data against loss, manipulation or unauthorised access. The measures taken are subject to regular review and are continuously adapted to the state of the art. Should there be a breach of the protection of your personal data that is likely to result in a high risk to your rights and freedoms, we will notify you immediately.

2nd partner

Exclusive Cars Vertriebs GmbH does not carry out all processing of personal data itself, but has the support of professional partners. A categorisation of our service providers/recipients of the data can be found in the respective data processing. The partners have been carefully selected and take suitable technical and organisational measures to ensure that your data is processed in accordance with data protection regulations and that your rights are protected. The partners are not permitted to use the personal data provided for their own or advertising purposes or to pass it on to unauthorised third parties.

3.1 Data processing (operation)

Customer enquiries and sending of important information by the company
Customers have the opportunity to make the following enquiries via various contact channels (e.g. contact form homepage, telephone, social media [Facebook, Instagram, LinkedIn, TikTok, WhatsApp], email...): Transmission of information material on models, accessories, enquiries about car purchase (new cars, used cars) and car financing, request service appointments, praise and criticism, as well as other individual enquiries. In addition, customers who have been with the company in the last three years will be informed by the company by post or e-mail in the event of important changes and information (e.g. new company name, new contact person, new contact information, etc.).

Data categoriesContact and identification data, vehicle data, text of the enquiry
PurposeCustomer service
JustificationLegitimate interest in being able to process and reliably answer the individual enquiry or legitimate interest in informing our customers about important changes in terms of customer service
Recipient of the dataIT service provider, vehicle manufacturer
Storage duration: 1 year

Data processing in the context of a new car sale
Depending on the service used, the data processing includes: enquiries and test drives, preparation of a personalised offer, order processing, delivery and payment of new cars, processing of transport damage

Data categories: Contact and identification data, vehicle data, contract data, creditworthiness and bank data
Purpose: Sale of vehicles incl. accessories and spare parts
Justification: Contract or pre-contractual relationship at the request of the customer
Recipient of the data: IT service providers, vehicle manufacturers including haulage companies
Storage duration: In accordance with statutory retention obligations: 7 years, offer: 1 year, test drive: 3 years

Data processing in the context of a used car sale or purchase
Depending on the service used, the data processing includes: enquiry and execution of test drives, preparation of a personalised offer, processing of the purchase by the dealer from the customer including preparation of a purchase test (evaluation) and further use of the §57a test certificate for resale, processing of the used car purchase by the customer from the dealer

Data categoriesContact and identification data, vehicle data including data of any valid §57a test certificate, contract data, creditworthiness and bank data
PurposeSale of vehicles incl. accessories and spare parts
JustificationContract or pre-contractual relationship at the request of the customer
Recipient of the dataIT service providers, financing service providers for lease returns and used car buyers (§57a test certificate of the previous owner)
Storage durationIn accordance with statutory retention obligations: 7 years, preparation of a purchase test: 3 years, test drive: 3 years

Data processing for the processing of workshop and service activities and the sale of other products and services
Depending on the service used, the data processing includes: processing of workshop orders and repair extensions including notification of completion, tyre storage, sale of spare parts, tools and (vehicle-specific) accessories, towing service and rental/leasing of replacement service vehicles, mobility guarantee

Data categoriesContact and identification data, vehicle data, contract data, creditworthiness and bank data
PurposeCustomer service and repair, sale of vehicles including accessories and spare parts as well as breakdown assistance
JustificationContract or pre-contractual relationship at the request of the customer, legitimate interest in the case of repair extensions to be able to send the customer a corresponding offer
Recipient of the dataIT service providers, communication service providers, towing service providers for car breakdowns, insurance and financing service providers for maintenance contracts
Storage durationIn accordance with the statutory retention obligations: 7 years

Data processing for the handling of warranty, guarantee and goodwill services
Depending on the service utilised, the data processing includes: damage calculation/obtaining expert opinions, damage documentation for warranty and insurance by means of photographs, warranty and warranty extension, warranty extension as well as complaints/enquiries from customers regarding warranty, guarantee and goodwill services

Data categoriesContact and identification data, vehicle data, contract data
PurposeWarranty and guarantee, insurance processing, administration and processing of customer enquiries regarding warranty, guarantee and goodwill services
JustificationContract, or pre-contractual relationship at the customer's request, legitimate interest for expert reports/damage calculation and the ability to defend against complaints (damage documentation) as well as legitimate interest in being able to process enquiries carefully and to coordinate with the parties involved (e.g. importer) in order to be able to fulfil the customer's request in the best possible way.
Recipient of the dataIT service provider, vehicle manufacturer (factory), financing service provider, insurance companies
Storage duration7 years in accordance with the statutory retention obligations; customer enquiries for which no services have been provided are deleted after 1 year

Internal data processing and the fulfilment of legal obligations
Depending on operational requirements, data processing includes: internal reporting and analyses, compliance checks, use of customer data in test systems for technical support and for new and further development of the systems, video surveillance at the entrance to the PIA Vienna-Liesing premises, audits and the archiving of contract documents and invoices to fulfil documentation and retention obligations in accordance with the relevant laws

Data categoriesContact and identification data, vehicle data, contract data, creditworthiness and bank data
PurposeInternal reporting, compliance, technical support as well as new and further development of systems, video surveillance, revision and audit, archiving of documents
JustificationLegitimate interest in evaluating and preparing key business figures to manage the business (internal reporting); legitimate interest in being able to rectify software errors and continuously improve systems (testing purposes), legitimate interest in averting danger and preserving evidence (video surveillance); legitimate interest in checking compliance with legal and internal company regulations in business transactions (internal audit) and fulfilment of legal obligations (archiving of documents)
Recipient of the dataIT service provider, security service provider (video surveillance), corporate audit and vehicle manufacturer (revision and audits)
Storage durationReporting: up to 7 years, video surveillance: 72 hours, audit: 4 years

Data processing in the context of marketing measures

Market research and quality assurance/improvement purposes (with the exception of the CarAdvisor customer satisfaction survey) and reminders of important workshop appointments are sent on the basis of your express consent. In the case of postal advertising mailings, we rely on our overriding legitimate interest.

Data categories: Contact and identification data, vehicle data

Purpose: Sending information about products, services and events

Justification: Consent, legitimate interest for postal mailings

Recipient of the data: IT service provider, marketing service provider
Storage duration: The data will be stored until the respective purpose is achieved or until consent is revoked (in the case of electronic advertising) or objection is made (in the case of postal advertising).

Reading OBFCM data (On-Board Fuel Consumption Monitoring data)
In order to fulfil legal obligations (Implementing Regulation (EU) No. 2021/392), vehicle data on fuel consumption and energy consumption in kilometres driven (so-called on-board fuel consumption monitoring data) is read out from vehicles during workshop visits and transmitted by the manufacturer together with the vehicle identification number to the European Commission and the European Environment Agency (EEA).
Data processing, transmission and storage are the responsibility of the manufacturer (not Exclusive Cars Vertriebs GmbH) within the scope of this legal obligation and can be refused by the customer before the readout process in the authorised workshop.
The data will be deleted by the manufacturer after 15 years at the latest. Further information on data processing can be found on the homepage of the respective vehicle manufacturer.

Data transfers to internal and external third parties:
Your personal data (contact data, vehicle data, contract data, bank data) may be transferred to the following recipients or categories of recipients (in addition to the recipients of the data mentioned for the respective data processing under point 3) for the purposes and legal bases listed below:

Porsche Holding GmbH (parent company)Reporting, Group Internal Audit and Compliance due to the legitimate interest in being able to review business processes and comply with legal requirements.
Austrian authorities and courtsData disclosure in the event of inspections or enquiries by the authorities (e.g. police) and proceedings based on the legal obligation or the legitimate interest in assisting in the investigation of criminal offences, defence and assertion of legal claims
Debt collection agencies and lawyersDunning procedure due to the legitimate interest in the settlement of outstanding accounts
Vehicle manufacturers/plantsGroup Audit, on the basis of legitimate interest and legal obligations (e.g. OBFCM). You can find more detailed information on further data processing by the vehicle manufacturer on the homepage of the respective vehicle manufacturer. vehicle manufacturer.

3.2 Data processing (website)

Customer enquiries
Request for a test drive and other individual enquiries from website visitors. Your personal data will be processed from the time you send the respective enquiry.

Data categoriesContact & identification data, selected brand, information about the account manager and the text of your enquiry
PurposeAnswering your enquiry
JustificationLegitimate interest in being able to process and reliably respond to your individual enquiries. The test drive is based on pre-contractual measures.
Recipient of the dataIT service provider
Storage duration: 12 months

Newsletter
If you have registered for one of our newsletters, we must process your personal data in order to send you the newsletter. To protect your e-mail address, you must confirm your e-mail address again in a confirmation e-mail when you subscribe to the newsletter (double opt-in). You can unsubscribe at any time using the unsubscribe option provided in the newsletter or at wien@exclusivecars.eu revoked.

Data categoriesContact & identification data
PurposeSending information about products, services and events
JustificationConsent
Recipient of the dataIT service provider, marketing service provider
Storage durationUntil further notice

4. rights of data subjects

If the processing is based on consent, you as the data subject have the right to withdraw this consent at any time.

In principle, you have the rights to information (Art 15 GDPR), rectification (Art 16 GDPR), erasure (Art 17 GDPR), restriction of processing (Art 18 GDPR) and objection (Art 21 GDPR) as well as the right to data portability (Art 20 GDPR).

You can exercise these rights via the e-mail address wien@exclusivecars.eu claim.

If you are of the opinion that we have violated Austrian or European data protection law when processing your data and thereby infringed your rights, we ask you to contact us so that we can clarify any questions you may have. Of course, you also have the right to lodge a complaint with the Austrian data protection authority or a European supervisory authority.

B: Cookie policy

Our whistleblower system

Compliance with legal regulations, internal rules, the principles of our Code of Conduct and the Code of Conduct for Business Partners is a top priority at Porsche Holding Salzburg. The success of our company is based on integrity and compliance. In order to live up to this claim, it is important to learn of possible misconduct by our own employees or those of our suppliers and to prevent it. We have therefore commissioned the Central Investigation Office to operate an independent, impartial and confidential whistleblower system for us.

An important pillar of our whistleblower system is the principle of fair proceedings. It guarantees the greatest possible protection for whistleblowers, those affected and employees who are involved in investigating the reported misconduct.

This also includes offering opportunities for anonymous reporting and communication. We ensure that we do not take any measures to identify anonymous whistleblowers who do not abuse our whistleblowing system. Discrimination against whistleblowers and all persons who contribute to investigations at Porsche Holding Salzburg will not be tolerated. Those affected are presumed innocent until the offence is proven. Investigations are conducted with the utmost confidentiality. The information is processed in a fair, fast and protected procedure.

How do we process your tip?

Qualified and experienced employees of the Central Investigation Office thoroughly check all reports of potential serious breaches of regulations by employees of the Volkswagen Group and systematically investigate them. Firstly, you will receive a confirmation of receipt. The Investigation Office will then assess your report. This includes obtaining information from the whistleblower in particular. Only if this leads to an initial suspicion of a potential serious breach of regulations will a suitable investigation unit be commissioned to investigate the case. Once the investigation has been completed, the Investigation Office evaluates the results and, if misconduct is found, makes an appropriate sanction recommendation. You will be informed immediately about the processing status* of your report and the outcome of any investigation.

Potential violations of the Code of Conduct for Business Partners, including serious risks and human rights and environmental violations by direct and indirect suppliers, can also be reported to the Central Enlightenment Office. This also applies to other reports that require immediate action by the company. The Investigation Office informs the responsible departments, which process the matter accordingly. This includes, in particular, measures required to minimise or end violations and/or risks.

Further information on the rules of procedure for the Volkswagen Group's complaints mechanism can be found at here.

* The processing time may vary and depends, among other things, on the subject of the notice.

Submit a report to our whistleblower system

The whistleblower system offers various channels for reporting potential misconduct by employees or violations of the Code of Conduct for business partners in our supply chain that require a rapid review and - if necessary - a response from our company.

However, this does not affect the statutory right to contact the competent authorities as described below.

24/7 voice message by phone

You can submit messages around the clock by voice message:
Free phone number for Austria: 0800 909 683
Porsche Holding Salzburg Company code: 122333

The list of telephone accesses for all countries can be found here

Online reporting channel

You have the option of contacting the information office via an internet-based communication platform in various languages. The system is confidential and protected. If your preferred language is not listed, you can also report in any other language. You can also contact the Enlightenment Office in any language by e-mail or post:

Online reporting channel: https//goto.speakup.report/phs
Porsche Holding Salzburg Company code: 122333

The description of the online reporting channel can be found here

Ombudsmen

Porsche Holding Salzburg has appointed external lawyers (ombudsmen) to advise on the whistleblower system or to ensure that reports from whistleblowers are forwarded to the Investigation Office - anonymously if desired.

If you would like to contact the ombudsmen, you will find all the necessary information under the following link:

https://ombudsleute-der-volkswagen-ag.de/

e-mail

You can reach the Porsche Holding Salzburg Clarification Office by e-mail at the following address:
io@volkswagen.de

Central Reconnaissance Office

Postal address:

Volkswagen AG, Central Investigation Office
P.O. Box 1717
Berliner Ring 2
38436 Wolfsburg, Germany

Personal:

Please arrange appointments in advance via io@volkswagen.de

SpeakUp APP

You can easily download the SpeakUP app using the QR code below and submit your comments directly via the app. Please use the Porsche Holding Salzburg company code: 122333.

Here is the QR code for the company code (when using the APP for the first time
required:

Do you have any further questions or need a local contact?

You can also address any questions or suggestions for improvement regarding the whistleblower system to the responsible Investigation Office.

In addition, you are welcome to contact the Compliance department by e-mail on all matters relating to the whistleblower system at hinweis@porsche.co.at turn.

Author: Julian Berger