BMW Personal Information Protection Policy

This Personal Information Protection Policy solely applies to the products and services BMW China Automotive Trading Ltd. (hereinafter “BMW China” or “we”) provides to you through the MINI App. With respect to such product or service, Lingyue Digital Information Technology Co., Ltd. is the operator and service provider of the MINI App, and BMW China Services Ltd. is the copyright owner and technology developer of the MINI App.

BMW China Automotive Trading Ltd. will determine the purpose for and method of processing your personal information, and protect your personal information in accordance with the provisions of this Personal Information Protection Policy.

This Personal Information Protection Policy was updated in May 2022.

If you have any questions or comments, please contact us at the contact information set out in Part IX hereof.

 

This Personal Information Protection Policy helps you understand the following information:

  1. Our business functions and how we collect and use your personal information
  2. How we use cookies and other similar technologies
  3. How we entrust, share, transfer and publicly disclose your personal information
  4. How we protect your personal information
  5. Your rights
  6. How we process personal information of children
  7. How your personal information will be transferred globally
  8. How this Personal Information Protection Policy will be updated
  9. How to contact us

 

We are fully aware of the importance of personal information to you and treat your personal information in accordance with the same high standards that you expect from BMW products and services. We are committed to creating and maintaining your trust in us and observe the following principles when protecting your personal information: consistency between rights and liabilities, clear purposes, solicitation of consent, minimum necessity, guarantee of security, involvement of personal information subjects, and openness and transparency. Meanwhile, we are committed to setting up necessary safeguards pursuant to well-developed security standards in order to protect your personal information.

By affixing your signature hereto, or clicking on “read”, “agree” or other similar options, or accepting the products or services that we provide, and submitting to us your personal information, you have accepted this Personal Information Protection Policy.  We will use and protect your personal information according to the relevant laws and regulations and this Personal Information Protection Policy. Please carefully read this Personal Information Protection Policy before ticking or clicking on “read”, “agree” or other similar options, accepting the products or services that we provide, filling in, confirming, authorizing the export and import of personal information, or signing the authorization document, and ensure a full understanding of the meaning of this Personal Information Protection Policy and the corresponding legal consequences.

 

 

I. Our business functions and how we collect and use your personal information

Personal information means any information saved in electronic or other forms that relates to an identified or identifiable natural person, including but not limited to name, date of birth, identification number, personal biometric information, address and telephone number, but excluding anonymised information.

Sensitive personal information means the personal information that is likely to infringe on the personal dignity of, or endanger the personal or property safety of, a natural person, once it is leaked, unlawfully used.  In general, biometric information, religious beliefs, particular identities, medical health, financial accounts, personal whereabouts and other information, as well as personal information of minors under the age of fourteen are regarded as sensitive personal information.  In this Personal Information Protection Policy, the terms and articles concerning sensitive personal information will be marked in bold for your special attention.  In scenarios where sensitive personal information is actually collected, we will further bring to your attention by means of an enhanced notification or an instant alert (such as a pop-up window) and obtain your authorization, or request you to otherwise click confirm or sign a Separate Consent.

We will collect and process your personal information solely for the purposes specified as below.

Unless otherwise indicated in below the purposes, we store your personal information only for as long as the relevant purpose requires it. If your personal information is processed for multiple purposes, your information will be deleted or stored in a form that cannot directly be traced back to you, as soon as the last specified purpose has been fulfilled.

1. User registration

To enable your full use of the various services that Lingyue provides and of the various features of MINI App, you have to register a BMW ID. After registration, you will receive an online customer account, and log in with such account will enable you to access to all portals and online service platforms of the BMW China simultaneously. In order to register and use the account, we will collect from you and use the following information:

(1)       mobile number

(2)       BMW ID (BMW account) login information

If you do not provide such required information, you will not be able to obtain a BMW ID or log in with a BMW ID and further enjoy and fully use the various services provided by BMW China.

Meanwhile, if you have registered such online customer account with other BMW platforms, you may also log in on such platform with such account.

When you are using our services, we will be authorized to use the above-said information you have provided. We will cease using and delete the above-mentioned information (including the personal information generated during your use of the customer account) in a timely manner after you withdraw your consent, request deletion of your personal information pursuant to this Personal Information Protection Policy, or cancel your user account. Nevertheless, in accordance with the applicable legal or regulatory provisions, or cancel your user account. Nevertheless, in accordance with the applicable legal or regulatory provisions, information related to use of the MINI App and/or financial transactions will be retained for statutory time limit after the use is completed or the transaction is completed and be subject to reviews by the relevant authorities.

2. Providing the relevant services of MINI App

In the MINI App, we shall provide you with the following services and process the corresponding personal information:

(1)       MINI China member alliance service. This service will enable you to enjoy the benefits and rewards provided by BMW China and its dealers, as well as BMW China partners.

(2)       Request a test drive. This service will enable you to request a test drive.

The above information is necessary for the fulfillment of various features or related specified services embedded in the MINI App. Therefore, we cannot provide the specified services under the various features of MINI App unless you have submitted the information and we are authorized to process it.

The above personal information will be deleted when you cease to use the related feature of MINI App and cancel the BMW ID, unless it is required to be retained under laws and regulations or your further authorization and consent is obtained.

In order to improve service quality and enhance your user experience of the product, we will collect the following personal information during your use of the MINI App, including: (1) terminal device information of a MINI App user; (2) MINI App account login information; (3) APP use records and click records; and (4) date of birth.

The information listed above is not necessary for the use of related products or services but has important meanings for improving service quality and for researching and developing new products and services or other purposes of this Personal Information Protection Policy.

When you use the relevant business functions, our App will apply to you for system permissions related to personal information:

1)       Notification permission

We will seek your permission under any of the following circumstances:

2)       Storage permission

We will seek your permission under the following circumstance:

3)       Location permission

We will seek your permission under the following circumstances:

The above-mentioned system permissions are three items in total. Without your permissions we will not be able to provide the specific functions of such business. Except for the above-mentioned system permissions, you may voluntarily choose whether you would like to grant the APP other system permissions.

In order to ensure the implementation of MINI App related features and stable operation of application, we may access the software development package (SDK) provided by a third party to achieve relevant purposes. Different versions of third-party SDKs may vary, which generally include map navigation and push notifications. We will carry out strict security monitoring on the software development package (SDK) for the partners to obtain information to protect data security. Below is the rules of third-party SDKs for the use and protection of personal information. In addition, for Android version 28 and above, we may require additional access to your device in the relevant business functions. The detailed permissions and usage purposes as follows, android.permission.GET_TASKS(get task information permission): allows apps to get current or recently running apps

SDK

Features and Purposes

Provider

Permission Required

User Information Collected

Link to Privacy Policy

 

Tencent OCR SDK

 

Recognize customer's cert card & vin

 

Shenzhen Tencent Computer System Co., Ltd.

 

 

Network permission, Camera permission

 

Device Info, Cert Card information, VIN

 

https://cloud.tencent.com/document/product/301/11470

 

 

AutoNavi Map SDK (autonavi-atlas, autonavi-maps);

AutoNavi Navigation SDK (autonavi-geolocator)

To locate the device, plan the route, and search for points of interest

AutoNavi Software Co., Ltd

Location permission, read access to device information, network access, access to network status, access to wifi status

Geographic location, mobile device operation information (MAC address, device model, terminal device manufacturer and SSID)

https://developer.amap.com/pages/privacy/

Countly SDK

To collect users’ front end interactive behaviour data

Countly Ltd

Network access, read access to device information, read and write access to files

Mobile device operation information (device model)

https://count.ly/legal/privacy-policy

Miaozhen Analytics

Flutter SDK

To collect users’ front end interactive behaviour data

Beijing Mininglamp Technology Co., Ltd.

Network access, read access to device information, read and write access to files

Mobile device operation information (device model and terminal device manufacturer), users browsing and click behaviour in the App

https://miaozhen.com/cn/privacy

JPush

To deliver system push notifications

Shenzhen Hexun Huagu Information Technology Co., Ltd.

Notification permission, network access, read access to device information

Mobile device operation information (device model, terminal device manufacturer, and type and version of operating system of terminal device)

https://www.jiguang.cn/license/privacy

Huawei Push Kit

To enable push notifications through manufacturer channel when the App is running in the background

HUAWEI Software Technology Co., Ltd.

Notification permission, network access, read access to device information

Mobile device operation information (AAID), network status

https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/privacy-statement-0000001050042021

MiPush

To enable push notifications through manufacturer channel when the App is running in the background

Xiaomi Technology Co., Ltd.

Notification permission, network access, read access to device information

Mobile device operation information (device identifier, OAID, encrypted Android ID, and network status)

https://dev.mi.com/console/doc/detail?pId=1822

Vivo Push (Vpush)

To enable push notifications through manufacturer channel when the App is running in the background

Guangdong Tiancheng Network Technology Co., Ltd.

Notification permission, network access, read access to device information

Device model, terminal device manufacturer, type and version of operating system of terminal device, and network status

https://dev.vivo.com.cn/documentCenter/doc/366#w1-08512613

OPPO Push (OPUSH)

To enable push notifications through manufacturer channel when the App is running in the background

Guangdong HeyTap Technology Co., Ltd.

Notification permission, network access, read access to device information

Device model, terminal device manufacturer, type and version of operating system of terminal device, and network status

https://open.oppomobile.com/wiki/doc#id=10288

 

3. Ensuring product quality and developing new products

Beyond the mere provision of services, the information collected under I.1 and I.2 will also be processed to ensure the quality of the BMW products and services and to develop new BMW products and services. This kind of processing is related to BMW’s commitments to meet high customer demand for existing products and services and to satisfy the future wishes of our customers with new products and services still to be developed.

4. Fulfilment of the sales, service, and administration processes

In order to continuously optimize the customer experience and cooperation with the BMW dealers, we may compile analyses and reports based on the information collected under I.1 and I.2, which we may share with the responsible BMW dealers. These analyses will primarily be used to introduce appropriate measures (e.g. training for sales staff) to improve the application and sales process.

Also, parts of the personal information and vehicle-specific data collected under I.1 and I.2 will be processed to fulfill the service processes (e.g. repair, warranty, goodwill) of BMW China and authorized dealers. This kind of processing is to offer our customers the best possible service process. The technical vehicle data will be deleted in a timely manner at the end of the vehicle’s service life. However, if there are specific stipulations under the laws and regulations and required by the authorities, we are still obligated to retain your personal information to the extent permitted by law (e.g. information related to contractual transactions will be retained within statutory time limit and may be inspected by the relevant authorities). 

5. Customer service

We use your personal information (i.e. your name, email address and phone number) to contact you in connection with the processing of contracts (e.g. booking of BMW Connected Drive services) or to process a request formulated by you (e.g. inquiries and complaints sent to BMW customer services). For all aspects of processing contracts or requests, we will contact you without obtaining separate consent, e.g. in writing, by telephone, messenger services, or email, depending on the contact media you specified.

6.  Customer activities, marketing campaign and market research

You acknowledge and agree that we may use your personal information for customer activities, marketing campaigns and/or market research purposes during your use of our services. For example, we will use your name, email and phone number and other relevant personal information to carry out customer group analysis and other market research to optimize and improve the services we provide, or to offer you personalized products according to your interest. At the same time, your above information will also be used to carry out customer care and marketing activities, including information of our new cars, product promotions, holiday blessings and other promotional information. Should you wish not to receive such information, you can unsubscribe by following the instructions given in the relevant message or by contacting us. In addition, we will obtain your personal information from our dealers based on your authorization to do so. We will verify the legitimacy of the sources of such personal information and the scope of authorization, and will further seek your authorization if your scope of authorization is exceeded. For details, please refer to the authorization statement under the specific scenario. You have the right to revoke such consent at any time at your own discretion.

In addition, we will collect and use your personal information required for your participation and for the purposes of I.3 to I.8 of this Personal Information Protection Policy (e.g. to optimize and improve the services we provide, or to offer you personalized products according to your interest) during your participation in the online or offline activities held by us on an irregular basis. The types of personal information collected and the content of the activities will be explained to you separately at the time of collection, and we will obtain your consent in the form of BMW Statement on Personal Information Collection and Use. Under such scenarios, the BMW Statement on Personal Information Collection and Use will remind you to read this Personal Information Protection Policy, and by participating in our online or offline activities, you will be deemed to have read and accepted this Personal Information Protection Policy. We will process your personal information in strict accordance with this Personal Information Protection Policy.

7. Fulfilment of statutory obligations

We may process your personal information based on statutory and regulatory obligations, such as when we perform a recall obligation which involves your vehicle or carry out a technical activity.

Sometimes, parts of the vehicle information collected under I.2 are also processed to meet legal and regulatory requirements such as disclosure of repair and maintenance information request by the relevant regulation. To protect the privacy of our customers, the processing of technical information listed below is always vehicle-related and without direct or indirect connection to the specific customer.

In order to ensure the secured operation of IT systems, we may need to use your information. Smooth and secured operation of IT systems will be ensured with the following actions, among others:

The information collected is also processed as part of internal compliance management by which we check, for example, whether you received sufficient advice when concluding a contract and that the dealer complied with all statutory obligations.

We are subject to a variety of other statutory obligations. In order to fulfill these obligations, we process your information to the extent required by laws, regulations and regulatory requirements

8. Exceptions to acquire authorization and consent for collection and use of personal information

In accordance with relevant laws, regulations, and national standards, we may collect and use your personal information without your consent in the following scenarios:

(1)      where it is required to enter into and perform a contract to which you are a party;

(2)      where it is required for us to perform statutory duties or statutory obligations;

(3)      where it is required to respond to public health emergencies or protect the life, health and property safety of you and others;

(4)      processing of your personal information to a reasonable extent in order to implement news reporting, public opinion supervision or other acts for the public interest;

(5)      lawfully processing of your personal information disclosed by you or otherwise lawfully disclosed to a reasonable extent;

(6)      other scenarios stipulated in laws and administrative regulations.

Please note that in accordance with applicable laws, if we take technical measures to process personal information so that such information cannot re-identify particular individuals and cannot be restored, such information shall no longer be personal information. We may use such information for research, statistics and analysis so as to improve the content of BMW products, provide support to business decisions and improve our products and services, and may share such statistics with the public or a third party to show the overall usage trends of our products and/or services. It is not necessary to otherwise inform you or obtain your consent for such use.

 

II. How We Use Cookies and Other Similar Technologies

We do not use cookies and other similar technologies in the product/service offered through the MINI App to collect your personal information.

 

III. How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information

1. Entrusted processing

In order to provide you with professional and high-quality products and services, certain modules or functions of MINI App are provided by the affiliated companies of BMW China (e.g. BMW China Services Ltd. and Lingyue Digital Information Technology Co., Ltd.), BMW authorized dealers and/or external providers engaged by us.

In such circumstances, in order to provide you with relevant services and support, we have to entrust such affiliated companies, BMW authorized dealers and/or external providers with the processing of your personal information. In the case of entrusted processing, we will, to the extent of this Personal Information Protection Policy, determine the method of and purpose for processing your personal information, and the entrusted party will process your personal information as instructed by us. If you have questions regarding the processing of personal information for such modules or functions, or seek a complaint, you can contact us directly through the contact means set out in IX.

In the case of entrusted processing, we will based on your scope of authorization agree with all companies, organizations and individuals entrusted by us with the processing of personal information on the purpose, term and method of processing, types of personal information, protection measures and rights and obligations of us and them, and supervise their processing of personal information. We will ensure that the entrusted companies, organizations and individuals process your personal information in accordance with our agreements with them and will not process your personal information beyond the agreed purpose for and method of processing. We will enter into strict non-disclosure agreements with all entrusted companies, organizations and individuals and require them to process personal information according to our instructions, this Personal Information Protection Policy and any other related measures for confidentiality and security.

2. Sharing

 (1) Sharing information with our affiliated companies and dealers

Save for the case of entrusted processing, we may share your personal information with our affiliated companies and dealers from time to time. Different from entrusted processing, in the case of sharing your personal information, our affiliated companies and dealers as the receiving party will independently determine the purpose for and method of processing your personal information. Therefore, in the case of sharing your personal information, we will inform you of the details of such sharing and obtain your separate consent.

 (a) Sharing information with our affiliated companies. To realize the purposes specified in this Personal Information Protection Policy, if you grant your authorization and consent to use the services provided by BMW Automotive Finance (China) Co., Ltd., your personal information may be shared with BMW Automotive Finance (China) Co., Ltd.

If an affiliated company changes the purpose for processing your personal information, your further authorization and consent will be obtained.

(b) Sharing with authorized dealers. To realize the purposes specified in this Personal Information Protection Policy only, subject to your authorization or separate consent, we may share some of your personal information with our authorized dealers, in order to offer you more convenient client services and to enhance your user experience. We will enter into strict non-disclosure agreements with all companies, organizations and individuals with which we share information and require them to process personal information according to our instructions, this Personal Information Protection Policy and any other related measures for confidentiality and security.

(2) We may share your personal information with external parties as required under laws or regulations or upon compulsory requirements of competent government authorities.

(3) We will share the necessary personal information only for the purposes specified in this Personal Information Protection Policy. Before sharing your personal information, we will remind you again by means of pop-ups and obtain your authorization, or request you to otherwise click confirm or sign a Separate Consent.

3. Provision

We will not provide your personal information to any other company, organization or individual, except under the following circumstances.

(1) Providing information with explicit consent: we will provide your personal information to other parties after obtaining your explicit consent.

(2) If your personal information has to be provided to the successor of the rights and obligations of a company in a merger, acquisition or bankruptcy liquidation, we will inform you separately and require the new company or organization that will hold your personal information to continue to observe this Personal Information Protection Policy.  Otherwise, we will require the new company or organization to request for your authorization and consent before transferring your personal information.

4. Disclosure

We will disclose your personal information only under the following circumstances.

(1) Where it is necessary for our business and after obtaining your separate consent.

(2) Disclosure under the law: we may publicly disclose your personal information as required by laws, under legal procedures, in lawsuits or upon compulsory requirements of competent authorities under the government.

5. Exceptions to acquire authorization and consent for sharing, provision and disclosure of personal information

In accordance with relevant laws, regulations, and national standards, we may share, transfer, or disclose to the public your personal information without your prior authorization and consent if:

(1)      where it is required to enter into and perform a contract to which you are a party;

(2)      where it is required for us to perform statutory duties or statutory obligations;

(3)      where it is required to respond to public health emergencies or protect the life, health and property safety of you and others;

(4)      processing of your personal information to a reasonable extent in order to implement news reporting, public opinion supervision or other acts for the public interest;

(5)      lawfully processing of your personal information disclosed by you or otherwise lawfully disclosed to a reasonable extent;

(6)      other scenarios stipulated in laws and administrative regulations.

 

IV. How We Protect Your Personal Information

1. We store your information based on the state of the art and we take the following safeguards to protect your personal information from misuse or any other unauthorized processing, disclosing, using, rectifying, or destroying. Access to personal information is restricted to a limited number of authorized persons for the stated purposes only.  The data collected will only be transmitted in encrypted form. Sensitive data is stored only in encrypted form. The IT systems for processing the data are technically isolated from other systems to prevent unauthorized access, e.g. through hacking. In addition, access to these IT systems is continuously monitored to detect and ward off misuse at an early stage.

2. We will take all reasonable and feasible measures to ensure that we only collect such personal information as required to realize the purposes specified in this Personal Information Protection Policy. We will only retain your personal information for a limited period necessary for realizing the purposes specified in this Personal Information Protection Policy, unless it is necessary to extend the retention period or it is protected under the law.

3. The Internet is not an absolutely safe environment. Although we are committed to protecting your personal information, we cannot guarantee or warrant that it is absolutely secure. Therefore, you shall also take active measures to ensure the security of your personal information, e.g. changing your account password on a regular basis, and not disclosing your account password information to others.

4. In the case of any incident in respect of personal information security, we will, pursuant to requirements set out in laws and regulations, inform you promptly of the particulars, including basic information about the security incident and the likely impact, what measures we have taken or will take to respond to such incident, suggestions on what measures you may take yourself to guard against and lower risks, remedial actions we offer to you, etc. We will brief you on the progress of the incident by email, correspondence, phone or by sending notifications, and we will release announcements for this purpose in a reasonable and effective manner even when it is difficult to notify personal information subjects one by one.

Meanwhile, we will actively report how the personal information security incident is being handled pursuant to the requirement of the regulator.

 

V. Your Rights

According to applicable Chinese laws, regulations and standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights with respect to your personal information:

1. Accessing, review and copy your personal information

You have the right to access your own personal information, unless there are exceptions in laws and regulations. If you would like to exercise your right to access to personal information, you may contact us via email at servicecenter@bmw.com.cn. We will respond to your request within 15 working days upon authentication of your identity.

You have the right to copy your personal information, or obtain a copy of your information. You may contact us via email at servicecenter@bmw.com.cn.

If it is technically feasible, such as matching of data interface, and is in line with the conditions stipulated by the national cyberspace administration, we also can directly transfer a copy of your personal information to the third party designated by you.

2. Rectifying your personal information

If you find that your personal information we process is inaccurate, you have the right to request us to rectify your information. You may contact us at servicecenter@bmw.com.cn to request the detailed process of rectification. Upon authentication of your identity, we will respond to your request within 15 working days.

3. Deleting your personal information

You may request the deletion of your personal information under any of the following circumstances:

(1) When our processing of personal information violates laws or regulations;

(2) When we collect or use your personal information without your consent;

(3) When our processing of personal information violates our agreement with you;

(4) When you have achieved, or find it impossible or unnecessary to achieve, the purpose of processing your information (for example, you no longer use our products or services, or you cancel your account);

(5) When you revoke your consent to our processing your personal information.

If we agree with your request to delete information, we will also notify entities that obtain your personal information from us to require them to delete the information concerned in a timely manner, unless otherwise stipulated by laws and regulations or such entity has obtained your separate authorization.

Once your information has been removed from our services, due to the restrictions under the applicable laws and regulations, we may not immediately delete the corresponding information from the backup system, but we will store the information safely without further processing until the backup could be eliminated or anonymized. To fully protect your personal rights and interests, we may retain the necessary information in the backup system whilst keep such information unsearchable or inaccessible through technical means.

4. Changing the scope of your authorization or revoking your consent
    You may at any time grant or revoke your authorization or consent for our collection and use of your personal information. You may revoke your consent by emailing us at servicecenter@bmw.com.cn. Please note that each business function cannot be realized without some basic personal information (see Part I of this Personal Information Protection Policy); thus, we cannot continue to provide the relevant services to you if you revoke your consent for our collection and use of your personal information required for the business function.

After you have revoked your consent, we will no longer process the personal information in respect of which your consent is revoked. But your decision to revoke your consent does not affect the previous processing of personal information based on your authorization.

If you do not want to receive commercial advertisements and other marketing and promotion information we send, you may unsubscribe at any time by emailing us at servicecenter@bmw.com.cn.

5. Cancelling user accounts

You may at any time cancel your BMW ID by emailing us at servicecenter@bmw.com.cn.

After your account is cancelled, we will cease providing you with products or services, and delete your personal information in a timely manner, unless otherwise stipulated by laws and regulations.

6. Use of automatic decision-making of the information system

Our decisions will not only rely on the automatic decision-making mechanisms, such as the information system and algorithms.

7. Responding to your requests

You may make requests in respect of your personal information by the above said methods. For the sake of security, you may be required to submit your request in writing or otherwise prove your identity. We may request authentication of your identity before responding to your requests.

We will reply within 15 working days. If you are dissatisfied with our reply, you may lodge a complaint by emailing us at servicecenter@bmw.com.cn.

In principle, we will not charge fees for your reasonable requests. However, if your requests are lodged repeatedly or beyond a reasonable extent, we will charge fees of a proper amount depending on the cost. We may refuse your requests if they are repeated without reason, need to be replied to through excessive technical methods (for example, a new system needs to be developed or the existing common practices need to be fundamentally reformed), pose risks to others’ legal rights or interests, or are fairly unrealistic (for example, it involves information stored on backup tapes).

We will not respond to your requests under any of the following circumstances.

(1) Where requests are in relation to our performance of the obligations specified in laws and regulations;

(2) Where requests are in direct relation to the national security or national defense security;

(3) Where requests are in direct relation to the public security, public sanitation, or major public benefits;

(4) Where requests are in direct relation to investigations into crimes, prosecutions, court trials, execution of rulings, etc.;

(5) Where we have sufficient evidence that you are intentionally malicious or abusing his/her rights;

(6) Where personal information collecting and processing are for the sake of safeguarding significant legal rights and interests, such as the life and property of you or other individuals, but it is difficult to obtain your or their consent;

(7) Where responses to your requests will give rise to serious damage to the legal rights and interests of you or any other individual or organization; or

(8) Where requests involve trade secrets.

 

VI. How We Deal with Children’s Personal Information

Our products and services are designed primarily for adults. We will not create a BMW ID for children, nor collect or use the personal information of children. If it is necessary to collect and use the personal information of children, we will inform their guardians beforehand to obtain their separate consent.

For the purpose of this Personal Information Protection Policy, we regard any minor who is under the age of 14 as a child.

If we find that we have created a BMW ID for children or collected the personal information of children without prior, provable and separate consent from the children’s guardians, we will do our best to delete the relevant account and information as soon as possible.

 

VII. How Your Personal Information Will Be Transferred Globally

The personal information we collect and generate within the territory of the People’s Republic of China (PRC) will be stored within the territory of the PRC. Therefore, your personal information will not be transferred to other jurisdictions outside the PRC or be accessed by these overseas jurisdictions. If cross-border data transfer is required in the future, we will otherwise ask for your permission, comply with the applicable laws and regulations, and make sure that your information will be under the same and equal protection as in the PRC.

 

VIII. How this Personal Information Protection Policy Will Be Updated

Our Personal Information Protection Policy may be changed. We will not reduce your rights under this Personal Information Protection Policy without your explicit consent. We will publish any change to this Personal Information Protection Policy at this page. We will keep the former versions of this Personal Information Protection Policy available to you for reference.

In the case of major changes, we will release clear notices (including, for some services, the mail messages that inform you of what specific changes are introduced to this Personal Information Protection Policy).

The major changes in this Personal Information Protection Policy include but are not limited to:

1. Significant changes to our service mode, such as the purposes of processing personal information, categories of personal information to be processed, the ways to use personal information, etc.;

2. Substantial changes to the ownership structure, organizational structure, etc., such as changes to the owners as a result of business adjustments, bankruptcy, mergers and acquisitions;

3. Changes to the subjects we share with, transfer to or publicly disclose personal information;

4. Significant changes to your rights in respect of your participation in personal information processing and to the ways in which you can exercise such rights; and

5. Changes to our department responsible for the security of personal information, contact information of such department, or complaint channels.

 

  1. How to Contact Us

If you have any concerns or comments on this Personal Information Protection Policy, please contact us through the following means:

Email: servicecenter@bmw.com.cn

Contact information: 400-800-6666

BMW China Automotive Trading Ltd., registered address: 28F, Tower B, Gateway Plaza, No. 18 Xia Guang Li, North Road East Third Ring, Chaoyang District, Beijing 100027.

We will make every effort to reply all requests within 15 working days.