Personal Information Protection Policy

 

This Personal Information Protection Policy solely applies to MINI Connected Drive Service. NavInfo Co., Ltd.("operator" or "we") is the operator and service provider of MINI Connected Drive.

MINI is the intellectual property owner and solution designer for the MINI Connected Drive Service. "MINI" refers to MINI (China) Automobile Trading Co., Ltd. in terms of imported vehicles; and refers to MINI Brilliance Co., Ltd. in terms of vehicles produced by MINI Brilliance Co., Ltd.

Latest updated date: 3/2025

If you have any questions or comments, please contact us at:

Email: ConnectedDrive@bmw.com.cn

Phone: 400-800-6699

 

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

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

 

We treat your privacy in accordance with the same high standards that you expect from our products and services. 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

 

Please carefully read this Personal Information Protection Policy before clicking “agree” and ensure a full understanding of the meaning and corresponding legal consequences of this Personal Information Protection Policy. Clicking “agree” is deemed as the acceptance of this Personal Information Protection Policy. We will use and protect your personal information according to the relevant laws and regulations and this Personal Information Protection Policy.

 

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

Personal information means any information saved in electronic or other forms that can be used independently or together with other information to identify a natural person or reflect the activities of a natural person, including but not limited to name, date of birth, identification number, personal biometric information, address and telephone number.

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 personal reputation or physical or mental health or give rise to discriminatory treatment, once it is leaked, unlawfully provided or 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 Personal Information Protection 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 authorization by means of enhanced notification and alerts (e.g., pop-up reminders), or require you to confirmation or sign a Separate Consent Letter.

 

We collect and process your personal information solely for the purposes specified as below to realize MINI Connected Drive Service.

We will seek your consent if we use your information for purposes other than those stated in this Personal Information Protection Policy. We will also seek your consent if we use your information which is collected for specific purposes for other purposes.

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 Connected Drive contract

2) For other personal information collected in the Connected Drive Mall, 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. (Recorded in remote control commands or in 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 mainland, and the specific city will depend on our service providers.

1. Conclude terms and conditions of MINI Connected Driving service
1) In order to take full advantage of the MINI Connected Mobility service and to fully utilize the functions of MINI Connected Mobility, you will need to register for a MINI ID, after which you will receive an online account with which you will be able to log in to enable you to use all of BMW China's portals and online business platforms at the same time. In order to conclude the terms and conditions of the MINI Connected service with you and to complete the real-name registration, we will collect the following information.

(1) MINI ID Register information

(2) Mandatory information:

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

b) For individual customers, please provide the name of vehicle owner, gender, phone number ,ID number or other valid ID number, and VIN;

(3) Emergency contact information ：name, relationship with owner and mobile number（ will be processed only when the individuals or authorized persons provide voluntarily ）

 

If you do not provide the information in item (1) above, you will not be able to obtain MINI ID or log in with MINI ID to enjoy various services provided by BMW China.

At the same time, if you have already registered this online account on other MINI platforms, you can also log inby using same account. .

 

The information in item (2) above is necessary for us to conclude the MINI Connected Terms and Conditions of Service with you and to complete the registration of your real name and provide you with basic business functions. If you do not provide the above required information, we will not be able to conclude the terms and conditions of the MINI Connected Mobility service, complete the real name registration or provide the relevant basic business services with you.

The information listed in (3) above is not mandatory for the conclusion of the MINI Connected Terms and Conditions of Service/completion of real name registration, but is important to enhance the customer experience. You may choose to provide us or allow us to collect the information listed in this section. We are not obliged to ask you to provide such information, and your refuse will not affect your right to enter into the MINI Connected Mobility Terms and Conditions of Service, amd complete the registration process, or to use the basic product or service features under the Contract.

When you are using our services, we will be authorized to use the above-said information you have provided. In the event that you withdraw your consent, request the deletion of your personal information in accordance with this policy, or you terminate the MINI Connected Drive service or cancel your account, we will stop the use of, and will promptly delete the above information (including personal information generated during your use of the account). However, in cases explicitly provided for by laws, regulations and regulatory agencies, information related to the use of MINI Connected Services and financial transactions will be kept for a statutory period of time and may be subject to inspection by the relevant regulatory agencies.

2. Obligations under the MINI Connected Drive Service contract

In order to fulfill the MINI Connected Drive Service contract we sign with you, we will provide you with MINI Connected Drive service.

According to the configuration of different models, the vehicle is equipped with the corresponding MINI Connected Drive Service packages, with the following types:

(1) Basic Connected Service Package includes the following services: Intelligent emergency rescue service; and Teleservices, etc.

(2) Selected Connected Service Package includes the following services: Intelligent emergency rescue service; Teleservices; remote service; weather information; and online speech processing, etc.

(3) Advanced Connected Service Package includes the following services: Intelligent emergency rescue service; Teleservices; remote service; weather information; online speech processing; real-time traffic information;, etc.

(4) MINI Connected Base (Capable for MINI Operating System 9) includes following services: intelligent emergency rescue service; teleservices; information online - weather information; remote software update; MINI intelligent personal assistant; remote service; connected music; connected navigation service, Login administration, MINI Digital Key Plus (u*) Remote Control Parking and Festive App ,etc

(5) MINI Connected Package (Capable for MINI Operating System 9) includes following services: connected parking; (s) Indoor parking map*: video streaming; app store, etc.

1）Personal identification information: MINI ID (MINI 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) Third Party Application Account Information: Nickname

5) In-vehicle infotainment system and operation records:

The above information is not necessary to conclude the terms and conditions of BMW Internet driving service, but it is necessary to provide specific services under BMW connected drive service. Therefore, if you do not provide and authorize us to use the above information, we will not be able to provide specific services under the BMW connected drive Service.

The above personal information will be deleted after you stop using the relevant functions in the BMW connected drive service and log off your MINI ID, unless such information must be saved according to laws and regulations, or we have obtained your separate authorization.

2.3 During the free service period, in order to settle the communication costs incurred by the vehicle IoT network card, we will collect and process the consumption information and related information of the vehicle IoT network card connected to the Internet, including the vehicle identification number (VIN) and ICCID.

2.4 In order to use use our business functions, we may request the following vehicle system permissions related to personal information from you:

(1) Location

   We may obtain location permissions from you in the following circumstances:

   (a) To use navigation or other functions that require your approximate/precise location.

(2) Camera

    We will ask you for camera permission in the following scenarios:

   (a) Use the car camera to take pictures or observe the interior of the car.

(3) Microphone

   We will ask you for microphone permission in the following circumstances:

   (a) Using voice assistant to send commands;

   (b) Use the car camera to record videos;

   (c) When making a call through the vehicle side;

(4) Phone

   We will ask you for phone permission in the following circumstances:

   (a) Allow the application to initiate a phone call without the dialer interface.

(5) Notification

   We will obtain notification permissions from you in the following circumstances:

   (a) Push message notifications to you

(6) Address Book

     We will obtain address book permission from you in the following circumstances:

     (a) When you use the function of making calls from the vehicle side.

    (b) When using voice assistant

(7) Calendar

   We will obtain calendar permission from you in the following circumstances:

   (a) When using the BMW Intelligent Reminder Service

 (8) Bluetooth

  We will obtain your Bluetooth permission in the following business circumstances:

   (a) When establishing a connection to the vehicle through Car Connection and exporting videos and images from your vehicle to your moblie phone;

   (b) When using the remote upgrade service, Bluetooth is required for connecting to the vehicle;

   (c) When using digital key pairing, Bluetooth is required for connecting to the vehicle;

   (d) When using Car play to connect the cell phone and the vehicle

(9) WiFi Permission

We will obtain your WiFi permissions in the following circumstances:

     (a) When establishing a connection to the vehicle through Car Connection and exporting videos and images from your vehicle to your moblie phone;

     (b) Using Remote Upgrade Service, for establishing vehicle connection and possibly downloading upgrade package via Wifi;

     (c) When using Car play to connect the cell phone and the vehicle

In addition, we will apply for the following mobile system permissions and mobile related personal information from you through MINI application:

1.1 Location permission (corresponding business module: remote vehicle control service)

We will ask you for location permission under the following circumstances:

(a) It is used for vehicle positioning in remote vehicle control service (only when your vehicle does not have "Remote Vehicle Update" (LSC)).

1.2 Camera permission (corresponding business module: activation of connected drive service, login of connected drive service)

We will ask you for camera permission under the following circumstances:

(a) It is used to scan documents and materials required for real name registration during the activation of the connected drive service;

(b) In the connected drive service login, it is used to quickly log in the connected drive account in the vehicle by scanning the code.

1.3 Local photo album permission (corresponding business module: activation of connected drive service)

It is used to upload documents and materials required for real name registration during the activation of the connected drive service;

1.4 Face or fingerprint permission (corresponding business module: remote vehicle control service)

It is used to verify the identity and unlock the door remotely in the remote vehicle control service.

1.5 Notification authority (corresponding business modules: activation of connected parking service, remote vehicle control service and connected drive service)

Used to send system notifications to customers.

1.6 Sensor Permission （Accelerometer:corresponding business module: remote control parking service）

1.7 Bluetooth Permission (corresponding business module: remote control parking service)

 

There are 8 system permissions mentioned above. If you do not authorize, we will be unable to provide specific functions of the business.

2.5 In order to ensure the realization and stable operation of MINI's connected drive related functions, we may access the software development kit (SDK) provided by a third party to achieve relevant purposes. Different versions of third-party SDKs vary, generally including map navigation class, push notification message etc. We will strictly monitor the security of software tool development kits (SDKs) that partners obtain information to ensure data security. You can view the third-party data use and protection rules through the following table.

 

Provision of ConnectedDrive Mall Services

You may access the ConnectedDrive Mall from your vehicle, your computer or your mobile device to purchase, renew and obtain other information about products and services related to BMW ConnectedDrive Services. In order to provide the ConnectedDrive Mall services, we collect the following information:

1. MINI ID (MINI account number) login information;

2. Vehicle Identification Number (VIN);

3. When you access the ConnectedDrive Mall platform, the ConnectedDrive Mall platform automatically receives and logs certain log information about your browser, computer, or mobile device including your IP address, operating system, browser type, language used, date of access, and the date and time you accessed the ConnectedDrive Mall platform. When you visit the Connected Mall Platform, the Connected Mall Platform will automatically receive and record certain log information of your browser, computer or mobile device , including your IP address, operating system , type of browser , language used, date and time of visit, information on hardware and software characteristics, records of web pages you request, and information on the model of the device, device identifier, resolution, and telecommunication operator.

4. 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.

The above information is necessary for us to provide you with the basic business functions of the Connected Vehicle Mall related services. If you do not provide this information, we will not be able to provide you with the basic business functions of the Connected Vehicle Mall Services.

Developing and improving new products and optimizing the service

Beyond the provision of services, the information under1.2 will also be processed to ensure the quality of the MINI Connected Drive services and to develop new products and 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.

Fulfillment of the service and administration processes

In order to continuously optimize the customer experience, we may compile analyses and reports based on pervious information,. These analyses will primarily be used to introduce appropriate measures to improve the services process.

Also, parts of the vehicle-specific data collected under I.2 will be processed to fulfill the service processes (e.g. repair, warranty, goodwill) of BMW, BMW China affiliated companies and authorized dealers. This kind of processing is to offer our customers the best possible service process. The technical vehicle data will be deleted in a timely manner at the end of the vehicle’s service lifeHowever, we will still be obliged to retain your personal information within the scope of the law in cases explicitly provided for by laws, regulations and supervisory authorities (e.g., information relating to contractual transactions will be retained for a period of time beyond the expiration of the contract or the completion of the transaction and may be subject to inspection by the relevant supervisory authorities).

Customer service

We use your personal data (e.g. name, e-mail and telephone number) in order to contact you for contractual matters (e.g. to activate the BMW ConnectedDrive 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.

Advertising communication and market research based on consent

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 authorized consent. We will confirm the legitimacy of the source of such personal information and the scope of authorized consent, and if it exceeds your authorized consent, we will obtain your consent again. Please refer to the content of the authorization statement in specific scenarios for details. You have the right to withdraw such consent at any time according to your personal wishesIn addition, when you participate in the online or offline activities we organize from time to time, we will collect and use your personal information for the purposes necessary for your participation in the activities and for the purposes set forth in Parts I (3) to I (9) of this Personal Information Protection Policy (e.g., to optimize and improve the services we provide, to provide you with personalized product offers based on your interests). 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 “MINI Personal Information Collection and Use Instructions”. In such cases, these MINI Personal Information Collection and Use Instructions will prompt you to read this Personal Information Protection Policy, and your participation in online or offline activities will be deemed to constitute your reading of and consent to this Personal Information Protection Policy. We will handle your personal information strictly in accordance with this Personal Information Protection Policy.

Fulfillment of legal obligations

We process personal information based on a legal obligation. For example: when we perform recall obligations or carry out technical activities involving your vehicle. Sometimes, we use the vehicle information in part I (II) above based on legal requirements, such as disclosure of maintenance information according to relevant regulatory requirements. In order to protect the privacy of customers, the use of the technical information listed below will only be related to vehicles and not directly related to customers.

The information collected is also processed to ensure the operation of IT systems. In the following cases, we need to ensure IT running smoothly:

The information we collect is also used for compliance management purposes, such as checking whether the dealer is fulfilling its statutory obligation to give you adequate advice before you enter into a contract.

We are also subject to a range of other statutory obligations. For this, we may use your information to the extent required by law, regulation and supervision.

Exceptions of obtaining authorization 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 authorized consent:

(1) where it is necessary for the conclusion or performance of a contract to which the individual concerned is a party, or to implement human resources management in accordance with labor rules and regulations formulated according to law and collective contracts concluded according to law;

(2) where it is necessary for the performance of 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 a natural person;

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

(5) where the personal information disclosed by individuals themselves or other legally disclosed personal information is processed within a reasonable scope in accordance with the provisions of this Law; 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 this information for research, statistical and analytical purposes to improve the content of MINI 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 with your consent.

II. How We Use Cookies and Other Similar Technologies

As MINI Connected Drive Service will not use cookies or similar technologies. For how we use these on the website, please refer to our cookie policy.

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

Outsourcing In order to provide you with specialized, high-quality products and services, certain specific modules or functions of the BMW ConnectedDrive 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 Application Service, Connected Music Service, Connected Navigation Service, Map Upgrade, Connected Parking Service, MPP Service, WeChat In-vehicle Version (applicable to serval models only, subject to configuration of the models sold in the market at present), 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, authorized BMW dealers and/or external suppliers in order to provide you with relevant services and support. 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.

1. In the case of outsourcing 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, making agreement with the entrustees on the purpose of the entrusted duration, processing method, the types of personal information, protection measures, and the rights and obligations of and supervise their activities in the processing. We will ensure that the trustee handles your personal information in accordance with our agreement, and will not handle your personal information beyond the agreed purpose and method of handling. We will enter into a strict confidentiality agreement with the trustee requiring them to handle personal information in accordance with our requirements, this policy, and any other relevant confidentiality and security measures. Sharing

（1）Sharing with domestic MINI manufacturers

As the manufacturer of MINI new energy vehicles in China, in order to fulfill its statutory obligations as an automobile manufacturer under the laws and regulations of China (e.g., in order to satisfy the obligations of the automobile manufacturer in the fields of real-name registration of Telematics cards, real-time monitoring of new energy vehicles, traceability management of the recycling and utilization of new energy vehicle power storage batteries, automobile software upgrades, defective product recalls, special case, after-sales service and routine maintenance, management of vulnerabilities of vehicle networks and emergency response, and management of vehicle data, etc.), we may share the necessary personal information of you with Spotlight Automobile Co.

（2）Sharing with BMW China's affiliates, MINI partners and domestic MINI manufacturers

We may share your personal information with BMW China's affiliates、MINI partners and MINI domestic manufacturers. Unlike entrusted processing, in the case of sharing your personal information, BMW China's affiliates or MINI partners or domestic MINI manufacturers will independently decide on the purpose and manner of processing your personal information, and therefore, in the case of sharing, we will inform you of the specifics of the sharing in detail and obtain your individual consent.

（a）Sharing with our affiliates. Your personal information may be shared with BMW Automotive Finance (China) Co., Ltd. when you authorize and consent to the use of the services provided by BMW Automotive Finance (China) Co., Ltd.

The affiliated companies will ask for your authorized consent again if they want to change the purpose of handling personal information.

(b) Sharing with MINI partners. Only for the purposes stated in this policy, and subject to your authorization or separate consent, we will share your personal information with MINI partners in order to provide you with more convenient customer service and enhance your user experience.

Companies, organizations and individuals with whom we share Personal Information will be subject to strict confidentiality agreements requiring them to handle Personal Information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.

2. we may share your personal information in accordance with laws and regulations, or as mandated by regulatory agencies.

3. We will only share personal information that is necessary and subject to the purposes stated in this Policy. Before sharing your personal information, we will remind you and obtain your authorization again by means of a pop-up window, etc., or ask you to confirmation or sign a Separate Consent Letter.

3. Transferring

We will not transfer your personal information to any other company, organization or individual, including but not limited to 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 in a merger, acquisition or bankruptcy liquidation, we will require the new company or organization that will hold your personal information to continue to observe this Personal Information Protection Policy. Otherwise, we will require the new company or organization to request for your authorization and consent before transferring your personal information.

4. Public disclosure

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

(1) After obtaining your explicit consent.

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

5. Exceptions of obtaining prior authorized consent to share, provide or disclose personal information

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

(1) where it is necessary for the conclusion or performance of a contract to which the individual concerned is a party, or to implement human resources management in accordance with labor rules and regulations formulated according to law and collective contracts concluded according to law;

(2) where it is necessary for the performance of 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 a natural person;

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

(5) where the personal information disclosed by individuals themselves or other legally disclosed personal information is processed within a reasonable scope in accordance with the provisions of this Law; and

(6) other circumstances provided by laws and administrative regulations.

IV. 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 visit 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 protecting personal information.
  2. We will take all reasonable and feasible measures to ensure that we have not collected irrelevant personal information. We will only retain your personal information for a limited period necessary for realizing the purposes specified in this Personal Information Protection Policy, unless it is necessary to extend the retention period with your authorization or it is protected under the law.
  3. The Internet is not an absolutely safe environment. We will do our best to ensure the security of any information you send to us. If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized assess, public disclosure and data tampering or destruction, leading to the damage of your legitimate rights and interest, we will bear the legal liability.
  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.

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.

  1. Accessing your personal information

You have the right to access your own personal information, unless there are exceptions in laws and regulations. When you would like to exercise your right to access data, you may access the information by visiting: [Log in to MINI Internet driving user website - > Settings - > personal data to access or edit your personal information.

If you are unable to access your personal information from the above link, you may contact MINI client service 400-800-6699 for relative information. We will respond to your request within 15 days.

You also have the right to reproduce your personal information or to obtain a copy of it via sending an email to ConnectedDrive@bmw.com.cn.

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 Internet trust department are met.

  1. 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 400-800-6699 for specific process. We will respond to your request within 15 days.

  1. Deleting your personal information

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

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

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

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

(4) When you no longer use our products or services;

(5) When we no longer provide you with the products or services.

We will respond to your request in 15 business days after verification. If a request is to delete sensitive personal information, we will give the response within 10 business days. 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.

  1. Changing the scope of your authorization

Each business function cannot be realized without some basic personal information (see Part I of this Personal Information Protection Policy). 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 400-800-6699 or email ConnectedDrive@bmw.com.cn.

After you have revoked 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 authorization.

If you do not want to receive the commercial advertisements you choose to receive, you can unsubscribe related product push information or contact 400-800-6699.

  1. Deregisteruser accounts

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

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

  1. 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.

  1. 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 MINI Personal Information Protection Officer, and we will respond within 15 working days. Contact Number: 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 the personal information controller of obligations specified in laws and regulations;

(2) Where requests are in direct relation to the national security or national 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 the personal information controller has 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 personal information subjects or other individuals, but it is difficult to obtain their consent;

(7) Where responses to the requests of the personal information subject will give rise to serious damage to the legal rights and interests of the personal information subject 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. No child is allowed to create a user account by himself or herself, without the consent of his or her parent or guardian. Where personal information of a child is collected with the explicit consent of his or her parent, we will use or publicly disclose such information only when it is permitted under the law, the child’s parent or guardian grants explicit consent or it is necessary to do so to protect the child.

We regard any minor who is under the age of 14 as a child, no matter whether the child is defined differently under local laws and by local customs. If we find that we have collected the personal information of a child without prior and provable consent from the child’s parent, we will do our best to delete the relevant 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 in 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).

Although such jurisdictions may have different data protection laws, we will ensure that your personal information is adequately and equally protected 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 receiver to use personal information in strict accordance with the purpose agreed in the agreement by signing an agreement, and implement data security protection obligations by adopting technical and management measures.

VIII. How the Personal Information Protection Policy Will Be Updated

Our Personal Information Protection Policy may be changed from time to time. We will not reduce your rights under the Policy without your explicit consent. We will publish any change to the Personal Information Protection Policy and will make the historcial versions of the 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 Personal Information Protection Policy).

For the purpose of this Personal Information Protection 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 Personal Information Protection Policy, or if you have any questions about the way we use your personal information please contact us through the following means:

Email: ConnectedDrive@bmw.com.cn

Hotline: 400-800-6699

MINI (China) Automobile Trading Co., Ltd. registered address: 28 / F, block B, Jiacheng Plaza, No. 18, Xiaguangli, Dongsanhuan North Road, Chaoyang District, Beijing 100027, China. We make every effort to comply with all requests within 15 days.