Porsche Smart Mobility GmbH
Porsche Digital Service Infrastructure / Porsche ID
1. Controller and data protection officer; contact
Porsche Smart Mobility GmbH
Should you have questions or suggestions regarding data protection or privacy, please feel free to contact us.
You can reach our data protection officer as follows:
Porsche Smart Mobility GmbH
Data Protection Officer
2. Subject-matter of data protection
3. Nature, scope, purposes and legal bases of data processing in the case of the Porsche Digital Service Infrastructure
4. Porsche ID user account
4.1 The registration process and creating your Porsche ID user account
4.1.1 Invitation by an authorised dealer
Self-registration requires that you upload pictures from your device. This means you will be asked for authorisation to access your device’s camera or photo library. Granting authorisation is voluntary. However, if you wish to use the self-registration feature, granting the relevant authorisation is required, as you will be unable to use self-registration otherwise. The authorisation remains active until you reset it in your device and/or internet browser by deactivating the relevant setting.
When registering and creating your Porsche ID user account you are required (in the case of self-registration) to enter your email address, a password, your name and any suffixes, contact and address information, mobile phone number, email address and, where applicable, the language in which you wish to communicate with us, or (in the case of registration and creation of your Porsche ID user account via an authorised dealer) to confirm this personal data during the process of registering and creating your Porsche ID user account. This personal data is required in order to set up and manage your Porsche ID user account for you so that you can use the full range of our Services offered within the scope of the Porsche Digital Service Infrastructure. In selected countries, you can also use our offerings as a prospective customer. In this case all you are required to provide is your name and email address and a password. We also need this and, where applicable, further personal data not least in order to be able to respond to requests, questions and criticism. In addition we store the time of your most recent log-in. During registration and creation of your Porsche ID user account we perform a plausibility check of your name and address information.
When registering and creating your Porsche ID user account you also have the option to voluntarily enter further information, such as additional name information (academic titles, etc.), company contact information, date of birth, other phone numbers, credit card information (which is stored exclusively with the payment service provider) and your vehicle registration number and a personal vehicle name. In addition you can provide information on your interests and preferences and your desired contact channels. Please note that this information is not required in order to register and create your Porsche ID user account, and it is entirely up to you whether you wish to communicate this personal data to us.
4.2 Porsche Digital Service Infrastructure: Data processing after registration and creation of your Porsche ID user account
If you have selected an authorised dealer and granted your consent, the personal data stored in your Porsche ID user account, particularly contact information, customer service, contract and Service information and information on your interests, vehicles and Services used, will also be shared with the authorised dealer and synchronised with any personal data concerning you that may be stored by the authorised dealer. If you no longer wish this sharing of data to take place in the future, you can adjust the user settings for your Porsche ID user account accordingly. The aforementioned personal data will no longer be shared with the authorised dealer from then on. The legal basis for the processing of your personal data in this context is your consent pursuant to Article 6(1)(a) GDPR.
4.3 Deleting your Porsche ID user account
5. Central Services
5.1 Booking and activation of Services; handling of payment information
We use a payment service provider commissioned by us to process payments for paid services and products within the framework of My Porsche, Porsche Connect, Online Marketplace and Porsche Drive. For this purpose, we process your credit card details and the respective payment information. Management of your credit card information as well as the processing of payments is carried out via systems of the payment service provider on behalf of Porsche Smart Mobility GmbH. If you enter your credit card information, this is done directly via an input field of the payment service provider, which encrypts, stores and uses this information independently for your payments. The encrypted information is then transferred from Porsche/from us to the payment service provider where it is stored and used for your payment. The legal basis for processing is fulfilment of the contract.
Exclusively for the purpose of accounts receivable management (including compliance checks, to the extent required by law) and to perform credit checks, the payment service provider used processes your customer and contact information (name, address, email address, Porsche Connect customer number; if applicable, company name and affiliated companies) and the vehicle identification number shown in the proof of ownership on our behalf. The legal basis for the processing of the personal data mentioned for the purposes stated above is, pursuant to Article 6(1)(c) GDPR, compliance with a legal obligation to which we are subject or, pursuant to Article 6(1)(f) GDPR, our legitimate interest in complying with legal requirements.
When purchasing through online shops, our payment service provider determines the fraud risk. The transaction data is checked and examined for abnormalities (e.g. frequency of password changes). The legal basis for the processing of the mentioned personal data for the aforementioned purposes is, in accordance with GDPR Article 6  (b), the fulfilment of a contract, or, pursuant to GDPR Article 6  (f), our legitimate interest in preventing fraud.
After the booking is complete, you can activate the Services. This will store your use authorisation in the system and cause the list of available Services to be updated accordingly.
To use certain Services (such as charging station offers), a personalised card containing RFID chips (Porsche ID Card, Porsche Charging Card) is sent out by mail in numerous countries where the Services are offered when a product is purchased. An identification number is stored on this card; this number can be used to associate the card with your Porsche ID user account. No personal data other than the identification number, particularly not your name or address, is stored digitally on the card itself. If the card is lost, you can block it within your Porsche ID user account.
Once delivered, the Porsche ID Card can be used directly in dealings with supported infrastructure (such as public charging stations).
Unless otherwise indicated, we carry out the processing operations described in this section in order to perform our contract with you on the basis of Article 6(1)(b) GDPR.
5.2 Use of the My Porsche Services and Porsche Connect Services
When you use the Services booked via My Porsche or the Porsche Connect Store in your vehicle or on other devices, we process personal data concerning you for the purposes of enabling the use of the Services, for support purposes and for further, specifically defined purposes. Unless otherwise indicated, we process your personal data only within the scope necessary to enable the use of the relevant My Porsche Service or Porsche Connect Service.
When you use the individual My Porsche Services or Porsche Connect Services the following categories of personal data may be processed, for example, depending on how the specific Service works:
a) identification information, such as the vehicle identification number, your Porsche ID and the device and system IDs for your devices and mobile radio modules, which is needed to identify you personally, your device or your vehicle in order to establish connections, use Services or access content;
b) authorisation information, including that the vehicle or the relevant device has been activated for the relevant Porsche Connect Service, which can be linked to your personal data that you entered during the process of registering and creating your Porsche ID user account;
c) login information that is needed if you wish to use services from other providers that require a login in your vehicle or on other devices;
d) communication information that is required in order to establish a connection between your vehicle and/or other devices and our servers or the servers of third-party providers of content for Porsche Connect Services;
e) location and movement information, such as GPS or speed data, that is needed in order to use location-based content;
f) language information that enables voice control and voice entries in certain Porsche Connect Services. Voice data is transferred to us from the vehicle or a device as recordings for the purpose of conversion to text. The text that is then generated by a service provider is transferred back to the vehicle and the recording is then deleted at our end;
g) contact information that is used in communication services, for example to send email or text messages;
h) billing data, such as individual connection records regarding charging processes. We may combine this information with your address and payment information for individual billing purposes;
i) image/video data of your vehicle or its components
j) further content that must be shared with us or with service providers in order to be able to provide a Service for you.
For detailed information on which personal data is processed within the scope of which Service, please see the relevant Service descriptions at .
The following applies especially in the context of workshop visits and the associated use of online order extension:
Online order extension is a service that offers our customers the possibility to follow the vehicle acceptance process during a workshop appointment at any time and from anywhere through recorded and personalised videos of the service consultant and/or technician. In addition, the customer can release/approve additional repairs/repair extensions directly via the My Porsche Portal and/or the My Porsche App.
Unless otherwise mentioned here, in one of the Specific Privacy Policies or, where applicable, in the further specific privacy notices pertaining to the relevant Service, we process your personal data in each case on the basis of Article 6(1)(b) GDPR in order to provide you with the Services in this context and perform the contract associated therewith.
5.3 Use of services of a third-party provider
We have no influence over the processing of data by this third-party provider or the location of the data processing. Therefore please see the relevant third-party provider’s separate privacy notices for information on the nature, scope and purpose of the processing of personal data with regard to the relevant service.
We transfer the necessary personal data to the relevant third-party provider on the basis of Article 6(1)(b) GDPR to perform the contract existing between you and us.
6. Safeguarding legitimate interests
The relevant data processing takes place on the basis of Article 6(1)(f) GDPR in this regard.
On the basis of any consent that may have been granted by you, the companies listed in the declaration of consent may use the data for specific purposes, e.g. to provide individual care for customers and prospective customers, and may contact you via your desired communication channels.
If we use your data to provide individual care for customers and prospective customers within this scope, this takes place in order to provide you with an exciting brand and customer care experience with Porsche and to make our communications and interactions with you as personal and relevant as possible. Which of your data is specifically used to provide individual care for customers and prospective customers depends in particular on which data has been collected on the basis of inquiries, orders and advising (e.g. when purchasing Porsche products) and which data (e.g. your personal interests) you have provided at the relevant contact points (e.g. via this website or at the Porsche Zentrum).
In these cases, the specific scope and intended purpose of the consent granted by you arise from the wording of the declaration of consent at the point of contact.
8. Recipients of personal data
External recipients: We do not disclose your personal data to external recipients outside PSM GmbH except where necessary in order to provide and carry out the relevant Service, where there is another legal authorisation or where we have your consent to do so.
External recipients may be the following:
Dr. Ing. h.c. F. Porsche AG or its affiliates or external service providers with which we contract for the provision of services, for example in the areas of technical infrastructure and service/maintenance for the offerings of PSM GmbH or the provision of content. We select these processors carefully and subject them to regular reviews to ensure that your privacy is safeguarded. The service providers are not permitted to use the personal data other than for the purposes specified by us and according to our instructions.
b) Public bodies:
Government agencies and state institutions, such as tax authorities, public prosecutors’ offices or courts, to which we transfer (and/or are required to transfer) personal data for mandatory legal reasons or to safeguard legitimate interests. In these cases the transfer takes place on the basis of point(s) (c) and/or (f) of Article 6(1) GDPR.
c) Private bodies
Porsche dealers and service businesses, cooperation partners, service providers or persons to which or whom personal data is transferred on the basis of consent, to perform a contract with you or to safeguard legitimate interests, such as Porsche centres and Porsche service centres, financing banks, providers of further services or transportation service providers. In these cases the transfer takes place on the basis of point(s) (a), (b) and/or (f) of Article 6(1) GDPR.
9. Data processing in third countries
Insofar as data is transferred on the basis of GDPR Article 46, 47 or 49, Paragraph 1, Subparagraph 2, you can obtain from us a copy of the guarantees for the existence of an adequate level of data protection with regard to the data transfer. For this purpose, please use the information under point 1.
10. Collection of data by third parties
For details regarding collection of data by third parties, please see the Specific Privacy Policies and, where applicable, the further specific privacy notices pertaining to the relevant Service.
11. Automated decision-making and profiling
12. Duration of storage; erasure
We store your personal data only as long as is necessary to fulfil the intended purposes or – in the case of consent – unless and until you withdraw consent. In the event of an objection to processing, we erase your personal data unless the continued processing thereof is permitted pursuant to the relevant statutory provisions. We also erase your personal data if we are obligated to do so for other statutory reasons.
Applying these general principles, we generally erase your personal data without delay
13. Rights of data subjects
Right of rectification and erasure: You can request that we rectify incorrect data and – provided that the statutory prerequisites are met – erase your data.
Restriction of processing: You can request – provided that the statutory prerequisites are met – that we restrict the processing of your data.
Data portability: Should you have provided data to us on the basis of a contract or consent, you can, if the statutory prerequisites are met, request that you receive the data provided by you in a structured, commonly used and machine-readable format or that we transfer it to another controller.
Contacting us: You can also contact us free of charge with any questions regarding the processing of your personal data, your data subject rights and any consent you may have given us. To exercise all your aforementioned rights, please contact us by e-mail at email@example.com, via the website or by post at the address indicated in Point 1 above. When doing so, please make sure that we can clearly identify you.
14. Data security
15. Third-party offerings
Last updated: 01.08.2020
Porsche Smart Mobility Websites
You can book My Porsche services, Porsche Connect services and Functions on Demand (FoD) and activate the corresponding licences in My Porsche and the Porsche Connect Store. You can rent vehicles under Porsche Drive. This requires you to be registered with My Porsche and have a Porsche ID user account. Depending on the service, you can use and manage the aforementioned services via our website, via various Porsche apps and, if available for your vehicle, in your vehicle via wireless network connection.
In addition, you can use the Online Marketplace to access the extended range of products and services offered by our Group companies and third-party providers. Customers with a Porsche ID user account can use the Marketplace sections Porsche Finder and Porsche Store.
Some features on our websites are also available without registration. For further details see Point 2.3.
1. Special notes on the use of our website
1.1 Provision of our website
Below you will find an overview of the type, scope, purposes of and legal grounds for automated data processing that takes place when using our website. For information on the processing of personal data when using the individual specific features and services, please refer to Point 2 below.
1.1.1 Automated data collection
We process this data on the basis of GDPR Article 6  (f) for the purpose of providing the website, safeguarding its technical operation and identifying and clearing up malfunctions. In doing so, we pursue the interest of making it possible for our website to be used and ensuring its long-term technical functionality. When you access our website, this data will be processed automatically. You will not be able to use our website without providing this data. We do not use this data for the purpose of drawing conclusions about you or your identity.
1.1.2 Data processing to improve our online offer
We shall process your data in accordance with GDPR Article 6  (f) based on our legitimate interest in the performance and availability of our products, as well as in the analysis of the usage patterns of our website visitors. We do not use this data for the purpose of drawing conclusions about you or your identity.
In addition, we store cookies as part of the processing described here. For further details, please refer to Point 1.1.3.
1.1.3 Cookies, tracking technologies and related services
Details regarding the function and the cookies and comparable technologies used as well as setting and revocation options, can be found under
1.2 Device access permissions
Granting permissions is voluntary. However, if you wish to use the relevant features, you must grant the corresponding permissions, otherwise you will not be able to use these features.
Permissions remain active unless you revoke them in your device and/or Internet browser by deactivating the relevant setting.
2. Special services and features
It is necessary to register in advance and to create a Porsche ID user account in order to use the services and features described in Point 2.2. The services and features described in Point 2.3 can be used without prior registration.
2.1 Registration process and creation of a Porsche ID user account
2.2 Using the individual features with registration/login
2.2.1 Booking and activating services, handling payment information, identity verification
The laws in some countries may require an identity check based on identification documents in order to book certain telecommunications services. In relation to data processing when carrying out such identity checks, we are jointly responsible with
There are two methods available for performing identity verification. One method is that you can be redirected to the external page or app of the service provider, IDnow, as part of the service booking procedure. As part of the process, we will, at your request, transmit the information to be verified (your name, your address and your date of birth) as well as a reference number to the service provider that will allow us to assign the test result at a later point. As part of the identity check, the service provider will compare the aforementioned data with your identification document and store the data, as well as an optoelectronic copy of the identification document, a photo of the verified person and an audio record of the session. The service provider will then inform us of the result of the identity check, using the reference number.
Your other option is to have identity verification performed at a participating Porsche Centre. This involves staff at the Porsche Centre verifying your identity on the basis of an identification document and sending the verified information (your name, address and date of birth) and a reference number to the service provider via a Porsche system. By entering this reference number, you can use the service provider's app to submit an optoelectronic copy of your identification document to the service provider at your convenience. The service provider will then inform us of the result of the identity check, using the reference number.
Personal data resulting from this identity check will only be shared with third parties if we are legally obliged to do so. Only in such cases will we obtain access to a copy of your identification document from the service provider, for the purpose of fulfilling our legal obligations.
The legal basis for our processing of your personal data in order to carry out an identity check is GDPR Article 6  (c) and/or (f), as the identity check is the fulfilment of a legal obligation by which we are bound, or reflects to our legitimate interest in complying with legal requirements.
You are welcome to contact either of the jointly responsible parties with questions or to exercise your rights as a data subject. In the spirit of the aforementioned agreement, we will consult with IDnow GmbH in accordance with GDPR Article 26 in order to answer your inquiry and, if necessary, to fulfil your wish to exercise your rights as a data subject.
The exchange of personal data between the jointly responsible parties takes place on the basis of GDPR Article 6 (1) (f), in other words our legitimate interest in the effective implementation of identity checks in cooperation with IDnow GmbH.
If necessary, we supply further information about the processing of personal data for our bookable services in the additional special data protection provisions for the relevant services.
2.2.2 Using the My Porsche services and Porsche Connect services
2.2.3 Provision of service and warranty information
In order to provide you with information about your vehicle, current warranties and recall campaigns in the "My Porsche" section of our website, we process equipment and vehicle master data such as the vehicle identification number shown on the proof of ownership, current warranties, the model year and a model picture.
Pursuant to GDPR Article 6  (b), the legal basis for the processing of your personal data is the fulfilment of the contract between you and us.
2.2.4 Service appointment request
To request service appointments with Porsche dealers and service companies in the "My Porsche" section of our website, we may provide customer and vehicle data to companies of your choice at your request. If you provide us with your consent to do so as part of a service request, we will provide your name, address, telephone number, e-mail address, Porsche ID, vehicle identification number shown in the proof of ownership, vehicle model, the service dates you have selected, the scope of service you desire, and a supplementary message to your inquiry from you, as well as the desired contact channels for the dealer or service company chosen by you for the relevant inquiry.
The transmission of your personal data takes place once within the framework of the respective service request on the basis of the legal basis of GDPR Article 6  (a), i.e. your consent. We store your respective service request in order to fulfil the contract between you and us in accordance with GDPR Article 6  (b).
2.2.5 Collection of vehicle, service and product data for product and service development and improvement
You can consent to this on the "My Porsche" website.
The vehicle, service and product data comprise identification, basic, usage, analysis, environmental, traffic, location and movement data.
Some data cannot be deleted retroactively, as they are stored without concrete vehicle identification. In this case the data will be deleted after 5 years at the latest.
2.2.6 Reservation and purchase of services and products via the "Online Marketplace" section
Customers with a Porsche ID user account can use the "Marketplace" sections "Porsche Finder" and "Porsche Store". Customers without an existing Porsche ID contract can also use the Marketplace section "Porsche Store" via the "Guest access" feature.
Processing within the framework of the Online Marketplace is carried out partly by us, partly by the respective participant and partly under joint responsibility.
126.96.36.199 Processing under the responsibility of PSM GmbH
188.8.131.52 Processing under the responsibility of Marketplace participants
184.108.40.206 Processing under joint responsibility of PSM GmbH and Marketplace participants
In relation to these data processing activities, we determine the purposes and means of processing personal data in cooperation with the respective Marketplace participants.
In an agreement with the relevant Marketplace participants on joint responsibility, we have defined, pursuant to GDPR Article 26, the respective tasks and responsibilities in the processing of personal data and the responsible parties to fulfil data protection obligations. In particular, we have defined how an appropriate level of security and your rights as a data subject can be ensured, how we can jointly comply with data protection information obligations and how we can monitor potential data protection incidents. This also includes ensuring that we can fulfil our reporting and notification obligations.
2.2.7 Formation and processing of the rental agreement within the framework of Porsche Drive
In order to conclude a rental contract, you must provide us with the personal data listed below. You can save this personal data in your Porsche ID user account at any time, thus speeding up processing at the rental location. If you do not save this personal data in your Porsche ID user account in advance, you will be required to provide this personal data by completing this personal data in your Porsche ID user account at the rental location (possibly by our service provider). An appropriate device will be made available to you at the location for this purpose if necessary.
In order for a valid rental contract to be created, the following mandatory data must be saved in your Porsche ID user account:
If this data is not provided, it is not possible to draw up a rental contract and the vehicle cannot be collected.
We shall process the gathered data on the basis of GDPR Article 6  (b) and (f) in order to provide you with the services you require in this connection, and to implement the associated contractual relationship with you.
In order to establish your identity before you sign the rental contract, you will be asked by our service provider to identify yourself. In addition, to ensure the correctness of the data (for example no typographical errors, reversal of first and last name, the spelling of foreign street names and house numbers, etc.) and for security reasons (for example disclosure of the card number to the competent authorities in the event of a criminal offense or misdemeanour relating to the rented vehicle) a copy is generally made of your ID card. Unnecessary information (such as your height or eye colour) will be blacked out. You personal data will be processed on the basis of GDPR Article 6  (b), (c) and (f) in order to provide you with the services you require in this connection, to implement the associated contractual relationship with you and to meet our legal obligations. Our legitimate interest derives from the purposes set out at the beginning of this paragraph.
The vehicles have a device for tracking the location and condition of the vehicle (especially current mileage). Using this device, it is possible for a limited number of employees to keep track of the contractually agreed mileage and current location of the vehicle.
You personal data will be processed on the basis of GDPR Article 6  (b), (c) and (f) in order to safeguard our legitimate interest, to provide you with the support you require and to prevent uses contrary to the contract and potential damage as well as to fulfil official and/or legal requirements or obligations, such as official, public prosecutor or judicial requests.
Selected service providers are used by PSM GmbH for the fulfilment of the contract. These service providers are carefully selected by PSM GmbH. The Porsche Drive service currently uses the following service provider(s), working on behalf of PSM GmbH.
Porsche Zentrum Hamburg
Porsche Niederlassung Hamburg GmbH
Lübecker Str. 2
Porsche Zentrum Berlin
Porsche Niederlassung Berlin GmbH
Porsche Zentrum Dortmund
PZ Dortmund GmbH
Porsche Experience Center Leipzig
Porsche Leipzig GmbH
Porsche Zentrum Düsseldorf
Gottfried Schultz Sportwagen Düsseldorf GmbH & Co. KG
Porsche Zentrum Saarland
Scherer Sportwagen GmbH & Co. KG
Im Rotfeld 19
Porsche Zentrum Köln
Fleischhauer PZ GmbH
Porsche Zentrum Olympiapark
SZM Sportwagen Zentrum München GmbH
At the end of the rental period you will receive a summary of your trip data by e-mail. You can save this summary as you wish, or send it to third parties, independently of our offers, via your own terminal device or the third-party services you use.
After the end of the rental period, you also have the option of informing us by e-mail via an online dialogue (e.g. by awarding stars) how you enjoyed the rental. We process the data we collect on the basis of Article 6(1)(b) of GDPR in order to further improve the services based on your feedback.
2.3 Using the individual features without registration/login
2.3.1 Contact via Live Chat
In certain sections of our website we offer contact and advice via Live Chat. Live Chat allows you to communicate with one of our consultants via text messages. When you access and use Live Chat, your browser automatically transmits the following data at the beginning of use for technical reasons. We store this data separately from other data that you may transmit to us:
The legal basis for this data processing is GDPR Article 6  (f), whereby our legitimate interest is directed towards guaranteeing and maintaining the operation and security of our services and the elimination of faults. Within this framework, data is also processed by us for analysis purposes, without allocation to a specific person.
If you provide us with additional personal data via Live Chat, you do so on a voluntary basis. If personal data is required to clarify your request, we will point this out to you and ask you for your personal data. The texts you enter into the input mask during the Live Chat session are stored on our behalf on an external service provider's server. The legal basis for this data processing is GDPR Article 6  (b).
2.3.2 Guest access for reservation and purchase of services and products via the "Online Marketplace" section
2.3.3 Closest Porsche Drive location
This feature allows you to find the closest Porsche Drive location with your device.
When this feature is used, the following categories of personal data will be processed:
This is provided voluntarily. If you do not provide this data, however, we may not be able to fully comply with your wishes in relation to using this feature.
We shall process this data on the basis of GDPR Article 6  (b) in order to provide you with the services you require in this connection, and to implement the associated contractual relationship with you.
2.3.4 Non-binding reservation inquiry via Porsche Drive
This feature allows you to contact us using a contact form to make a non-binding reservation inquiry. The data gathered here will be used solely to process your inquiry and to send you a non-binding offer.
When using this feature, the following categories of personal data, marked with an "*", will be processed as mandatory data:
Reservation inquiries are not possible without providing this mandatory data.
As part of your reservation inquiry, you also have the option of providing further data on a voluntary basis, i.e. the following categories of personal data:
Please note that this information is not required for registration inquiries and whether you want to disclose this data to us is completely up to you.
We shall process this data on the basis of GDPR Article 6  (b) and (f) in order to provide you with the services you require in this connection, to implement the associated contractual relationship with you and to enable us to draw up an offer or reservation for you.
3. Rights of data subjects