Privacy policy for the use of EPS (Electronic Pricing System) and PHACT online (Price Harmonization and Calculation Tool online)


A.   Person responsible

With this data protection declaration we inform you about the collection, processing and use of your personal data by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, registered in the commercial register of the Braunschweig district court under the number HRB 100484 ("Volkswagen AG") when using the EPS and PHACT online systems.


B. Collection, processing and use of your personal data


I.                   Principles

EPS is the Volkswagen Group's standard application for pricing genuine parts and accessories. It represents both new pricing and quarterly price adjustments of the existing range. In addition, EPS communicates with various connected systems (SAP, ET2000, ...).

PHACT online represents the importer's level and can be used for new pricing as well as for quarterly price adjustments. PHACT online is based on EPS but offers a smaller range of functions.


II.                Processed personal data

In EPS and PHACT online, in addition to an internal User ID (IT usage data), professional contact and organizational data such as surname and first name, professional telephone number and professional e-mail address as well as the department code are stored.

The following legal basis is relevant for the processing of professional and IT usage data:

- Implementation of the employment relationship (§ 26 (1) BDSG) - applies to employees of Volkswagen AG

- an overriding legitimate interest of Volkswagen AG (Article 6(1)(f) DSGVO) - applies to users who are not employees of Volkswagen AG

The reasonable interest of Volkswagen AG is to quickly identify the contact person for corresponding changes to data (prices, master data, conditions, etc.) in order to be able to answer queries and thus ensure the satisfaction of dealers and customers.

The personal data can be viewed and, if necessary, also changed by the user concerned. Only professional contact data and IT usage data are processed by the affected user. When applying for a user, a multi-stage user authorisation procedure is always carried out, so that only those users who absolutely need access are authorised. In this way the circle of users is kept as small as possible.


III.             beginning and duration of storage

The data of users is managed and saved when a user is created by an administrator. If EPS/PHACT online access is no longer required for a user, access will be blocked at the latest one month after the confirmation that EPS/PHACT online is no longer required.

For further inquiries or proof it is necessary to save the assignment of the update user to all changes to data in the system. Each saved change in the system is clearly assigned to a user. This assignment is visible for EPS/PHACT online users with the appropriate authorisation.


IV.             Third country transmission

The following companies have EPS access: Volkswagen de Mexico

The following companies have PHACT online access: AMAG GmbH, Audi Volkswagen Korea Ltd, Audi Japan KK, Volkswagen Group Import (China) Co, Ltd, Volkswagen South Africa, Audi Singapore Pte Ltd, Volkswagen Group Japan KK

If the data processing takes place in a third country outside the EU/EEA, we are obliged as the responsible party to guarantee a certain level of protection. By concluding EU standard data protection clauses, we ensure that this level of protection is maintained. The EU standard contractual clauses used can be accessed via the URL


V.                Recipients of personal data


Service provider

The service provider LexCom Informationssysteme GmbH, as a contract processor, is suitable for and maintains the EPS and PHACT online systems for the purposes of technical support and further development.


System users

All users of the system have access to personal data as listed under II, in order to be able to carry out the desired professional exchange.


C.    Your rights

You can assert your following rights against Volkswagen AG at any time free of charge. For further information on how to exercise your rights, please refer to section D.

Right to information: You have the right to receive information from us about the processing of your personal data.

Right of rectification: You have the right to demand that we correct any incorrect or incomplete personal data concerning you.

Right of deletion: You have the right to request the deletion of your data if the conditions set out in Art. 17 DSGVO are met. You can then, for example, request the deletion of your data if they are no longer necessary for the purposes for which they were collected. You can also demand deletion if we process your data on the basis of your consent and you revoke this consent.

Right to limit processing: You have the right to demand that the processing of your data be limited if the conditions of Art. 18 DSGVO are met. This is the case, for example, if you dispute the accuracy of your data. You can then demand that the processing be restricted for the duration of the verification of the accuracy of the data. 

Right of objection: If the processing is based on an overriding interest or your data are used for the purpose of direct marketing, you have the right to object to the processing of your data. An objection is permissible if the processing is either in the public interest or in the exercise of official authority or on the basis of a legitimate interest of Volkswagen AG or a third party. In the event of an objection, we ask you to inform us of your reasons for objecting to the processing of your data. You also have the right to object to data processing for the purposes of direct advertising. This also applies to profiling insofar as it is related to direct advertising. 

Right to data transferability: Provided that the data processing is based on consent or on the fulfilment of a contract, and provided that it is also carried out using automated processing, you have the right to receive your data in a structured, common and machine-readable format and to transfer it to another data processor.

Right of revocation: If the data processing is based on consent, you have the right to revoke the data processing free of charge at any time with effect for the future.

Right of complaint: You also have the right to complain to a supervisory authority (e.g. the Lower Saxony State Commissioner for Data Protection) about our processing of your data.


D.   Your contact persons

Contact person for the exercise of your rights

You will find the contact persons for exercising your rights and further information on the following website


Data protection officer

Our data protection officer is available to you as a contact person for data protection-related matters:

Data protection officer of Volkswagen AG

Berliner Ring 2, 38440 Wolfsburg


Status: August 2020