PRIVACY POLICY FOR THE DIGITAL MANUAL

1. General information

With this data protection statement, we hereby inform you about the processing of your personal data in conjunction with the provision of the Digital Manual. The Digital Manual is used to call up the Owner's Manual in digital format in your vehicle or on the Internet, in accordance with the provisions of regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, "GDPR"); as well as the 3/2018, Data Protection Spanish Act (LOPDGG); and other local regulations that complement it.

The entity responsible for data processing linked to the Digital Manual is:

• Data controller identity: SEAT, S.A.U. (hereinafter, “SEAT / CUPRA“) with TAX ID A-28049161

• Address: Autovía A-2, Km. 585, Martorell (Barcelona, Spain)

• Contact email address:

  • SEAT: customercare@seat.es

  • CUPRA: customercare@cupraofficial.com

2. What personal data do we process, how do we use it and what is the lawful basis?

SEAT/CUPRA will process your personal data for the purpose of determining the correct vehicle owner's manual for you. The owner's manual assigned to your vehicle is determined according to the VIN number, and it is then displayed and updated according to the model, model year, market and language. The owner's manual must be downloaded to the vehicle and will then be available at any time in the infotainment system, even when the vehicle is not connected to the data server. The legal basis for data processing is the safeguarding of legitimate interests (article 6, paragraph 1, letter f of the General Data Protection Regulation, hereinafter “GDPR”) based on the interest to provide accurate and up-to-date information about the vehicle’s operation and maintenance.

3. Data recipients

The disclosure of your personal and vehicle data to third parties will only take place in compliance with the corresponding legal obligations. Likewise, SEAT/CUPRA will provide third parties acting as data processors with access to data for the purpose of offering certain features of the app. These third parties will always process the personal data on our behalf.

Both the data servers and the development and management of the Digital Manual App function are processed by CARIAD SE, a Volkswagen Group Company that will be considered our data processor, and which, additionally, has contracted Microsoft Ireland Operations Limited for cloud storage data and New Relic Inc. based in the US for data analytics. Microsoft and New Relic process the data as sub-processors in accordance with the Volkswagen Group’s instructions.

Microsoft encrypts data according to agreements held with the Volkswagen Group and exclusively processes data on servers located in the European Union. At the same time, New Relic also stores data on servers located in the European Union. Given the fact that some of these service providers may be located in the United States, access to data from the United States cannot be ruled out. A corresponding EU standard data protection agreement (an appropriate guarantee for data processing in non-European countries) was concluded accordingly to ensure sufficient protection of your personal data, which can be consulted here.

4. How long do we use your personal data for?

SEAT/CUPRA will store your personal data for as long as necessary in order to provide you with the aforementioned function and, in any event, until you ask for it to be erased or you object. In any case, we will retain your data to comply with any legal requirements corresponding to each category of data. The VIN is not permanently stored on our data server and is automatically deleted.

5. What are your rights and contact channels?

As the data subject, you can exercise the following rights:

• Access: you can obtain information if SEAT/CUPRA processes your personal data, as well as consult your personal data included in the SEAT/CUPRA files.

• Rectification: you can modify your personal data when it is inaccurate, as well as complete data that is incomplete.

• Erasure: if the requirements specified in article 17 of the GDPR have been met, you have the right to demand the erasure of your personal data. For instance, you may request the deletion of your data if it is no longer necessary for the purposes for which it was collected.

• Objection: insofar as the processing is predicated by an overriding legitimate interest on the part of CUPRA (article 6, paragraph 1, letter f of the GDPR), you have the right to object to the processing of your personal data. This means that you may request that your personal information not be processed. SEAT/CUPRA will stop processing the data, except for compelling legitimate reasons, or for the exercise or defence of possible claims.

• Restriction of the processing: if the requirements of article 18 of the GDPR are met, you can request the restriction of the processing of your personal data in the following cases:

  • While the objection of the accuracy of your personal data is being checked;

  • When the data processing is illegal, you object to the deletion of your data and request the limitation of its use;

  • When SEAT/CUPRA does not need to process your data, but you need it for the exercise or defence of claims;

  • When you have opposed the processing of your personal data for the fulfilment of a mission of public interest or for the satisfaction of a legitimate interest, while it is verified if the legitimate reasons for the processing prevail over yours.

• Portability: you can receive, in electronic format, the personal data that you have provided to us and the data that has been obtained from your contractual relationship with CUPRA, as well as transfer them to another entity.

• Right of revocation: insofar as the data processing is undertaken based upon consent, you have the right to revoke your consent for the data processing, with future effect, at any time, free of charge.

Please note that due to the fact that we only process the VIN in order to offer this function, these rights are only available to a limited extent according to article 11 of the GDPR. This means that we are only obliged to fulfil your rights listed below if, when exerting your rights, you provide us with additional information that puts us in a position to be able to fulfil your right. As the data subject, you can exercise the following rights before CUPRA:

You can exercise these rights by (i) sending a written request to SEAT/CUPRA Customer Service department, Autovía A-2, Km. 585 (08760) Martorell, Barcelona (Spain), or (ii) sending an email message to the email address customercare@seat.es or customercare@cupraofficial.com. The exercise of these rights at any time is free of charge, except in cases of manifestly unfounded or excessive requests.

If you consider that SEAT/CUPRA has not processed your personal data in accordance with the applicable regulations, you also have the right to lodge a complaint with a supervisory personal data authority (e.g. with the Spanish Data Protection Authority through www.aepd.es) regarding our processing of your data.

If you have any doubts about data protection, or wish to get in touch with the data protection officer (“DPO”), you can also contact our company data protection delegate by sending an email to dataprotection@seat.es.

Version: April 2023