BMW Children’s Personal Information Protection Policy and Instructions for Guardians

Latest update:

November, 2023

BMW China ("We") is well aware of the importance of the security of children’s (referring to any natural person under the age of fourteen, the same below) personal information. We meet customers' high expectations for BMW products and strictly treat children's personal information involved in our products or services. We are committed to taking corresponding security protection measures in accordance with the well-established industry security standards to adequately protect children's personal information.

This BMW Children's Personal Information Protection Policy and Instructions for Guardians (this "Policy") aims to explain to guardians and children our rules for processing children's personal information based on the BMW Personal Information Protection Policy. Where there is any inconsistency between the rules in this Policy and the BMW Personal Information Protection Policy, this Policy shall take precedence; where this Policy is not specified, the provisions in the BMW Personal Information Protection Policy shall apply by reference.

If you have any questions, comments or suggestions about the content of this Policy, you may contact us through the contact information provided in Part 6 of this Policy.

Special Note：

       1.      Our products and services are mainly targeted at adults. We do not create BMW IDs for children. In principle, we will not proactively collect or use children's personal information. In case you provide us with children's personal information for your own needs, please note that:

       -        If you are the guardian of a child, in order to protect the legitimate rights and interests of the child, you should read this Policy carefully. If you do not agree with the content of the relevant documents, please do not provide us with the child's personal information. If you find that we have collected or used the child's personal information without the verifiable prior consent from the guardian, please contact us in due course and we will try to delete the relevant accounts and personal information as soon as possible.

       -        If you are a child, you should not obtain our products, websites and services alone or provide us with any of your personal information. You should notify your guardian to read this Policy and act with the confirmation of your guardian.

       2.      By signing, or clicking "Read", "Agree" or other similar options, or accepting the products or services we provide, and submitting relevant children's personal information to us, you will be deemed to have ensured that you have full rights, capability and authority to conduct relevant operations and that you have also accepted this Policy. We will use and protect the children's personal information you provide in accordance with relevant laws, regulations and this Policy. Please read this Policy carefully and make sure you are fully aware of and fully understand the meaning of its content and corresponding legal consequences before checking or clicking "Read", "Agree" or other similar options, accepting the products or services we provide, or filling in, confirming, authorizing the export or import of children's personal information, or signing the authorization document.

I. Our business functions and how we collect and use children’s personal information

We will only collect and use children's personal information for the following purposes as described in this Policy.

A.     Purchase of children-owned vehicle

Within the scope permitted by laws and regulations, if you need to register the owner of the vehicle you purchased as a child, you need to provide us with the child's relevant information to complete the corresponding operation.

1.      Real-name online registration of telematics cards. The guardians of the child register the owner of the vehicle you purchased as the child online and complete online vehicle owner authentication. In order to verify your identity as the guardian, we need to collect the proof materials of the children and the relationship between you and the children,

• Name of the vehicle owner
• Valid ID information (including type, number, validity period and mailing address of the ID, photo)
• VIN
• Vehicle credentials information (including name, type, photo)
• The relationship proof materials(including household register, birth certificate, only child certificate, police station certificate, adoption certificate, court judgment and effective certificate, or other materials that can prove the guardianship relationship are all sufficient )
• The frontal bareheaded photo of guardians
• The phone number of guardians

2.      Real-name online authentication of the vehicle owner. The guardians of the child register the owner of the vehicle you purchased as the child online and complete online vehicle owner authentication. In order to verify your identity as the guardian, we need to collect the proof materials of the children and the relationship between you and the children,

• Name of the vehicle owner
• Valid ID information (including type, number, validity period and mailing address of the ID, photo)
• VIN
• Vehicle credentials information (including name, type, photo)
• The relationship proof materials(including household register, birth certificate, only child certificate, police station certificate, adoption certificate, court judgment and effective certificate, or other materials that can prove the guardianship relationship are all sufficient )
• The phone number of guardians

3.      Real-name on-store registration of telematics cards. The guardians of the child register on-store the owner of the vehicle you purchased as the child and complete online vehicle owner authentication. In order to verify your identity as the guardian, we need to collect the proof materials of the children and the relationship between you and the children,

• Name of the vehicle owner
• Valid ID information (including type, number, validity period and mailing address of the ID, photo)
• VIN
• The relationship proof materials(including household register, birth certificate, only child certificate, police station certificate, adoption certificate, court judgment and effective certificate, or other materials that can prove the guardianship relationship are all sufficient )
• The frontal bareheaded photo of guardians
• The phone number of guardians
• The vehicle invoice information(including number, title, identified number and photo)

4.      Creating a vehicle order for children owner. When purchasing a BMW vehicle (including second-hand vehicle), in order to maintain order and invoice information, you need to provide us with the following personal information of the child:

• Name
• Valid ID information (including ID type and ID number)

Please understand that, except for the above scenarios that expressly involve the collection and use of children's personal information, under most circumstances, we cannot identify whether the users using our products and/or services are children, or whether the information we collected and used that does not have obvious age identification characteristics is children's personal information. In such cases, we will collect and process relevant personal information in accordance with the BMW Personal Information Protection Policy. If you, as the guardian of the child, find that we have collected or used the child's personal information under such circumstances without obtaining the verifiable separate consent from the guardian in advance, please contact us in due course and we will try to delete the relevant personal information as soon as possible.

II. How we provide children's personal information to external parties

In principle, we will not provide children's personal information to any third party, except in the following circumstances:

1.       Provide children's personal information to the guardian.

2.      Provide children's personal information to the external party(ies) to the extent necessary for our provision of products or services, in compliance with this Policy and the BMW Personal Information Protection Policy and with your express authorization and consent, or pursuant to the requirements of relevant laws, regulations and national standards. For details, please refer to the "How we entrust the processing of, share, transfer and publicly disclose your personal information" section in the BMW Personal Information Protection Policy.

III. How we protect children's personal information

A. Except as otherwise stipulated in the BMW Personal Information Protection Policy or otherwise informed by us through other channels, the personal information we collect and generate in the People's Republic of China (“China”) will be stored in the territory of China, and the children’s personal information involved will not be transferred to or accessed from jurisdictions outside China. If any overseas transfer is involved, we will separately seek your consent, comply with relevant laws and regulations, and ensure that the personal information of relevant children is adequately and equally protected as it is protected within the territory of China.

B. We will take all reasonably practicable measures to ensure that we follow the principles of lawfulness, legitimacy, necessity and good faith and only collect personal information necessary to achieve the purposes stated in this Policy. We will only retain children's personal information for the period necessary to achieve the purposes stated in this policy, unless there is a need to extend the retention period and your separate authorization or consent is obtained, or unless in accordance with laws, regulations or special regulatory requirements regarding the data retention period.

C. We attach great importance to the security of children's personal information and have taken strict security measures that comply with industry standards to protect the children's personal information you provide and prevent children's personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable measures to protect children's personal information. For example, we will use encryption technology to ensure the confidentiality of data; we will use trusted protection mechanisms to prevent data from malicious attacks; we will deploy access control mechanisms to ensure that only authorized personnel can access children's personal information; we will conduct personal information protection impact assessments in advance and record the processing status; and we will regularly hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting children's personal information.

D. The internet environment is not 100% secure. Please be reminded that as the guardian of children, you should correctly perform your guardianship duties and proactively take measures to protect the rights and interests of children's personal information.

E. If any security incident involving children's personal information occurs, we will immediately activate an emergency plan, take remedial measures, and notify you of the incident-related information in accordance with the requirements of laws and regulations by email, letter, telephone, push notification, etc.; When it is difficult to inform the personal information subjects one by one, we will make announcement of the relevant warning information in a reasonable and effective manner.

IV. Your rights

In accordance with relevant laws, regulations, standards of China, and common practices in other countries and regions, we ensure children's rights to their personal information. You can refer to the "Your rights" section in the BMW Personal Information Protection Policy to learn how you can exercise your rights for children's personal information such as right to access, review, copy, correct, delete, how to change the scope of authorized consent or withdraw consent, and how to de-register your account.

In particular, in addition to the circumstances stipulated in the BMW Personal Information Protection Policy, in the following circumstances, you, as the guardian of children, may also contact us to request the deletion of the corresponding children's information:

1.      We collect, store, use, transfer, or disclose children's personal information in violation of laws, administrative regulations, or mutual agreement between the parties;

2.      Collect, store, use, transfer, or disclose children’s information beyond the scope of purpose or the necessary period;

3.      The guardian withdraws his/her consent;

4.      The guardian terminates the use of the product or service by de-registration or other methods.

V. How this Policy is updated

This Policy is subject to change. We will not derogate from your rights under this Policy without your express consent. We will post any changes to this Policy on this page. We will archive history versions of this Policy for your review. For material changes to this Policy, we will also provide more prominent notices. For details, please refer to the " How this Policy is updated " section in the BMW Personal Information Protection Policy.

VI. How to contact us

If you have any questions, comments or suggestions about this Policy or the protection of children's personal information, please contact us through the following methods:

E-mail：servicecenter@bmw.com.cn

Hotline：400-800-6666

Data Management Department of BMW China Automotive Trading Ltd., registered address: 28/F, Building B, Jiacheng Plaza, No. 18 Xiaguangli, Dongsanhuan North Road, Chaoyang District, Beijing, China, zip code: 100027

We will process your request after verifying your identity (including children and guardian), and complete the examination and processing within fifteen working days.