BMW Personal Information Protection Policy
This Personal Information Protection Policy solely applies to the My BMW product or service provided by BMW China (with respect to imported vehicles, BMW China Automotive Trading Ltd.; with respect to domestic vehicles, BMW-Brilliance Automotive Ltd.) (hereinafter “BMW China” or “we”). With respect to such product or service, LingYue Digital Information Technology Co., Ltd. is the operator and service provider of My BMW, and BMW China Services Ltd. is the copyright owner and technology developer of My BMW.
Depending on the person who concludes a contract with, or provides services or products to, or carries out marketing activities to you, BMW China Automotive Trading Ltd. and BMW-Brilliance Automotive Ltd. will respectively 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 March 2023.
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:
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.
To enable your full use of the various services that LingYue provides and of the various features of My BMW 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 phone 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.
If you do not want to log in, you can select the guest mode to view the specific page of the My BMW APP, we will collect your IDFV for your normal use in the guest mode.
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 My BMW 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 My BMW
In the My BMW, we shall provide you with the following services and process the corresponding personal information:
(1) Services of BMW-emall.cn, including:
(a) We shall provide you or provide you through a third party with the new inventory sales services based on the purchase intention information you have reserved at BMW-emall.cn:
(b) We shall provide you (or through a third party) with the pre-owned inventory sales, pre-owned inventory trading or vehicle replacement services based on the purchase intention information, sales information, and replacement information that you have reserved in the “Shop Pre-Owned Inventory” of My BMW:
(c) You may pay online the deposit for the model that you are interested in at BMW-emall.cn:
(d) You may purchase online at BMW-emall.cn the original BMW branded parts, BMW lifestyle collection, and after-sales service vouchers at BMW-emall.cn:
(e) You may query the relevant information of BMW authorized dealers online:
(f) You may query online the new car range of particular all-electric models that you are interested in and the number of charging stations within the range:
(g) You can score and review the completed orders in Aftersale store and JOY coin store, and check the reviews by clicking product details, and turn to the review page of the product:
(2) BMW 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.
a) In order to send products to you when you use the points redemption service
b) In order to certificate the identity of the vehicle owner
c) 3rd party member acquisition track and reward
(3) Request a test drive. This service will enable you to request a test drive.
(4) Personal information export application
You can review the instruction for exporting personal information in My BMW App, then request for information exporting. After verifying your identity via security code, you can fill in the email address and set the extraction code, and apply for exporting personal information, membership information and etc. The information will be sent to your mailbox, opened and downloaded via the extraction code. In order to complete your personal information output, we will collect from you and use the following information:
The above information is necessary for the fulfillment of various features or related specified services embedded in the My BMW App. Therefore, we cannot provide the specified services under the various features of My BMW 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 My BMW 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.
Meantime, we will collect the following personal information during your use of My BMW:
If you do not provide the information listed above, you will not receive the customized product invitations and push services, but you can still use other products or services that we provide.
If you do not provide the information listed above, you cannot complete your BMW App account information filling, but you can still use other products or services that we provide.
You can apply personal data export in My BMW App. Personal data export statement is available for users in app. After verifying your identity, you can fill in your contact email and set a password to open the sent information zip you have applied in My BMW App (include personal information, membership information and others). In order to complete your personal information export, we will collect the following personal information:
When you use the relevant business functions, our App will apply to you for system permissions related to personal information:
(1) Bluetooth permission
We will seek your permission under the following circumstance:
(2) Location permission
We will seek your permission under any of the following circumstances:
(3) Camera permission
We will seek your permission under any of the following circumstances:
(4) Photo permission (only iOS)
We will seek your permission under any of the following circumstances:
(5) Notification permission
We will seek your permission under any of the following circumstances:
(6) Gyroscope permission
We will seek your permission under the following circumstance:
(7) Storage permission
We will seek your permission under the following circumstance:
(8) Calendar permission
We will seek your permission under the following circumstance:
(9) Network permission
We will seek your permission under the following circumstance:
(10) Read device information permission
We will seek your permission under the following circumstance:
(11) Access to network permission
We will seek your permission under the following circumstance:
(12) Access to network status permission
We will seek your permission under the following circumstance:
(13) Read and write access to files permission
We will seek your permission under the following circumstance:
(14) Sensor permission
We will seek your permission under the following circumstance:
(15) Clipboard permission
We will seek your permission under the following circumstance:
The above-mentioned system permissions are 15 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.
If you want to revoke the permissions you granted, you can enter the permission control page through "My" - "Settings" - "Device Permissions" - Enter My BMW App Information Page in the App, click the permission you want to revoke, select "Prohibited" to complete the permission revocation, or you can click "Revoke Permission and Free Up Space", the system will automatically revoke the permissions of the application that have not been used for a long time, and you can reauthorize it when you use it again.
In order to ensure the implementation of My BMW 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. The third-party SDK will collect your personal information including device information (IDFA, IDFV, OAID, IMEI, IMSI, Android ID, MAC address, hardware serial number, ICCID, SSID, BSSID, gyroscope sensor, IP address, GNSS information, device model, device manufacture, device memory, operating system type and version), network information, application information, geographic location, etc. You can click this link to check the comprehensive instruction of third-party SDKs.
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 My BMW product/service 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 My BMW App are provided by external providers. For example, we engage Hangzhou Bicheng Digital Technology Co., Ltd. to provide ecommerce operation services for bmw-emall.cn.
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. and Herald International Financial Leasing Co., Ltd., your personal information may be shared with BMW Automotive Finance (China) Co., Ltd. And Herald International Financial Leasing 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. Otherwise, we will delete or anonymize your personal information according to lawful regulations in case of the storage duration for your personal information expired.
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.
5. My BMW App may contain network links that are operated and maintained by third parties, but we have no control over such third parties. Please note that any information that you provide to a third party will be protected by the provisions of the personal information protection policy of such third party. We recommend that you enquire before providing any information to a third party. We assume no responsibility for the contents, acts or policies of third parties. The presence of a third-party link on My BMW App does not imply that we endorse the contents, acts or policies of such third party.
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 process your request after verifying your identity, then check and deal with the request within 15 working days.
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. We will process your request after verifying your identity, then check and deal with the 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 process your request after verifying your identity, then check and deal with the request 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 business 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.
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
Data Governance and Compliance Department of 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.
Data Governance and Compliance Department of BMW-Brilliance Automotive Ltd. Registered address: No. 14 Shanzuizi Road, Dadong District, Shenyang 110143.
We will process your request after verifying your identity, then check and deal with the request within 15 working days.