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: March, 2026

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:

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

2. How we use cookies and other similar technologies

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

4. How we protect your personal information

5. Your rights

6. How we process personal information of children

7. How your personal information will be transferred globally

8. How this Policy will be updated

9. 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 Connected Drive services and functions and the corresponding processing of personal information from the vehicle are as follows (relevant functions, adaptable vehicle models and vehicle version may be adjusted from time to time. The features that you will actually use will vary depending on the model, vehicle system version and Connected Drive service you purchase. The availability of specific functions is subject to actual situation. Please refer to specific contents of in “My BMW APP - Mine - Privacy and Terms and Conditions - the Personal Information Protection Policy (Information Services)” for information on the handling of personal information from mobile phones involved in the functions and services.):

1. BMW ID

The feature allows login via the smartphone camera, the “Scan” feature in the My BMW APP, or scanning via WeChat the QR code displayed on the vehicle system. Some models also support logging in by entering BMW ID account information.

After logging in, settings such as system settings, driving preference settings, media preference settings, privacy protection preference settings, personal assistant preference settings, charging preference settings, and exterior lighting settings can be synchronized. This means that once you log into another vehicle, you can use your saved personal settings.

Additionally, users can invite other BMW ID holders to share some Connected Drive services through the invitation feature in the customer management section of the My BMW APP.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2. Vehicle and Connected Drive services functions

We will provide you with the following vehicle use and Connected Drive services and may process personal information generated on the vehicle system accordingly (this applies to the main driver’s screen, the passenger’s screen and the rear entertainment screen):

2.1 Data Privacy Menu

This feature allows the user to independently consent to the use of their sensitive personal information for each function and to choose whether to enable or close a particular function or data analytics service. Data analytics services are used to support vehicle remote service reminder, vehicle fault identification and troubleshooting, the continuous optimization of our products, services and mobility solutions, and for product development. Unless otherwise set forth, the term of consent for sensitive personal information is two years. Due to the limitations of the default settings of the Android native system, the information displayed on the vehicle side may not be consistent with this Policy (e.g. the text of agreed term of consent displayed on the vehicle side), in such case, please refer to this Policy.

Additionally, users can view and update their vehicle privacy settings via the My BMW APP and synchronize these settings to the vehicle.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.2 Weather

This feature displays basic weather parameters and weather forecasts for the next few days for your current location, your destination, your favourite location or any other location, and can broadcast weather forecasts.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.3 Radio

The radio broadcasts radio programs for users by receiving broadcast signals.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.4 Wi-Fi

Users are allowed to set their vehicle up as a Wi-Fi hotspot, connect devices to it, and share the internet connection with vehicle apps.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.5 Bluetooth

Users are able to pair the car with smartphones/handheld devices/wearable devices, etc. via Bluetooth.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.6 Telephony

The user pairs the vehicle with a smartphone via Bluetooth, enabling them to make and receive calls via the in-vehicle hands-free system. The user can also agree to access contacts and communication records in the phone’s contact list through the vehicle, to browse and use such information in vehicle. In addition, it allows users to receive and send text messages in vehicle. Received text messages can be displayed in the notification bar.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.7 Owner’s Handbook

This feature provides the user with instructions for the use of each function.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.8 Intelligent Personal Assistant (IPA)

Users can use IPA to realize the functions of speech and IPA recommendation. The speech function provides users with the ability to send commands or inputs to the vehicle through voice; IPA recommendation function, by understanding the user’s preference and situation, provides users with the infotainment services that they may be interested in; For vehicles with BMW Operating System X only, interior sensing functions include a variety of functions that can interact with the user, such as triggering interior sensor lighting and automatically selecting rearview mirrors for adjustment through driver or passenger activities.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.9 Intelligent Reminder

This feature provides the user with a reminder function that can remind the user to perform certain actions in a scenario or time period set by the user.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.10 Festive App

Users can receive holiday-related exciting videos pushed by BMW through this feature, and the content changes according to the holiday.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.11 DIY surprise

Users can customize the video through this feature to DIY surprise.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.12 Let’s celebrate

New car buyers can enjoy BMW’s new car celebration video through this feature.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.13 My Modes

This feature allows the user to set the theme of the car system independently.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.14 Doors and Windows

Users can save through this feature the positions where the user frequently opens the windows of the car and automatically open the windows when arriving at such location to facilitate the user to operate or focus on driving.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.15 Interior Camera

This feature enables the user to take photos or videos in the vehicle via the interior camera.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.16 My Highlights App

This feature enables the users to learn about the highlight feature content of each remote software upgrade.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.17 Navigation

This feature helps the user to view the route to their destination and provides guidance, including services such as search, guidance, map display/view, traffic, parking information, lane level navigation, estimated arrival time calculation, Daily Commute (Learning Navigation) (proactively provide accurate and dynamic destination and route suggestions through the user’s departure point, route, destination and other travel preferences and historical trip data), Search/POI and set, Sending destination to vehicle from mobile app, Pothole Warning, Real Time Traffic Information, Map Update, Smart Parking, Indoor Parking. Electric vehicles include additional services such as eRoute Charge Stop Proposal and Charging Cost Estimation.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.18 Charging

This feature provides the services of Charging Reservation, Predictive Thermal Management, BMW Branded Charging services, MALIBU (Management of Lifetime Budget - HV-Battery) and Location Based Charging Settings.

Additionally, users can access and view charging information, perform charging-related operations, and initiate battery preconditioning through the My BMW APP.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.19 System Settings-Time

This function is used to display the time.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.20 M-Laptimer NEXT

This function is used for track lap timing, including automatic calculation of lap times.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.21 BMW Messages

This feature enables messages and campaigns to be sent to the vehicle, helping users access information such as recalls, service information, contract information and product information.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.22 Remote Software Upgrade

This feature is available through BMW vehicle side or My BMW APP to ensure that the vehicle system is up-to-date and that you can use the latest intelligent digital features.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.23 Climate Control

Users can adjust and control the temperature of the vehicle via BMW vehicle or My BMW APP (including Passenger Mode).

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.24 Drive Recorder

This feature allows the user to record and view the information outside the vehicle recorded by vehicle’s external camera through vehicle side or My BMW APP.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.25 BMW Assistance

When the vehicle is involved in an accident or breaks down, the user can contact the BMW Accident Assistance Center by selecting “Accident Assistance Call (A-Call)” or “Roadside Assistance Call (B-Call)” in the “BMW Service Assistant” menu on the vehicle. Users can also select to contact “Customer Support Service (Hotline Call)” to inquire questions about the vehicle and Connected Drive service.

In order to realize the function of this service, the personal information involved and its handling are as follows:

2.26 Login Administration

This feature supports the binding of a BMW account with a third-party account, realizing the ability that when a BMW account is logged in, the bound third-party account can be logged in at the same time.

In order to realize the function of this service, the personal information involved and its handling are as follows:

3. Vehicle and Connected Drive service functions (third-party)

The service features such as smart internet music, audio and video, games, apps, and malls on the vehicle are provided by third-party service providers that we work with. When you choose to use these features, you need to agree to and follow the third party’s user agreement and/or privacy policy.

Meanwhile, in order to support your use of these service features in vehicle, the following scenarios may require the processing of personal information in your vehicle:

3.1 Intelligent Connected Music

This feature integrates music as well as audiobook streaming services to provide users with a high-quality driving audio experience.

In order to realize the function of this service, the personal information involved and its handling are as follows:

3.1.1 QQ Music

3.1.2 Ximalaya

3.1.3 NetEase Cloud Music

3.1.4 Kuwo Music

3.2 Audio and Video

This feature integrates audio and video services to provide users with a high-quality video entertainment experience.

In order to realize the function of this service, the personal information involved and its handling are as follows:

3.2.1 Tencent Video

3.2.2 iQiyi

3.3 Gaming

This feature provides a gaming platform that enables users to realize the gaming experience in the vehicle.

In order to realize the function of this service, the personal information involved and its handling are as follows:

3.4 Tencent Mini Program Platform

This feature provides users with commonly used applications.

In order to realize the function of this service, the personal information involved and its handling are as follows:

3.5 App Store

This function provides users with the download, installation and management of commonly used applications. If your model supports, you can also view, install, update, and uninstall apps on your vehicle via My BMW APP.

In order to realize the function of this service, the personal information involved and its handling are as follows:

3.6 ETC

The pre-installed electronic non-stop toll collection system in the vehicle. Users can use this feature to realize automatic payment.

In order to realize the function of this service, the personal information involved and its handling are as follows:

4. Mobile application services

The following cell phone application services are required to process data from the vehicle, and can only be used by logging in with a BMW ID.

4.1 Remote Services

This feature allows the user to display the vehicle status in My BMW APP and perform remote vehicle control for unlocking, locking, flashing lights, blowing the horn, immediate ventilation, scheduled ventilation or locating vehicle.

In order to realize the function of this service, the personal information involved and its handling are as follows:

4.2 Remote Cameras

This feature allows users to remotely view the interior of the vehicle or its surroundings via the My BMW App. The Remote View and Remote Theft Recorder functions are also included.

In order to realize the function of this service, the personal information involved and its handling are as follows:

4.3 My Trips

This feature enables the user to inquire about services related to historical trips via My BMW APP.

In order to realize the function of this service, the personal information involved and its handling are as follows:

4.4 Digital Key

This feature enables the user to install a digital key in a compatible smartphone and use it as a vehicle key, as well as to bind and log in to BMW ID, in addition, to invite others to own the digital key to their vehicle.

In order to realize the function of this service, the personal information involved and its handling are as follows:

5. Connected Drive Store

This feature is to provide users with the purchasing, renewing services and other information related to BMW Connected Drive services.

After you have ordered the relevant products or services, you may choose to make payment by using the payment service function provided by the third-party payment organization. The payment service function itself does not collect your personal information, but we need to share your order number and transaction amount information with these payment organizations in order for them to confirm your payment instructions and complete the payment.

In order to realize the function of this service, the personal information involved and its handling are as follows:

6. Driving settings

6.1 Driving

It provides users with an intelligent driving experience.

In order to realize the function of this service, the personal information involved and its handling are as follows:

6.2 Parking

It helps users park their vehicles more easily.

In order to realize the function of this service, the personal information involved and its handling are as follows:

6.3 Safety and warnings

It brings users round-the-clock security guarding.

In order to realize the function of this service, the personal information involved and its handling are as follows:

7. Smartphone-Vehicle connectivity services

7.1 Apple CarPlay

iPhone users can establish a connection between their phone and the vehicle and activate the Apple CarPlay function. This function can support access to various applications and functions on the phone, including making phone calls, performing navigation, playing music, voice wake-up, etc.

Apple may process location data, voice data informationin order to enable certain program features. When you choose to use the Apple CarPlay feature, you need to agree to and follow Apple’s user agreement and/or privacy policy.

The information in items 1-7 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.

8. Functions required for personal and property safety and required by laws, regulations and mandatory national standards

In order to protect your personal and property safety, and perform the requirements under laws, administrative regulations and mandatory national standards, we will provide you with the following features. Please understand that the processing of personal information for the provision of the following features does not require the consent of the individual.

8.1 Emergency Call (E-Call)

Emergency call system is activated automatically if an airbag is ejected or a seat belt tensioner is activated as a result of an accident. The emergency call system can also be activated manually using the SOS button in the vehicle in other scenarios, e.g. if you need to help another road user.

High Voltage warn (HV warn Call) is limited to electric and hybrid models only, and the vehicle will automatically activate the High Voltage Battery Abnormality Alarm* when an abnormality is detected by the sensors in the vehicle. (*Vehicles are required to have specific hardware configurations or reach the appropriate software integration level to use this service, and the relevant service may vary due to laws and regulations, information protection terms, or the opening of your relevant device permissions, etc.).

If you encounter a potential emergency while using the assisted driving system, the vehicle will notify and request you to take over control after entering assisted driving. If you no longer respond to the request to take over, the vehicle will initiate an Autonomous Driving Call(AD Call) for assistance.

In order to realize the function of this service, the personal information involved and its handling are as follows:

Legal Disclosures: In accordance with the requirements of on-board accident emergency call system(GB 45672-2025), the processing of location data and voice data for the purpose of providing emergency call services does not require separate user consent.

8.2 Real Time Monitoring

For electric vehicles, in order to ensure the safe operation of vehicles, this function helps to detect potential problems in advance by monitoring vehicle data in real time so that timely measures can be taken.

In order to realize the function of this service, the personal information involved and its handling are as follows:

Legal Disclosures: In accordance with the requirements of the MIIT Document No. 377 (2016) — Notice of the Ministry of Industry and Information Technology on Strengthening the Safety Supervision of the Promotion and Application of New Energy Vehicles — and Technical specifications of remote service and management system for electric vehicles (GB/T 32960), the processing of location data for the purpose of fulfilling relevant regulatory obligations does not require separate user consent.

8.3 Event Data Recorder

This feature is used to record event data for collisions triggered by front, rear, side, active pedestrian protection or rollover.

In order to realize the function of this service, the personal information involved and its handling are as follows:

Legal Disclosures: In accordance with the requirements of Technical specifications for safety of power-driven vehicles operating on roads (GB 7258-2017) and event data recorder system for road vehicles(GB 39732-2020), the processing of location data for the purpose of fulfilling relevant regulatory obligations does not require separate user consent. In accordance with the requirements of vehicle event data recorder system(GB 39732-2020), the personal information stored in the EDR on the vehicle head unit is not required to be deleted.

9. Basic prerequisite services for Connected Drive service functions:

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.

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

10.1 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:

10.2 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.

10.3 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”.

  1. 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.

  1. 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:

Basic data of vehicle (vehicle model, body color, configuration, production date, etc.)

Vehicle maintenance data (next service date, oil level, brake pad wear, etc.)

Vehicle status data (mileage, battery voltage, door and flap status, etc.)

  1. 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:

Backup and recovery of data processed in IT systems

Logging and monitoring of transactions to check the operation of IT systems

Detection and prevention of unauthorized access to personal information

IT systems security incident and problem management

  1. 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, specifically in Beijing, Shanghai, and Zhongwei City, Ningxia. The storage location is determined by our cloud service provider. In the event of any future changes, we will notify you promptly.

  1. Duration of storage

Unless otherwise required by applicable laws and regulations, we do not store your personal information permanently, but only for a period as long as necessary to fulfill the functions of the relevant service and as required by applicable laws and regulations (e.g. event data stored in the EDR system needs to be readable throughout the life cycle of the vehicle, and information relating to contractual transactions will be kept for a statutory period after the expiry of the contract or the completion of the transaction, and may be subject to inspection by the relevant regulatory authorities).

For your personal information stored in the vehicle, when the storage space is full, we may adopt the rule of overwriting the old content with new content, or stop continuing to store it.

For your personal information stored in the cloud, depending on the type and purpose of the information, we will apply different storage periods (if multiple storage periods apply to the same information, the longer period will apply), such as:

  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 Connected Drive contract.
  2. For other personal information collected in the Connected Drive Store, we will delete your information in 6 years after completing the order.
  3. For the personal information stored in logs we will delete within 30 days(personal information in logs of recording network operation status and security events will be stored for not less than six months);
  4. Deletion upon expiration of the storage period required by other laws or administrative regulations.

Your personal information will be deleted in a timely manner after the function is realized or the expiration of storage period. 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.

II. 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.

III. 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 and BMW authorized dealers

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.

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

  2. 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.

IV. How We Protect Your Personal Information

(I) 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.

(II) 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.

(III) 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.

(IV) 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.

V. 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

Information stored in the vehicle can generally be deleted at any time by the deletion options provided in the functions or by “resetting the vehicle data” (for ETC function, if you wish to completely delete the personal information it processes, you can log out the ETC first and then select “resetting the vehicle data”), and in some cases by removing or logging out of the BMW ID (in which case the data in the cloud is still retained) or by removing the device, unless such information is required to be stored by law or regulation or we have obtained your individual consent.

You may request the deletion of your personal information stored in the cloud 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

With respect to our collection and use of your personal information, you can change or withdraw your consent to the use of sensitive personal information or personal information for certain features through the “Data Privacy menu (DPM)” on your vehicle, or you can stop your consent to the use of relevant personal information by turning off certain features through the function switches under the Functions menu on your vehicle or mobile phone. You can also contact 400-800-6666 or email connecteddrive_CN@bmw.com to withdraw your consent. Please note, however, that each business function requires some basic personal information in order to be completed (see Section I of this Policy), so if you withdraw your consent to our collection and use of your personal information that is necessary for the business function, we will not be able to continue to provide you with the appropriate services.

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), Location data 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.

VI. 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.

VII. 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..

VIII. 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.

IX. 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.1, BMW Avenue Shenyang Economic & Technical Development Area Tiexi Shenyang 110143 Province Liaoning P.R.China

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