Privacy Policy - Information and Policies

Great Wall Motor Deutschland GmbH (hereinafter referred to as "GWMD" or "we") will protect and respect any personal information you share with us.

This Privacy Policy explains what kind of personal data we collect and process, to what extent and for what purpose, how we share personal data with others, how you can change and manage the information we hold, how you can contact us when you use our websites and services offered in this context (hereinafter collectively referred to as "Services"), and what rights you have in connection with the processing of your personal data.

Unless otherwise stated below, this privacy policy applies exclusively to products and Services provided by GWM.

We collect and process your personal data as described below when you use the functions of our Services:

A) When browsing our website

Each time you visit our website, our system automatically collects and processes data as follows:

(1) Information about the type of browser and the version used

(2) Operating system of the user

(3) User's internet service provider

(4) IP address of the user

(5) Date and time of access

(6) Websites from which the user's system accesses our website (referrer)

(7) Websites that are accessed by the user's system via our website

This data is also stored in the log files of our system. This data is usually not stored together with other personal data of the user unless there is a separate legal basis for such a processing.

The legal basis for the processing of the above data and the log files is Art. 6 (1) lit. f GDPR.

The storage in log files is done to ensure the functionality of the website. In addition, we use the data for technical optimization of the website and to ensure the security of our information technology systems.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. Log-files will be stored for a period of 7 days.

B) When registering for a Test Drive

When you register for a test drive via the website, we will process your name, phone number, e-mail address and country / postal code. We will process your country / postal code for the purposes of locating the agent nearest to your location for car collection and test drive. The test drive is performed by our agent (currently Emil Frey [Frey Import Services GmbH, Emil-Frey-Straße 2, 61169 Friedberg, Germany] and/or its authorized sub-agents. We will forward your data provided in this context to our agent for the agent and/or its authorized sub-agents to contact you via email or telephone once testdrives are available. The legal basis for the processing of the above data including the transfer to and processing through the agent / sub-agents is Art. 6 (1) lit. b GDPR (processing of your request and enabling you to perform a test drive). The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In this context the data may be stored until the test drive has been performed and additionally for as long as necessary to comply with statutory retention obligations (which can amount to 6 or 10 years) or to the extent necessary to fulfill other legitimate interests (Art. 6 (1) lit. f GDPR, e.g. for legal defense throughout statutory limitation periods).

Further data protection related information on Emil Frey can be found on the website of Emil Frey and their privacy policy.

C) When contacting us via the contact form

When you send messages to us via the contact form of the website or by e-mail, we will process and store your messages along with related information (such as your Name, e-mail-address, when the message was sent and message content). The legal basis for the processing is Art. 6 (1) lit. b GDPR (processing of your request). The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected or as necessary to comply with statutory retention obligations (which can amount to 6 or 10 years).

D) When registering for our newsletter or subscribing to other marketing related services

When you subscribed to marketing related services we may send you advertising or other marketing materials about goods, services and events of Great Wall Motor Deutschland GmbH or other partners of the Great Wall Motors company group by email ( as requested).

The legal basis for sending you marketing related information will be your consent (§ 7 UWG). The processing of personal data such as name and email address or phone number is based on Art. 6 (1) lit. f GDPR (direct marketing as legitimate interest).

For a better user experience, we may recommend products, services and events to you based on personal data you have voluntarily provided to us (such as your country). To the extent permitted by law we will do so based on our legitimate interest for direct marketing (Art. 6 (1) lit. f GDPR). In other cases, where a separate consent is required we will only do so based on your prior separate consent. Legal basis for such a processing would be Art. 6 (1) lit. a GDPR.

If you do not provide your personal data or do not give the corresponding consent, we will not be able to provide you with corresponding information and recommendations. You can revoke your consent at any time with effect for the future by e-mailing dpo@gwm-eu.com, or by contacting us via the provided contact details in this document.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Accordingly, the user's data collected in this context will be stored as long as the subscription to our marketing services is active.

E) Service improvement and business intelligence

We may use information that was collected during your visit of our website to better understand customisation and optimisation opportunities of our services, improve the design and usability of our Services and run customary and industry standard business intelligence analysis and reportings. For this purpose we may use selected user data in an anonymized or at least a pseudonymised form which does not allow to identify a natural person. Analysis and reports are always aggregated and anonymized and do not contain any personal data. The processing is based on Art. 6 (1) lit. f GDPR (business analytics, corporate management and product improvement as legitimate interest).

We only share your personal data within our company to those areas and persons who need this data to fulfil contractual and legal obligations or to implement our legitimate interests. We may grant companies affiliated with GWM access to our systems for supporting us with technical and administrative processing activities for our Services (other group companies usually acting as data processors).

We also work with other carefully selected service providers, including call-centres, who carry out certain activities on our behalf. These include, for example, technology service providers. These service providers are legally and contractually bound to ensure a high level of data protection and to process your personal data only in accordance with our instructions (data processors). If not necessary in order to perform our contractual obligations (Art. 6 (1) lit. b GDPR) or statutory legal obligations (Art. 6 (1) lit. c GDPR), such a processing is usually based on Art. 6 (1) lit. f GDPR (legitimate interest).

We may also pass on your personal data to other recipients such as public authorities, courts, lawyers, tax consultants insofar as this is necessary to fulfill contractual and legal obligations (Art. 6 (1) lit. c GDPR) or legitimate interests (Art. 6 (1) lit. f GDPR, e.g. for enforcing or defending against legal claims).

On this website we may use cookies. Cookies are files containing small amounts of information that are downloaded to a user's device when visiting a website and by which it is possible to recognize the device when it interacts or returns to the websites. Cookies may be used in combination with pixels, local storage objects and similar devices and technologies (hereinafter collectively referred to as "Cookies").

When providing our services we use Strictly Necessary and other Cookies, such as Statistics & Performance Cookies, Preferences Cookies and Marketing Cookies (the latter hereinafter referred to as “Not Mandatory Cookies”). Strictly Necessary Cookies are necessary for the operation of our website and applications. We cannot switch them off in our systems. We do not require your consent for the use of these Strictly Necessary Cookies. The use of these types of Cookies is based on our legitimate interest (Art. 6 (1) lit. f GDPR).

To the extent that we have received your consent (Art. 6 (1) lit a GDPR), we use Not Mandatory Cookies in order to be able to analyse the use of the website, use collected information for marketing purposes or provide you or allow third parties to provide information that has been customized for you. In this context, your data might be forwarded to social media partners and other third parties. If such measures are applied, further information on this and which Cookies are used to what extent will be provided in the Cookie Policy . For further details on the cookies used and to make adjustments to the cookie settings, please click the link "Cookie Settings" in the footer of this website.

You have the following rights:

a) the right to information about the processing of your personal data and access to the personal data we hold about you (Art. 13 GDPR);

b) the right to access the personal data about you we process (Art. 15 GDPR);

c) the right to request rectification of your personal data if it is inaccurate or incomplete (Art. 16 GDPR);

d) the right to request deletion of your personal data in certain circumstances. Please note that circumstances may arise where you ask us to delete your personal data but we are required by law to continue to retain it in order to comply with a legal obligation (Art. 17 GDPR);

e) in certain circumstances, the right to receive some personal data in a structured, common and machine-readable format and/or to request that we transfer this information to third parties, if technically feasible (Art. 20 GDPR);

f) under certain conditions, the right to request the restriction of processing (Art. 18 GDPR);

g) the right to withdraw your consent to the processing of your personal data. We will then no longer process your data in the future. Please note that we may still be entitled to process your personal data if there is a relevant legal basis (other than consent) for doing so. For example, we may need to retain your personal data to comply with a legal obligation. To withdraw your consent please e-mail us at dpo@gwm-eu.com.

h) the right to object and the right to request that we restrict our processing of your personal data in certain circumstances. We will then no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims; if personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. In such a case, we will no longer process the data for these purposes (Art. 21 GDPR); and

i) the right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

Contact details for all European Union supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

The contact details for all German supervisory authorities can be found here: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

If you have any questions about data protection or wish to exercise your rights as a data subject, please feel free to contact us or our data protection officer at any time using the contact details provided in section 1 of this Privacy Policy.

How long we keep your personal data varies and is determined by the following criteria:

We must keep personal data for as long as is necessary for the purpose for which it was obtained or for other legal purposes.

Applicable laws or regulations may stipulate a minimum retention period for which we must retain your personal data. In addition, personal data may have to be stored for the period during which claims are or can be asserted against GWM (statutory limitation period of 3, but depending on the circumstances also up to 10 years).

Once the purpose has been fulfilled, we will (1) permanently delete your personal data or (2) ensure that your personal data is anonymised and thus no longer identifiable. Legal basis for the anonymization is Art. 6 (3) lit. f GDPR (legitimate interest).

The systems used to operate the Services are hosted in the European Union (EU) or the European Economic Area (EEA). In very limited cases personal data on our systems may be accessed from places outside the EEA from countries which do not provide for an adequate level of data protection (no adequacy decision of the European Commission acc. to Art. 45 GDPR). However, such access is not subject to the regular processes but may just not be fully excluded in exceptional cases. We conclude standard contractual clauses issued by the European Commission with the respective third parties where necessary according to applicable laws. Any data access is flanked by further technical and organisational measures as required. For more information about how we keep your personal data safe in this context, please contact us at dpo@gwm-eu.com.