My BMW PRIVACY POLICYinformation service

LingYue Digital Information Technology Co., Ltd. (hereinafter "LingYue") is the authorized developer and business planning responsible party of My BMW platform. NavInfo Co., Ltd. (hereinafter "NavInfo" or "operator") is entrusted by LingYue to operate some functions of My BMW and provide services to end users (see 1.2 of this policy for details). This Privacy Policy solely applies to My BMW product or service of NavInfo Co.,Ltd..

The Privacy Policy was updated in August 2021.

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

Email: BMW_Helpdesk@navinfo.com

The Privacy 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 entrust, 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 Privacy Policy will be updated

9. How to contact us

We are fully aware of the importance of personal information to you and treat your personal information in accordance with the same high standards that you expect from BMW products and services. The confidentiality and integrity of your personal information is of particular concern to us. We are committed to creating and maintaining your trust in us and observe the following principles when protecting your personal information: consistency between rights and liabilities, clear purposes, solicitation of consent, minimum necessity, guarantee of security, involvement of personal information subjects, and openness and transparency. Meanwhile, we are committed to setting up necessary safeguards pursuant to well-developed security standards in order to protect your personal information.

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

1. 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, national ID number, bank account number, precise personal positioning information etc. are regarded as sensitive personal information. In this Privacy Policy, the terms and articles concerning sensitive personal information will be marked in bold for your special attention.

We will collect and process your personal information solely for the purposes specified as below and to fulfill the business function of My BMW.

We will seek your prior consent if we use your information for purposes other than those stated in this Privacy Policy.

Unless otherwise indicated in below the purposes, we store your personal information only for as long as the relevant purpose requires it. If your personal information is processed for multiple purposes, your information will be automatically deleted or stored in a form that cannot directly be traced back to you, as soon as the last specified purpose has been fulfilled.

1.1. User Registration

In order to provide you My BMW service, we will collect the following information:

1.1.1 BMW ID (BMW account) login information (including the combination of registered account, password, password protection answer, user's personal digital certificate, etc.)

The above information is retained only so long as necessary for us to provide you with basic business functions. If you do not provide the above necessary information, we will not be able to provide you with basic business services through My BMW.

During the use of our services, you continue to authorize us to use the above information you provide. When you delete the account, we will stop using the account and delete the above information in time (including personal information generated during your use of the account). However, in case of any other specific provisions of laws and regulations and regulatory authorities, information related to contract transactions and financial transactions will be kept within the legal time limit after the contract expires or the transaction is completed and may be subject to the inspection of the relevant regulatory authorities.

1.2. Provide services related to My BMW software

In My BMW software, we will provide you with the following services and collect the following information related to the services:

1.2.1. Public charging information integration service, including:

(1). In order to provide you the instant plug in and instant charging integration service (“Instant Plug in and Instant Charging), public charging information integration service needs to collect and use your information:

VIN number.

(2). In order to provide you with the charging card discount service at the public charging service provider, the public charging information integration service needs to collect and use your information, including:

• My BMW account login information.

(3). In order to provide you with location-based public charging station query services, the public charging integration services need to collect and use your information, including:

• Geographical location information.

(4). In order to facilitate the reduction or exemption of parking fees when you are out of the field, some public charging stations provide the service of charging and exempting parking fees. When scanning the QR code of some public charging piles, you need to fill in your personal information. The information will be sent to the public charging operator and the parking lot system in an encrypted form. The information you need to provide includes:

Plate number.

1.2.2. Exclusive park & charge service, including:

(1). In order to provide you with an appointment service at the exclusive park & charge service provider, the exclusive park & charge service needs to collect and use the following information, including:

• Phone number.

(2). In order to provide you with the location-based exclusive park & charge station query service, the exclusive park & charge service needs to collect and use the following information, including:

• Geographical location information.

(3). In order to facilitate the automatic identification of the vehicle by the parking lot system when you enter the venue, and the identification of the reserved vehicle at the exclusive park & charge station, we need to f collect and use your license plate number. The license plate number information will be sent to the exclusive park & charge service provider and the parking lot system in an encrypted form.

1.2.3. Search function

The map service will enable you to use the function of address search, locating and sending points of interest to the car terminal. To achieve the above functions, we will collect and use the following information, including:

Map usage behavior data

1.2.4. Community service

The map service will enable you to use the function of address search, locating and sending points of interest to the car terminal. To achieve the above functions, we will collect and use the following information, including:

Name;

Gender;

Mobile phone number;

My BMW account login information.

1.2.5. Search BMW dealer service

In order to provide the above services, we will collect and process the following information generated during your use of the BMW dealership search service, including:

• Geographical location information.

1.2.6. Aftersales service booking

You can book after-sales service provided by dealers through My BMW. In order to provide the above services, we will collect and process the following information generated during your use of the after-sales service appointment service, including:

Name;

Phone number;

VIN number;

Plate number;

Vehicle model;

The current mileage of the vehicle;

Geographical location information.

1.2.7. Vehicle pick-up and delivery service

You can make an appointment to pick up and deliver the car service provided by the dealer through My BMW. In order to provide the above services, we will collect and process the following information generated during your use of the car service, including:

Name;

Phone number;

Number plate;

Pick-up and delivery address (geographical location information).

1.2.8. Road and accident rescue

You can book road and accident rescue services provided by the third party through My BMW. In order to provide the above services, we will collect and process the following information generated during your use of road and accident rescue services, including:

Name;

Phone number;

Vehicle location;

Phone location.

1.2.9. Service status tracking

You can reserve the service status tracking service provided by the dealer through My BMW. You can send or save pictures, audio and video in the online chat room with dealers. In order to provide the above services, we will collect and process the following information generated during your use of the service status tracking service, including:

Phone number;

1.2.10. Save POI function

You can collect your favorite points of interest into My BMW App. To achieve this function, we will collect and process the following personal information generated during use:

Login information of My BMW account

Collected destination

1.2.11. Intelligent reminder

When the user has established the reminder (triggered by speech or touching the screen), the data will be sent to the backend to store this reminder:

         userId

         content of the reminder created by the user

1.2.12. Other car terminal functions

Other car terminal functions are related to tabs “Vehicle”, “Map” and “Profile”. For specific privacy policies, please refer to the Privacy Policy of ConnectedDrive Service:

https://myc-profile.bmw.com.cn/api/gateway/views/legal-documents/privacy-policy-en_US.html

In order to improve the service quality and accuracy, we will collect the following personal information during your use of My BMW, including:

My BMW user’s terminal device information;

APP use record and click record.

The above information is not necessary for you to register for the basic functions of My BMW, but it is necessary for you to provide the specific services under my BMW. Therefore, we cannot provide the specified services of My BMW product unless you have submitted the information and we are authorized to process it.

The processed personal information will be automatically deleted when your BMW ID account is cancelled., unless it is needed longer for the provision of the specified service and your further authorization and consent is obtained.

When you use the relevant business functions, My BMW will apply to you for system permissions related to personal information:

         Get the user's geographical location;

         Allow the access to cameras and local albums;

         Allow the access to microphone;

         Allow the access to mobile phone;

         Fingerprint and Facial information permission;

         External storage permissions of Android systems;

         Notification access;

         Calendar Reminder permission.

System permissions and corresponding business modules are as follows:

(1). Get the user's geographical location (corresponding business modules: search function, public charging information integration service, exclusive park & charge service, search BMW dealer service, aftersales service booking, road and accident rescue, vehicle pick-up and delivery service, car terminal service related “Vehicle” and “Map” tabs)

(2). Allow the access to cameras and local photo albums (corresponding business modules: release news (community service), Profile/my, aftersales service, public charging information integration service, send and receive pictures and videos in service status tracking, car terminal service related “Vehicle” tab)

(3). Microphone permissions (corresponding business modules in iOS: release news (community service), aftersales service, send and receive audio in service status tracking)

(4). Mobile phone access (for users to directly dial the customer service phone of BMW exclusive charging service provider, corresponding business modules: public charging information integration service, exclusive park & charge service)

(5). Fingerprint and Facial information permission (corresponding business modules: Fast login to mobile APP and car terminal service related “Vehicle” tab)

(6). External storage permission of Android system (corresponding business modules: This permission has been applied for car terminal service which is related to tab “vehicle”, but it has not been put into use.)

(7). Notification access (corresponding business modules: public charging information integration service, exclusive park & charge service, community service, aftersales service booking, vehicle pick-up and delivery service, road and accident rescue, service status tracking, intelligent reminder and the “recall and service” feature in My BMW, and car terminal service related tabs “Vehicle” and “Map”)

(8). Calendar reminder permission (corresponding business modules: aftersales service booking)

There are 8 system permissions mentioned above. If you do not authorize, we will not be able to provide relevant business functions. In addition to the above permissions, you can choose whether to grant additional system permissions to app.

In order to ensure the realization of APP-related functions and the stable operation of the application, we may access a software development kit (SDK) provided by a third party to achieve related purposes. Different versions of the third-party SDK will be different, generally including map navigation, push notification messages, etc. We will conduct strict security monitoring on the software tool development kit (SDK) used by partners to obtain information to ensure data security. You can view the third-party data usage and protection rules through the table below.

SDK

Function

Company

Access

Personal Information

OCR Registration SDK

Submit information in the process of real name authentication, call mobile phone camera to identify driving license, VIN number and purchase invoice

IntSig Information Co. Ltd

Network access, camera access, album read access, storage access

Mobile System Version

WeChat SDK

Call WeChat-related functions (sharing/authorization)

Shenzhen Tencent Computer System Co.,Ltd

Network access, read/write permissions, get network status, Wifi status

  1. Share and collection, the image data collected from third parties is used to share to friends or WeChat collection, but will not be used to associate and track users
  2. WeChat login, after user authorization, the third party application can get the user's avatar, nickname, region and gender information saved in WeChat side.

Alipay Direct Debit SDK

Call Alipay to complete online payment

Alipay (China) Network Technology Co.

Network access, device read/write, multimediapermissions

Encrypted order number

Auto Navi Map SDK

Calling map and POI functions

Auto Navi

Location permission, storage permission, read device information, device information, network request

Searching Location Information

Countly SDK

Collect front-end user operation data

 

Countly Ltd

Network request, device information, file reading and writing

Terminal device operating system

Application version

Mobile network

Network status

Equipment model

OS version of terminal equipment

Miaozhen Analysis Flutter SDK

Collect user front-end interaction behavior data

Beijing Mingluezhaohui Technology Co., Ltd

Network request, device information, file reading and writing

Terminal device operating system

Application version

Mobile network

Network status

Battery status

Application device identifier

Equipment model

Terminal manufacturer

OS version of terminal equipment

time zone

JPush

Push notification

Aurora Mobile

Access to network permissions, notification permissions, device information

Terminal device operating system

Application version

Application distribution channel

Mobile network / country code

Time zone

Network status (WiFi / 4G, disconnected, etc.)

Battery status

Application Identifier

Equipment model

Terminal manufacturer

OS version of terminal equipment

Tianrun IM SDK

 

Instant messaging service, support text, picture, audio, video, file and other message types

Beijing Tianrun rongtong Technology Co., Ltd

Camera access rights, file storage rights

Network status (disconnected or not), device model, terminal manufacturer, application version, device operating system version

 

1.3. Ensuring product quality and developing new products

Beyond the mere provision of services, the information collected under 1.2 will also be processed to ensure the quality of the BMW products and services and to develop new BMW products and services. This kind of processing serves the legitimate interest of BMW to meet high customer demand for existing products and services and for BMW to be in a position to satisfy the future wishes of our customers with new products and services still to be developed. For the protection of customers’ privacy, such information will be processed exclusively in a form that cannot be directly or indirectly traced back to the specific customer or vehicle unless additional and separate consent of the customer is obtained.

1.4. Fulfilment of the sales, service, and administration processes

In order to continuously optimize the customer experience and cooperation with the BMW authorized dealers, we may compile analyses and reports based on contract information, which we may share with the responsible BMW authorized dealers. These analyses will primarily be used to introduce appropriate measures (e.g. training for sales staff) to improve the application and sales process. We may prepare the reports described above exclusively in aggregated and anonymized form, i.e. the recipients of the reports will not be able to identify you as an individual from the data contained in the reports.

Also, parts of the vehicle-specific data collected under 1.2 will be processed to fulfill the service processes (e.g. repair, warranty, goodwill) of NavInfo, LingYue, BMW China and BMW authorized dealers. This kind of processing is in the legitimate interest of BMW to offer our customers the best possible service process. The technical vehicle data will be deleted in a timely manner at the end of the vehicle’s service life. However, if there are specific stipulations under the laws and regulations and required by the authorities, information related to contractual transactions will be retained within statutory time limit and may be inspected by the relevant authorities. See further information at “3. How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” below.

1.5. Customer service

We use your personal information (i.e. your name, email address and phone number) to contact you in connection with the processing of contracts (e.g. opening of BMW Connected Drive services) or to process a request formulated by you (e.g. inquiries and complaints sent to BMW customer services). For all aspects of processing contracts or requests, we will contact you without obtaining separate consent, e.g. in writing, by telephone, messenger services, or email, depending on the contact media you specified. Please note that we may also share your name, email address and phone number to LingYue affiliated companies (including offshore affiliated companies) and partners for the same purpose. See further information at “3. How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” and “7.How Your Personal Information Will Be Transferred Globally” below.

1.6. Customer activities, marketing campaign and market research

You acknowledge and agree that we may use your personal information for customer activities, marketing campaigns and/or market research purposes during your use of our services. For example, we will use your name, email and phone number and other relevant personal information to carry out customer group analysis and other market research to optimize and improve the services we provide. At the same time, your above information will also be used to carry out customer care and marketing activities, including information of our new cars, product promotions, holiday blessings and other promotional information. In addition, we will obtain your personal information from BMW authorized dealers based on your authorization to do so. For details, please refer to the authorization statement under the specific scenario. You have the right to revoke such consent at any time at your own discretion. Please note that, in order to accomplish the foregoing purposes, we may share your personal information with LingYue affiliates (including offshore affiliated companies), the details of which are stipulated “3. How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” and “7. How Your Personal Information Will Be Transferred Globally” below.

1.7. Fulfilment of legal obligations

We may process your personal information based on statutory and regulatory obligations, such as when we perform a recall obligation or carry out a technical activity which involves your vehicle.

Sometimes, parts of the vehicle-specific information collected under 1.2 are also processed to meet legal and regulatory requirements such as disclosure of repair and maintenance information request by the relevant regulation. To protect the privacy of our customers, the processing of technical information listed below is always vehicle-related and without direct or indirect connection to the specific customer.

• Vehicle master data (vehicle type, color, equipment, etc.)

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

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

In order to ensure the secured operation of IT systems, we may need to use your information. Smooth and secured operation of IT systems will be ensured with the following actions, among others:

• Backup and recovery of data processed in IT systems

• Logging and monitoring of transactions to check the correct functioning of IT systems

• Detection and prevention of unauthorized access to personal information

• Incident and problem management for troubleshooting IT systems

The information collected is also processed as part of internal compliance management by which we check, for example, whether you received sufficient advice when concluding a contract and that the dealer complied with all legal obligations.

We are subject to a variety of other legal obligations. In order to fulfill these obligations, we process your information to the required extent and, if necessary, pass it on to the responsible authorities in accordance with legal reporting requirements. See further information at “3. How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” below.

1.8. Exceptions to acquire authorization and consent for collection and use of personal information

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

(1)where it is related to our performance of obligations provided by laws or regulations;

(2)where there is a direct relation to national security or national defense;

(3)where there is direct relation to public safety, public health, or major public interests;

(4)where there is a direct relation to criminal investigations, prosecutions, trials, or enforcement of judgments and the like;

(5)where it is done to preserve the life, property, or major lawful rights and interests of you or another person, and it is very difficult to obtain your consent;

(6)where the personal information involved was voluntarily disclosed to the public by you;

(7)where it is done to enter into and perform a contract between you and us;

(8)personal information that is collected from lawfully disclosed information, such as lawful news reports, open government information, and other such channels;

(9)where used to preserve the secure and stable operations of product or service, such as discovering or handling problems with the product or service.

2. How We Use Cookies and Other Similar Technologies

We do not use cookies and other similar technologies in our products/services to collect your personal information.

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

3.1. Entrusted processing

In order to provide you with public charging pile service, park & charge service, we will not retain the plate number and mobile phone number in the order. We may provide or transfer the anonymous information collected under Section I.2 to the following third parties for the purpose of use for public charging information integration service, search function, community service, search BMW dealer services, aftersales service booking, vehicle pick-up and delivery service, ConnectedDrive service:

Public charging information integration service: UniEV, State Grid, Starcharge, Teld, Anyo, Potevio, EV Power

Exclusive park & charge service: Sinoair, EV card

 

Search function: Auto Navi map (map provider), Tencent (search function service provider, location data will be anonymously transmitted to Tencent)

Community service: Leo Group Digital Technology Co., Ltd. (operation provider, collecting information, including mobile phone number and name of users, used for community activity prize distribution, activity participation and management, community content management, etc.)

Service status tracking: instant messaging service provided to Tianrun (set up exclusive online chat rooms for users through mobile phone number in service status tracking)

We will enter into strict non-disclosure agreements with all entrusted companies, organizations and individuals and require them to process personal information according to our instructions, this Privacy Policy and any other related measures for confidentiality and security.

3.2. Sharing

3.2.1. Sharing information with LingYue, LingYue’s affiliated companies and BMW authorized dealers

We will share your personal information with LingYue, LingYue’s affiliates and BMW authorized dealers at times in order to provide you with the products or services you need.

(a). Sharing information with LingYue, LingYue’s affiliated companies: your personal information may be shared with affiliated companies of LingYue. For example, for the purposes of intra-brand performance inspection on customer relationship management, customer service, advertising and/or market research, we will share personal information with affiliated companies under the scenarios as described in Section I.6 of this Policy.

We will share the necessary personal information only for the purposes specified in this Privacy Policy. If an affiliated company changes the purpose for processing your personal information, your further authorization and consent will be obtained. LingYue’s affiliated companies include BMW AG, BMW (China) Automotive Trading Ltd., BMW Brilliance Automotive Ltd., BMW Automotive Finance (China) Co., Ltd., BMW China Services Ltd., Herald International Financial Leasing Co., Ltd., as well as any corporation or other entity, directly or indirectly controlled by, under control of or under common control with any of them, whether through the ownership of voting shares or equity interest or otherwise.

(b). Sharing with BMW authorized dealers. To realize the purposes specified in the Privacy Policy, we may share some of your personal information with BMW authorized dealers, in order to offer better client services and user experience.

We will enter into strict non-disclosure agreements with all companies, organizations and individuals with which we share information and require them to process personal information according to our instructions, this Privacy Policy and any other related measures for confidentiality and security.

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

3.2.4. Except for the circumstances mentioned above, if your personal information is required to be shared due to other business needs or reasonable causes, we will inform you of the purpose of sharing personal information and the type of data recipient and obtain your authorization and consent.

3.3. 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 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 Privacy Policy. Otherwise, we will require the new company or organization to request for your authorization and consent before transferring your personal information.

3.4. 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.

3.5. Exceptions to acquire authorization and consent for sharing, transfer and public disclosure of personal information

In accordance with relevant laws, regulations, and national standards, we may share, transfer, or disclose to the public your personal information without your prior authorization and consent if:

(1) Where it is related to our performance of obligations provided by laws or regulations;

(2) Where there is a direct relation to national security or national defense;

(3) Where there is direct relation to public safety, public health, or major public interests;

(4) Where there is a direct relation to criminal investigations, prosecutions, trials, or enforcement of judgments and the like;

(5) Where it is done to preserve the life, property, or major lawful rights and interests of you or another person, and it is very difficult to obtain your consent;

(6) Where the personal information involved was voluntarily disclosed to the public by you;

(7) Where the personal information is collected from information disclosed through lawful public channels, such as lawful news reports or information disclosure by the government.

4. How We Protect Your Personal Information

4.1. We store your information based on the state of the art and we take the following safeguards to protect your personal information from misuse or any other unauthorized processing, disclosing, using, rectifying, or destroying. Access to personal information is restricted to a limited number of authorized persons for the stated purposes only. The data collected will only be transmitted in encrypted form. Sensitive data is stored only in encrypted form. The IT systems for processing the data are technically isolated from other systems to prevent unauthorized access, e.g. through hacking. In addition, access to these IT systems is continuously monitored to detect and ward off misuse at an early stage.

4.2. 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 Privacy Policy, unless it is necessary to extend the retention period or it is protected under the law.

4.3. The Internet is not an absolutely safe environment. We will do our utmost to ensure the security of any information you send to us. If damage to our physical, technical or management safeguards results in your information being accessed, publicly disclosed, falsified or damaged without authority, which causes damage to your legal rights and interests, we will bear the legal liability.

4.4. In the case of any incident in respect of personal information security, we will, pursuant to requirements set out in laws and regulations, inform you promptly of the particulars, including basic information about the security incident and the likely impact, what measures we have taken or will take to respond to such incident, suggestions on what measures you may take yourself to guard against and lower risks, remedial actions we offer to you, etc. We will brief you on the progress of the incident by email, correspondence, phone or by sending notifications, and we will release announcements for this purpose in a reasonable and effective manner even when it is difficult to notify personal information subjects one by one.

Meanwhile, we will actively report how the personal information security incident is being handled pursuant to the requirement of the regulator.

5. Your Rights

According to applicable Chinese laws, regulations and standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights with respect to your personal information:

5.1. Accessing your personal information

You have the right to access your own personal information, unless there are exceptions in laws and regulations. If you would like to exercise your right to access, you may contact us by emailing BMW_Helpdesk@navinfo.com. We will respond to your request within 15 working days upon authentication of your identity.

5.2. Rectifying your personal information

If you find that your personal information we process is inaccurate, you have the right to request us to rectify your information. You may contact BMW_Helpdesk@navinfo.com for specific rectifying process.].

Upon authentication of your identity, we will respond to your request within 15 working days.

5.3. Deleting your personal information

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

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

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

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

(4) When you no longer use our products or services, or cancel your user account

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

If we agree with your request to delete information, we will also notify entities that obtain your personal information from us to require them to delete the information concerned in a timely manner, unless otherwise stipulated by laws and regulations or such entity has obtained your separate authorization.

Once your information has been removed from our services, we may not immediately delete the corresponding information from the backup system, but we will delete the information when the backup is updated.

5.4. Changing the scope of your authorization

Each business function cannot be realized without some basic personal information (see Part I of this Privacy 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 may contact at any time: BMW_Helpdesk@navinfo.com.

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

If you do not want to receive commercial advertisements and other marketing and promotion information we send, you may unsubscribe by contacting us:BMW_Helpdesk@navinfo.com.

5.5. Cancelling user accounts

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

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

5.6. Obtaining copies of your personal information

You have the right to obtain copies of your personal information at any time by emailing:BMW_Helpdesk@navinfo.com.

At your request, we can transfer your data to another person in charge as long as technologies permit, for example, the data interface matches.

5.7. Use of automatic decision-making of the information system

Our decisions will not only rely on the automatic decision-making mechanisms, such as the information system and algorithms.

5.8. Responding to your requests

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.

We will reply within 15 working days. If you are dissatisfied with our reply, you may lodge a complaint through the following means: BMW_Helpdesk@navinfo.com.

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 defense security;

(3) Where requests are in direct relation to the public security, public sanitation, or major public benefits;

(4) Where requests are in direct relation to investigations into crimes, prosecutions, court trials, execution of rulings, etc.;

(5) Where 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 are 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.

6. 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.

7. How Your Personal Information Will Be Transferred Globally

The personal information we collect and generate within the territory of the People’s Republic of China (PRC) will be stored within the territory of the PRC. Therefore, your personal information will not be transferred to other jurisdictions outside the PRC or be accessed by these overseas jurisdictions.

8. How the Privacy Policy Will Be Updated

Our Privacy Policy may be changed. We will not reduce your rights under the Privacy Policy without your explicit consent. We will publish any change to the Privacy Policy at this page. We will keep the former versions of this Privacy Policy available to you for reference.

In the case of major changes, we will release clear notices (including, for some services, the mail messages that inform you of what specific changes are introduced to this Privacy Policy).

The major changes in this Privacy Policy include but are not limited to:

8.1. 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.;

8.2. 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;

8.3. Changes to the subjects we share with, transfer to or publicly disclose personal information;

8.4. 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;

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

8.6. Changes made due to high risks revealed in the security impact assessment report for personal information.

9. How to Contact Us

If you have any concerns or comments on this Privacy Policy, please contact us through the following means:

Email: BMW_Helpdesk@navinfo.com

NavInfo Co.,Ltd, registered address: NavInfo Building at the intersection of Yongfeng Road and Beiqing Road, Haidian District, Beijing 100094.

We make every effort to reply all requests within 15 working days. If you are dissatisfied with our response and especially if our conduct of processing personal information harm your legitimate interest, you may consult the relevant government authorities and seek solutions.