Personal Information Protection Policy

This Personal Information Protection Policy (this “Policy”) solely applies to BMW Connected Drive Service provided to end customers by NavInfo Co., Ltd. (“Operator”) entrusted by BMW (in terms of imported vehicles, BMW refers to BMW (China) Automobile Trading Co., Ltd.; and in terms of vehicles produced by BMW Brilliance Co., Ltd. BMW refers to BMW Brilliance Co., Ltd.) (“BMW”or “we”). NavInfo Co., Ltd. is the Operator and service provider of BMW Connected Drive.

Depending on the principal who has concluded a contract with you, or has provided services or products to you, or who has carried out marketing activities to you, BMW (China) Automotive Trading Co., Ltd. and BMW Brilliance Co., Ltd. will respectively determine the purpose and manner of processing your personal information and will protect your personal information in accordance with this Policy.

In case of any ambiguity or inconsistency between the Chinese version and other language versions (e.g. English) of this Policy and the language in the vehicle system, the Chinese version shall prevail.

Latest updated date: September, 2025

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

The Policy helps you understand the following information:

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

II. How we use cookies and other similar technologies

III. How we process (by entrusting others), share, transfer and publicly disclose your personal information

IV. How we protect your personal information

V. Your rights

VI. How we process personal information of children

VII. How your personal information will be transferred globally

VIII. How this Policy will be updated

IX. How to contact us

We recognize the importance of your personal information and treat it in accordance with the same high standards that you expect from our products. The confidentiality and integrity of your personal information is of particular concern to us. We are committed to 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 sufficiency, 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 signing this document, clicking “Read”, “Agree”, or any similar option, or by accepting the products or services we provide or submitting your personal information to us, you shall be deemed to have accepted this Policy. We will use and protect your personal information according to the relevant laws and regulations and this Policy. Please read this Policy carefully before signing authorization documents, checking or clicking “Read”, “Agree”, or other similar options, accepting our products or services, or filling in, confirming, authorizing the export or import of personal information, to ensure that you fully understand the contents and corresponding legal consequences. Additionally, if there are other users or passengers of your vehicle, or if the personal information you provide includes personal information of others, you need to ensure that you have obtained full consent from the individuals concerned.

I. Our Business Functions and How We Collect and Use Your Personal Information

Personal information means any information relating to an identified or identifiable natural person recorded in electronic or other forms, including but not limited to name, date of birth, identification number, personal biometric information, address and telephone number. However, anonymized information is not included.

Sensitive personal information means the personal information that may cause harm to personal or property security, or is very likely to result in damage to an individual’s dignity, once it is leaked, unlawfully abused. In general, biometric identification, religious belief, specific identity, medical and health care, financial account, trace and other information, as well as personal information of minors under the age of 14 etc. are regarded as sensitive personal information. In this Policy, the terms and articles concerning sensitive personal information and the parts for your special attention will be marked in bold. In scenarios where sensitive personal information is actually collected, we will remind you again and obtain your consent by means of enhanced notification or instant reminder (e.g., pop-up window reminder), etc., or require you to click on a separate confirmation or sign a Separate Consent Letter.

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

(I) Conclude terms and conditions of BMW Connected Drive service

In order to ensure that you can take full advantage of the BMW Connected Drive service and to fully utilize the features of BMW Connected Drive, you will need to register for a BMW account (BMW ID), after which you will receive an online account with which you will be able to log in to enable you to access to all BMW portals and online business platforms at the same time. In order to conclude the BMW Connected Drive service terms and conditions with you, we will collect the information described below.

1.1 BMW ID Register information

1.2 Mandatory basic material and identity information:

(a) For enterprise customers, please provide the name of the enterprise; the name, ID number or other valid ID number, phone number of the authorized person; and VIN;

(b) For individual customers, please provide the name of owner or the person legally authorized by the vehicle owner to sign and perform this agreement, ID number or other valid ID number, phone number and VIN;

1.3 Emergency contact information ：name, relationship with the vehicle owner and mobile number (such information will be processed only if voluntarily provided by an individual customer or authorized person of an enterprise. For example, in the event of an emergency, a Call Center staff will contact you and the emergency contact person set by you to determine your needs, such as requesting medical assistance, police and fire alarms, or obtaining a route to the nearest hospital);

The information listed in item 1.1 above is necessary for us to conclude the BMW Connected Drive service terms and conditions with you and to provide you with basic business functions. If you do not provide the information in item 1.1 above, you will not be able to conclude the BMW Connected Drive service terms and conditions and obtain BMW ID or log in with BMW ID to fully use and enjoy various services provided by BMW China.

The information listed in item 1.2 is necessary for us to conclude the BMW Connected Drive service terms and conditions with you and to complete the registration of necessary contact information and provide you with basic business functions. If you do not provide the above necessary information, we may not be able to conclude the BMW Connected Drive service terms and conditions with you and to complete the real-name registration and provide you with basic business functions.

The information listed in item 1.3 above is not necessary for the conclusion of BMW Connected Drive service terms and conditions but is of great significance for improving service quality and developing new products or services. It is at your discretion to provide us with or allow us to collect the information listed in this item. We will not force you to provide such information. Your refusal to provide such information will not affect your right to enter into a BMW Connected Drive service terms and conditions and your use of the basic products or service functions under the contract.

When you are using our services, you agree that we will continuously use the above-said information you have provided. We will cease using and delete the above-said information (including personal information generated during your use of the customer account) in a timely manner in the event that you withdraw your consent, request the deletion of your personal information in accordance with this Policy, or if you terminate the BMW Connected Drive service or cancel your account. Nevertheless, in accordance with the applicable legal or regulatory provisions, we will still be obliged to retain your personal information for statutory period (e.g. information relating to the use of the BMW Connected Drive service and financial transactions will be retained for a statutory period after the use or transaction has been completed and may be subject to inspection by the relevant regulatory authority).

(II) Fulfill obligations under the BMW Connected Drive service terms and conditions

In order to fulfill the BMW Connected Drive service terms and conditions we sign with you, we will provide you with BMW Connected Drive service.Details of BMW ConnectedDrive Services (for reference only, relevant functions and adaptable vehicle models may be adjusted from time to time and should be subject to as-available basis). Vehicles will be equipped with various ConnectedDrive service packages or software subscribed on demand depending on the its production year, specification and model.

These ConnectedDrive service packages include:

(1) Basic ConnectedDrive Service Package (ex-factory); (2) Standard ConnectedDrive Service Package (ex-factory); (3) Premium ConnectedDrive Service Package (ex-factory); (4) Professional ConnectedDrive Service Package I/II/III (ex-factory); (5) Exclusive ConnectedDrive Service Package (ex-factory); (6) Standard ConnectedDrive Service Package (post-factory); (7) Standard ConnectedDrive Package for ID7 (post-factory); (8) Premium ConnectedDrive Package (post-factory); (9) Exclusive ConnectedDrive Package (post-factory); (10) Exclusive ConnectedDrive Package for ID7 (post-factory); (11) Digital standard equipment for OS9; and (12) BMW Digital Premium for OS9.

(1) Basic ConnectedDrive Service Package (ex-factory) includes the following services: (a) intelligent emergency rescue service; (b) teleservices, (p) E-drive service, and (t) Login Administration; and (x) BMW Digital Key, etc.

(2) Standard ConnectedDrive Service Package (ex-factory) includes the following services: (c) information online - weather information; (f) remote service; and (l) online speech processing etc.

(3) Premium ConnectedDrive Service Package (ex-factory) includes the following services: (c) information online – weather information; (f) remote service; (j) real-time traffic information; (l) online speech processing; and (m) map update; etc.

(4) Professional ConnectedDrive Service Package (ex-factory) consists of Package I/II/III depending on the production year, specification and model, and includes the following services: (c) information online - weather information; (d) remote software update; (e) BMW intelligent personal assistant; (f) BMW remote service; (g) connected music; (m) map update; and (n) Tencent mini program, (u) remote control parking, (x) BMW Digital Key or (y) BMW Digital Key PLUS; and (z) Festive App; etc.

(5) Exclusive ConnectedDrive Service Package (ex-factory) includes the following services: (c)® information onlin–e - weather information; (d) remote software update; ®(e) BMW intelligent personal assistant; (f) BMW remote service; (g) connected music; (i) connected navigation service; (j) Real-time traffic information; (k) connected parking; (m) map update; (n) Tencent mini program; a®nd (r) intelligent cockpit experience; (u) remote control parking; (x) BMW Digital Key or (y) BMW Digital Key PLUS, and (z) Festive App; etc.

(6) Standard ConnectedDrive Service Package (post-factory) includes the following services: (c) information online - weather information; (f) BMW remote service; and (l) online speech processing, etc.

(7) Standard Connected Drive Package for ID7 (post-factory) includes the following services: (c) information online - weather information; (e) BMW intelligent personal assistant; (f) BMW remote service; (l) online speech processing; (n) Tencent mini program; (r) intelligent cockpit experience; and (s) indoor parking map, etc.

(8) Premium Connected Drive Package (post-factory) includes the following services: (c) information online – weather information; (f) BMW remote service; (j) real-time traffic information; and (l) online speech processing, etc.

(9) Exclusive Connected Drive Package (post-factory) includes the following services: (c) information online – weather information; (f) BMW remote service; (g) connected music; (j) real-time traffic information; and (l) online speech processing, etc.

(10) Exclusive Connected Drive Package for ID7 (post-factory) includes the following services: (c) information online – weather information; (e) BMW intelligent personal assistant; (f) BMW remote service; (g) connected music; (j) real-time traffic information; (l) online speech processing; (n) Tencent mini program; (r) intelligent cockpit experience; and (s) indoor parking map, etc.

(11) Digital Standard Equipment for OS9 includes following services: (a) intelligent emergency rescue service; (b) teleservices; (c) information online - weather information; (d) remote software update; (e) BMW intelligent personal assistant; (f) remote service; (g) connected music; (i) connected navigation service, (u) remote control parking, (x) BMW Digital Key or (y) BMW Digital Key PLUS; and (z) Festive App; etc.

(12) BMW Digital Premium for OS9 includes following services: (k) connected parking; (v) video streaming; (w) app store, etc.

2. You can log in to your BMW account on the vehicle side to have a better use of ConnectedDrive services and synchronize your personalized settings.

Login scenarios: (1) Scanning the QR code on the vehicle side via your cell phone, (only for OS9 and ID7 of November 2020 and above); (2) Entering your account information voluntarily (only for ID7/ID8 of July 2023 and before). For providing this service, we will collect the following personal information:

2.1 BMW ID (BMW account number) login information;

2.2 Vehicle Identification Number (VIN)

3. In order to provide the above services, we, BMW and BMW service providers may process the following potential personal information generated during the use of motor vehicles or related to motor vehicles, including:

3.1 Personal Information :

1) Personal identification information: BMW ID (BMW account number) login information, driver's license;

2) Basic personal information: name, address book;

3) Vehicle identification: Vehicle Identification Number (VIN), license plate number;

4) In-vehicle infotainment system and operation records:

a. Image/video data: When the remote in-car camera function or the remote anti-theft alarm system is triggered, the interior image/video will be captured by the in-car camera and transmitted to the My BMW App via the BMW server for you to view. The images/videos stored in the BMW server will be automatically deleted within 60 minutes.

b. Voice data: When you use the BMW Intelligent Personal Assistant or Connected Apps, your voice will be collected by the in-car microphone and transmitted to the BMW back-end program to recognize your voice commands in order to fulfill your requests.

5) Vehicle location data:

a. Location data: Vehicle position information or vehicle trajectory information that is required to be used when using navigation functions or functions provided based on geolocation information.

6) Third Party Application Account Information: Nickname

3.2 Basic vehicle information: driving direction, service data or accidents related to your vehicle, relevant information of BMW connected drive service calls from your vehicle called by anyone or your own account, your call date/time/duration as well as the written record of any BMW connected drive service response specialist in the call.

3.3 Vehicle data related to vehicle performance, use, operation and condition: in car temperature, air conditioning and heating setting, navigation info (route guidance status, route guidance time and distance, destination location), vehicle info (road type, exterior weather, temperature and humidity, air quality), application usage, seat occupation and seatbelt usage, wiper gear situation, window and light status, customer’s feedback of suggestion, call status, vehicle and driving status, ignition time, flameout time, operation mode, vehicle speed, gear, acceleration information, braking information, motor status, engine status, speed, fuel consumption, energy consumption, odometer reading, electric mileage, gasoline surplus, battery voltage, battery current, battery temperature, battery use management information, battery charging history Electrical system information and charging management, tire pressure and tire temperature information, coolant temperature, software version information, infotainment system information, camera images, and other data used to identify problems and analyze vehicle performance.

3.4 Safety analysis data: data related to your vehicle's accidents or similar situations of a sign of danger accidents (airbag spreading, sensor data in case of serious collision, vehicle alarm signal), data related to remote after-sales service, data reports confirming that your vehicle is online with the current software version and some on-board information system data, vehicle network connection information, data related to any problem that will seriously affect your vehicle's operation, data on any safety critical issues, data on each software and firmware update, and other data used to help identify issues and analyze vehicle safety.

3.5 Service record: the data recorded by the vehicle service, including the instructions (audio instructions) and records that you or other passengers in your vehicle request to obtain BMW connected drive services, and the requests, orders and payment information and records that you or other passengers in your vehicle send to the response center.

3.6 Charging information: the information of the charging pile used by the vehicle, as well as the vehicle charging state, starting and ending time of charging, charging current, charging voltage, and SOC records.

Information you may provide when providing feedback or contacting or communicating with us by other means. For example, if you choose to give feedback through My BMW app, some of your information will be automatically sent with your feedback. Such information may include the unique identification code, province and city information, equipment operating system and version information, equipment manufacturer and model, and browsing information that you created when using the app for the first time.

The information above is not necessary to conclude the terms and conditions of the BMW Connected Drive service, but such information is necessary to provide the specific service features under the corresponding BMW Connected Drive service. Therefore, if we do not obtain your consent to the use of the relevant personal information, we will not be able to provide you with the corresponding specific service features or may render the relevant service features not functioning properly or completely.

4. During the free service period, in order to settle the communication costs incurred by the vehicle IoT SIM card and to carry out usage anomaly detection and fraud prevention, we will collect and process the consumption information and related information of the vehicle IoT SIM card connected to the Internet, including vehicle identification number (VIN), IoT SIM card number.

5. Description of permissions and access to third-party tools

5.1 Vehicle system permission

In order to use the BMW Connected Drive service functions above, we may request the following vehicle system permissions related to personal information from you:

5.2 Mobile system permission

In addition, we will apply for the mobile system permissions related to personal information from you through My BMW APP. You can refer to the content related to system permissions in “My BMW APP--Mine--Privacy and Terms and Conditions--Personal Information Protection Policy (Information Service)” to learn about the specific mobile system permissions to be requested from you.

5.3 Third-party software service toolkits

In order to ensure the realization and stable operation of BMW’s Connected Drive related functions, we may access the software services toolkits provided by a third party to achieve relevant purposes, including but not limited to software development kits (SDKs), Android application programming kits (APKs), application programming interfaces (APIs). The software services toolkits vary for different vehicle versions, generally including map navigation and push notification message etc. We will strictly monitor the security of our partners to ensure data security. You can view the third-party data use and protection rules through the following table.

(III) Ensuring service quality and developing new services

Beyond the provision of services, the information and the service utilization records under Section I, Subsection (I)-(II) will also be processed to ensure the quality of the BMW Connected Drive services and to develop new services. The use of the above information is related to our commitment to meet our customers’ high standards for existing services and expectations for new services in the future.

(IV) Fulfillment of the service and administration processes

In order to continuously optimize the customer experience, we may compile analyses and reports based on the information under Section I, Subsection (I)-(II). These analyses will primarily be used to introduce appropriate measures to improve the services process.

Also, personal information and vehicle-specific data involved under Section I, Subsection (I)-(II)) will be processed to fulfill the service processes (e.g. repair, warranty, goodwill) by BMW, BMW affiliated companies and BMW authorized dealers. This kind of processing is to offer our customers the best possible service process.

(V) Customer service

We use your personal information (e.g. name, e-mail and telephone number) in order to contact you for handling contractual matters related to you (e.g. to activate the BMW Connected Drive service) or at your request (e.g. in the case of an inquiry or a complaint submitted by you to BMW Customer Service). We will contact you on the basis of the contact details you have expressly provided (e.g. written communication, telephone call, SMS, e-mail, etc.) and will not ask for your consent separately when handling the aforesaid contractual matters and your request.

(VI) Customer activities, marketing promotions and market research

You understand and agree that during your use of our services, we may use your personal information for the purpose of customer activities, marketing promotions and/or market research. For example, we will use your personal information such as name, email and telephone number to conduct market research such as customer group analysis to optimize and improve the services, or to provide you with personalized product offers based on your interests; at the same time, the above information will be used by us to carry out customer care and marketing activities, including pushing new car launches, product promotions, festive wishes and other promotional information to you. If you do not wish to receive this type of notification, you may unsubscribe by following the instructions in the relevant information or by contacting us. In addition, in order to achieve the aforementioned purposes, we will also obtain your personal information from our dealers based on your individual consent. We will confirm the legitimacy of the source of such personal information and the scope of individual consent, and if it exceeds the scope your individual consent, we will obtain your consent again. Please refer to the content of the individual consent statement in specific scenarios for details. You have the right to withdraw such consent at any time according to your personal wishes.

In addition, when you participate in the online or offline activities we organize from time to time, we may also need to collect and use your personal information. The types of personal information collected and the content of the activities will be separately explained to you at the time of collection, and we will obtain your consent in the form of the “BMW Personal Information Collection and Use Instructions”. In such cases, these BMW Personal Information Collection and Use Instructions will prompt you to read this Policy, and your participation in online or offline activities will be deemed to constitute your reading of and consent to this Policy. We will handle your personal information strictly in accordance with this Policy.

(VII) Fulfillment of legal obligations

We are required to comply with a range of other statutory obligations. In order to fulfill the relevant statutory obligations, we use your information to the extent required by laws and regulatory requirements, including:

1. Functions required by laws, regulations and mandatory national standards

Please refer to Section I, Subsection (II), Item 8 of this Policy, “Functions required for personal and property safety and required by laws, regulations and mandatory national standards”.

2. Fulfillment of recall obligations or technical activities involving your vehicle

We may need to use your information in order to fulfill our recall obligations involving your vehicle or to conduct technical activities to ensure the proper operation and safe performance of your vehicle.

3. Disclosure of maintenance information in accordance with relevant regulatory requirements

We may need to disclose maintenance information in accordance with relevant regulatory requirements. In order to protect the privacy of customers, we will use technical information that relates only to the vehicle and not directly to the user, where possible and to the extent permitted by regulation, including:

4. Ensuring secure operation of IT systems

We may need to use your information to ensure the secure operation of IT systems. In the following cases, we need to particularly ensure IT running smoothly:

5. Compliance management

We may also use the relevant information for compliance management purposes, such as checking whether the dealer has fulfilled its statutory obligation to give you adequate advice before you enter into a contract, so as to better protect your legitimate rights and interests.

(VIII) Exceptions of obtaining consent to collect and use personal information

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

1. where it is necessary for the conclusion or performance of a contract to which you are a party;

2. where it is necessary for us to perform statutory duties or statutory obligations;

3. where it is necessary for coping with public health emergencies or for the protection of the life, health, and property safety of you or others;

4. where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of your personal information is within a reasonable scope;

5. where the personal information disclosed by yourself or other legally disclosed personal information is processed within a reasonable scope in accordance with the provisions of the laws; and

6. other circumstances provided by laws and administrative regulations.

Please be aware that, in accordance with applicable laws, personal information is no longer personal information if we take technical measures to process it in such a way that it cannot be re-identified to a specific individual and cannot be recovered. We may use such information for research, statistical and analytical purposes to improve the content of BMW products, to support business decisions and to improve our products and services, and may share this statistical information with the public or third parties in order to demonstrate overall trends in the use of our products and/or services, and such use need not be communicated to you separately and need not to obtain your consent.

(IX) How we store your personal information

1. Where it is stored

Your personal information may be stored in the vehicle or (and) in the cloud. For your personal information stored in the cloud, they are stored within China, the specific city will depend on our service providers.

2. Duration of storage

We do not store your personal information permanently. Unless specified in the purposes described below, we store your personal information only for as long as is necessary to fulfill the relevant function, and your personal information will be deleted promptly after the function is realized. If the information is used for multiple purposes, for example:

1) Personal information collected for the purpose of improving the quality of our products and services will be deleted within 3 years after the expiration of the ConnectedDrive contract

2) For other personal information collected in the ConnectedDrive Mall, we will delete your information in 6 years after completing the order.

3) For the personal information stored in logs we will delere within 30 days. (Recorded in remote control commands or logs of network operation status and security events will be stored for not less than six months);

4) Deletion upon expiration of the retention period required by other laws or administrative regulations.

If deletion is not possible due to technical reasons in the above scenarios, we will store your personal information in a form that cannot be directly or indirectly traced back to individuals.

Your personal information will be stored in China, the specific city will depend on our service providers.

6. How We Use Cookies and Other Similar Technologies

BMW Connected Drive service will not use cookies or similar technologies. For how we use these on the CD-store website, please refer to our Cookie policy.

7. How We Process (by Entrusting Others), Share, Transfer and Publicly Disclose Your Personal Information (I) Entrusted processing

In order to provide you with specialized, high-quality products and services, certain specific modules or functions of the BMW Connected Drive service are actually provided by our commissioned BMW China affiliates (e.g. BMW (China) Service Co., Ltd.), BMW authorized dealers and/or external suppliers. In order to utilize the Intelligent Emergency Assistance Service, Remote After-sales Service, Remote Software Upgrade, Remote Vehicle Control Service, Online Speech, BMW Intelligent Personal Assistant Service, Connected Navigation Service, Map Upgrade, Connected Parking Service, E-Drive Services, Online Information, we may provide or transmit the collected information to selected third parties.

In these cases, we may entrust the processing of your personal information to these affiliates, BMW authorized dealers and/or external suppliers in order to provide you with relevant services and support. In the case of entrusted processing, we will determine the purposes and manner for which your personal information within the scope of this Policy, and the entrusted party will process your personal information in accordance with our instructions. If you have questions about the processing of personal information by such modules or functions, or seek to make a complaint, you may contact us directly via the information in Section IX.

In the case of entrusted processing, for the mentioned companies, organizations and individuals who accept our entrustment to assist us in the processing of personal information, we will, in accordance with the scope of your authorization to us, make agreement with the entrusted party on the purpose, duration and processing method of the entrusted processing, the types of personal information, protection measures, and the rights and obligations between us and the entrusted party and supervise their activities in the processing. We will ensure that the entrusted party handles your personal information in accordance with its agreement with us, and will not handle your personal information beyond the agreed purpose and method of processing. We will enter into a strict confidentiality agreement with the entrusted party requiring them to process personal information in accordance with our requirements, this Policy, and any other relevant confidentiality and security measures.

(II) Sharing

1. Sharing with BMW affiliates, BMW authorized dealers and service providers

Other than entrusted processing, we may share your personal information with our affiliates, BMW authorized dealers and service providers from time to time. Unlike entrusted processing, in the case of sharing your personal information, BMW China’s affiliates, BMW authorized dealers or service providers, as the recipients, will independently decide the purpose and manner of processing your personal information, and therefore in the case of sharing, we will inform you of the specifics of such sharing in detail and obtain your sperate consent.

(1) Sharing with BMW affiliated companies. For the purposes specified in this Policy, your personal information may be shared with BMW Automotive Finance (China) Co., Ltd. when you agree to use the services provided by BMW Automotive Finance (China) Co., Ltd.

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

(2) Sharing with BMW authorized dealers. For the purposes specified in this Policy, we may share your personal information with our authorized dealers, in order to offer better client services and user experience, subject to your individual consent or separate consent.

(3) Sharing with service providers. We may also share your personal information with service providers in order to fulfil certain service features, subject to your sperate consent.

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 and subject to the purposes specified in this Policy. Before sharing your personal information, we will remind you again by means of pop-ups and obtain your consent, or request you to otherwise click confirm or sign a Separate Consent Letter.

(III) Transferring

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

1. Transferring information with explicit consent: we will transfer your personal information to other parties after obtaining your explicit consent.

2. If your personal information has to be transferred to a successor in a merger, acquisition or bankruptcy liquidation, we will inform you of relevant situation and require the new company or organization that will hold your personal information to continue to observe this Policy. Otherwise, we will require the new company or organization to re-obtain your consent before transferring your personal information.

(IV) Public disclosure

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

1. Necessary for our business and after obtaining your separate consent.

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

(V) Exceptions of obtaining prior individual consent to share, transfer or disclose personal information

In accordance with relevant laws and regulations and national standards, in the following exceptions, we may share, transfer or disclose your personal information without obtaining your prior individual consent:

1. where it is necessary for the conclusion or performance of a contract to which you are a party;

2. where it is necessary for us to perform statutory duties or statutory obligations;

3. where it is necessary for coping with public health emergencies or for the protection of the life, health, and property safety of you or others;

4. where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of your personal information is within a reasonable scope;

5. where the personal information disclosed by yourself or other legally disclosed personal information is processed within a reasonable scope in accordance with the laws; and

6. other circumstances provided by laws and administrative regulations.

8 How We Protect Your Personal Information

1. We have protect your personal information based on safety protection measures in line with industry standards from unauthorized access, public disclosure, use, modification and loss. We will take all reasonable actions to protect your personal information. For example, we will use encryption technique to ensure data confidentiality; we will use reliable protection mechanism to prevent data being hostile attack; we will deploy access control mechanism to ensure only authorized person accessing personal information; and we will provide safety and privacy protection training courses to strength employees’ awareness of the importance of protecting personal information.

2. We will take all reasonable and feasible measures to ensure that we only collect personal information necessary for the purpose of this Policy. We will only retain your personal information for a limited period necessary for realizing the purposes specified in this Policy, unless it is necessary to extend the retention period with your separate consent or in accordance with laws and regulations or special regulatory requirements relating to data retention periods.

3. The Internet is not an absolutely safe environment. Although we will do our best to protect your person information, we cannot guarantee or warrant its absolute security. Therefore, you should also take active measures to ensure the security of your personal information, such as changing your account password regularly and not disclosing your account password information to others.

4. In case of any incident in respect of personal information security, we will inform you in time according to laws and regulations, including basic information about the security incident and the potential 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.

9 Your Rights

You are entitled to the following rights over your own personal information according to applicable Chinese laws, regulations and standards, and common practices in other countries and regions.

(I) Accessing, viewing and coping your personal information

You have the right to access your own personal information, unless there are exceptions in laws and regulations. If you want to exercise your right of data access, you can log in to My BMW APP to access your personal information; If you are unable to access your personal information from the above link, you may contact BMW client service 400-800-6666 for relative information. We will respond to your request within no more than 15 days after verification.

You have the right to copy your personal information, or obtain a copy of your information. You may contact us by emailing connecteddrive_CN@bmw.com. We will respond to your request within no more than 15 days after verification.

We may also transmit copies of your personal information directly to a third party designated by you at your request, provided that it is technically feasible, for example, that the data interfaces are matched and that the conditions set by the national cyberspace administration authorities are met.

(II) 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 can contact 400-800-6666 for specific process. We will respond to your request within 15 days after verification.

(III) 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 the purposes for processing your personal information have been fulfilled, cannot be fulfilled or are no longer necessary (e.g., you no longer use our products or services, or you have cancelled your account);

5. When you have withdrawn your consent to our processing of your personal information.

If you want to delete your personal information, you can contact 400-800-6666 or email to connecteddrive_CN@bmw.com or request to cancel your account via My BMW APP.

We will reply to your request within 15 days after the verification is passed. If you request to delete sensitive personal information, we will reply to your request within 10 working days after the verification is passed.

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.

When you delete information from our services, because of applicable legal and security technical limitations, we may not immediately delete the corresponding information from the backup system, but we will securely store your personal information and not perform any further processing on it until the backup can be erased or anonymization is achieved. In order to adequately protect your personal rights and interests, we may retain the necessary information in the backup system while keeping such information in a state where it cannot be retrieved or accessed by technical means.

(IV) Changing the scope of your individual consent or revoking your consent

In terms of the collection and use of additionally collected personal information, you may grant or revoke your authorization and consent at any time.You can contact 400-800-6666 or email connecteddrive_CN@bmw.com. Please note, however, each business function cannot be realized without some basic personal information (see Part I of this Personal Information Protection Policy). Therefore, if you withdraw your consent to our collection and use of your personal information that is essential for the business function, we will be unable to continue providing the corresponding service to you.

After you have withdrawn your consent, we will not process the corresponding personal information any more. But your decision to withdraw your consent does not affect the previous processing of personal information based on your consent.

If you do not want to receive the commercial advertisements and other marking promotional information, you can request to stop receiving such information at any time by contacting 400-800-6666 or sending an email to connecteddrive_CN@bmw.com

(V) Deregister user accounts

You may cancel at any time the account you registered for by emailing connecteddrive_CN@bmw.com

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

(VI) Automatic decision-making of the information system

We will not make decisions solely based on non-human automatic decision-making mechanisms, including information systems, algorithms, etc.

(VII) The use of algorithmic recommendations

The intelligent personal assistant service uses computer algorithms to recommend features or services that may be of interest to you based on your authorized personal information and driving data, so that you can enjoy a smarter and more convenient driving experience.

The intelligent personal assistant service uses machine learning algorithms to automatically calculate and analyze your click history (click to accept/reject recommendations, application status), vehicle location information and other vehicle data related to vehicle performance, use, operation and condition to recommend content that may be of interest to you.

If you do not want to see the content recommended for you by intelligent personal assistant, you can disable the recommendation service by going to the “Intelligent Personal Assistant - Smart Suggestion” (or “Personal Assistant-Suggestions”) settings page and turning off the function switch. If you have any questions about this, you can contact us through the contact information provided in this document.

(VIII) Responding to your requests

In order to protect the realization of your rights to personal information, you can make a request for your rights to your personal information according to the specific methods listed above, or you can contact BMW’s Personal Information Protection Officer.The contact number is 400-800-6666.

We will reply within 15 days. If you are dissatisfied with our reply, you may lodge a complaint through the following means: 400-800-6666.

For the sake of security, you may be required to file written requests or prove your identity in other ways. We may request authentication of your identity before responding to your requests. 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 the performance by us of obligations specified in laws and regulations;

2. Where requests are in direct relation to the national security or national defence 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 the personal information subject is subjectively malicious or abusing his/her rights;

6. Where personal information collecting and processing is 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 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.

10 How We Deal with Children’s Personal Information

Our products and services are designed primarily for adults. We will not create BMW ID for children and will not collect and use children’ personal information. Where it is necessary to collect or use personal information of a child, we will inform the child’s guardian in advance and obtain sperate consent of the child’s guardian.

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

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

11 How Your Personal Information Will Be Transferred Globally

In principle, the personal information we collect and generate in the People’s Republic of China will be stored in the People’s Republic of China. However, in order to fulfill the contract with you or fulfill legal obligations such as recall, your personal information may be transferred to or accessed from foreign jurisdictions outside the countries/regions where you use products or services. For example, for the purpose of product quality analysis or technical support, our technology and operation and maintenance team in Germany may remotely access your vehicle identification number (VIN).

Prior to cross-border transfer of your personal information, we will inform you again by giving an enhanced notification or an instant alert (such as a pop-up window) to obtain your consent, or will ask you to separately click confirm or sign a Statement on the Personal Information Cross-border Transfer.

Although such jurisdictions may have different data protection laws, we will ensure that your personal information is adequately and equally protected as within the People’s Republic of China by signing cross-border data transmission agreements with overseas personal information recipients. For example, before cross-border data transfer, we will carry out personal information security impact assessment, implement security measures such as data de identification, require the data recipients by signing an agreement or other means to use personal information in strict accordance with the purpose agreed in the agreement, and to implement data security protection obligations by adopting technical and management measures, etc..

12 How this Policy Will Be Updated

Our Personal Information Protection Policy may be changed. We will not reduce your rights under this Policy without your explicit consent. We will publish any changes to this Policy on this page and will make the historical versions of this Policy available to you for your 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 Policy).

For the purpose of this Policy, major changes 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;

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

13 How to Contact Us

If you have any concerns or comments on this Policy, or if you have any questions about the way we use your personal information please contact us through the following means:

Email: connecteddrive_CN@bmw.com

Hotline: 400-800-6666

BMW (China) Automobile Trading Co., Ltd. registered address: 28 / F, block B, Jiacheng Plaza, No. 18, Xiaguangli, Dongsanhuan North Road, Chaoyang District, Beijing 100027, China

BMW Brilliance Automotive Ltd. registered address: No. 14, Shanzuizi Road, Dadong District, Shenyang, Liaoning Province 110143, China

We will reply to you within the time limit required by laws and regulations, which is normally no more than 15 days.