Privacy Policy

LingYue Digital Information Technology Co., Ltd. (hereinafter "LingYue") is the authorized developer and business planning responsible party of MINI APP platform. NavInfo Technology Co., Ltd. (hereinafter NavInfo or "operator" or “we”) is entrusted by LingYue to operate functions of MINI APP and provide services to end users (see part I of this policy for details). In terms of the product or service, NavInfo is the operator and service provider of MINI APP, and BMW (China) Services Ltd. is the copyright owner and technology developer of MINI APP software.

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. What data do we process and for what purpose

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 treat your privacy in accordance with the same high standards that you expect from our MINI 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 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 read carefully, fully understand and accept this Privacy Policy before using our products or services.

 

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. What data do we process and for what purpose

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 collect and process your personal information solely for the following purposes as described in this policy to complete the business functions of MINI APP mobile application (APP).

We will seek your 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. User registration

To enable you to use MINI APP software and / or complete user registration, we will collect the following information.

(1)    Account information ("MINI APP” account login information, including the combination of registration account, password, password protection answer, user's personal digital certificate, etc.)

The above information is necessary for us to provide you with basic business functions. If you do not provide necessary information above, we will not provide you with basic business services of MINI APP.

 

During your use of our services, you continuously authorize us to use the information above provided by you. When you cancel your account, we will stop using it and delete the information above (including personal information generated during your use of the account) in time. However, in the case that if laws and regulations and regulatory authorities have specified statement, the information related to contract transactions and financial transactions will still be preserved within the legal time limitation after the expiration of the contract or the completion of the transaction, and may be subject to inspection by the relevant regulatory authorities.

  1. Provide services related to MINI APP

In MINI APP software, we will provide you with the following services:

(1)    Search function

Use the map service to search for addresses, locate and send points of interest to the car and machine. To achieve the above functions, we will collect and use your geographic location information and map usage behaviour data.

          Geographic location;

          map used behaviour data.

(2)    Find a MINI dealer service

In order to provide the above services, we may collect or process potential personal information generated during your use of the Find a MINI dealer service, including:

Geographic location.

(3)    Appointment service for after-sales service

You can book after-sales service provided by dealers through MINI APP. In order to provide the above services, we may collect or process potential personal information generated during your use of the after-sales service appointment service, including:

Name;

phone number;

VIN;

plate number;

vehicle model;

Current mileage of vehicle;

Geographic location information.

(4)    Road and accident rescue

You can book road and accident rescue services provided by the third-party Allianz through MINI APP. In order to provide the above services, we may collect or process potential personal information generated during your use of road and accident rescue services, including:

• Name;

• Phone number;

• Vehicle location (Geographic location information);

• Phone location (Geographic location information).

(5)    Service status tracking

You can reserve the service status tracking service provided by the dealer through MINI APP. In order to provide the above services, we may collect or process potential personal information generated during your use of the service status tracking service, including:

• Phone number;

(6)    Other car terminal functions

Other car terminal functions which are related to tabs “Vehicle”, “Map” and “Profile”.

For specific privacy policies, please refer to the MINI Privacy Policy of Connected Driving Service:

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

 

In order to improve the quality of service and enhance your user experience of the product, we may collect the following personal information during your use of MINI APP, including:

MINI APP user’s terminal device information;

MINI APP use record and click record.

 

The provision of the above data is not required to use the basic functions of MINI APP, but is necessary to provide specific services of MINI APP. Therefore, we cannot provide the specified services unless you have submitted the data and we are authorized to process it.

The processed personal information will be automatically deleted after your MINI APP 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, our MINI APP will apply to you for system permissions related to personal information:

          Get the user’s geographical location;

          Allow access to cameras and local albums;

          Access to the microphone;

          Facial and fingerprint permission;

          Notification permission.

System permissions and corresponding business modules are as follows:

(1) Get the user's geographic location (corresponding business modules: search function, find MINI dealer appointment service for after-sales service, Road and accident rescue, other car terminal function related to tab “Vehicle”)

(2) Allow access to the camera and local photo albums (corresponding business module: profile, find MINI dealer appointment service for after-sales service, other car terminal service related to tab “Vehicle”)

(3) Microphone (only for IOS, corresponding business module: find MINI dealer appointment service for after-sales service, used in service status tracking for receiving and sending audios)

(4) Facial and fingerprint permission (corresponding business module: other car terminal service related to tab “Vehicle”)

(5) Notification permission (corresponding business module: other car terminal service related to tab “Vehicle”)

The above-mentioned system permissions are 5 items in total.  Without your permissions we will not be able to provide the relevant business functions.  Except for the above-mentioned system permissions, you may voluntarily choose whether you would like to grant other system permissions to MINI APP.

 

  1. Ensuring product quality and developing new products

Beyond the mere provision of services, the data collected under I.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, the data 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. Fulfillment of the sales, service, and administration processes

In order to continuously optimize the customer experience and cooperation with the MINI dealers, we may compile analyses and reports based on contract information, which we may share with the responsible BMW 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 I.2 will be processed to fulfill the service processes (e.g. repair, warranty, goodwill) of us, LingYue, BMW China and 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 “Section III How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” below.  

  1. 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. booking of MINI 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.  We may also share your name, email address and phone number to our affiliated companies and partners for the same purpose.  See further information at “Section III How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” below.

  1. 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 our 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 our affiliates (including offshore affiliated companies), the details of which are stipulated “Section III How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” and “Section VII How Your Personal Information Will Be Transferred Globally” below.

  1. Fulfillment of legal obligations

We process personal information if there is a legal obligation to do so. This may be the case if we need to contact you because your vehicle is affected by a recall or a technical action.

The information collected is also processed to ensure the secured operation of IT system. Smooth and secured operation of IT system will be ensured with the following actions, among others:

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.

  1. 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 “Section III How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information” below. Transfer and Publicly Disclose Your Personal Information” below.

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.

 

  1. How We Use Cookies and Other Similar Technologies

We do not use cookies and other similar technologies in MINI APP services to collect your personal information.

 

  1. How We Entrust, Share, Transfer and Publicly Disclose Your Personal Information
  1. Entrusted processing

Certain modules or functions of MINI APP service are provided by external providers.

In order to provide you with Search function, Find a MINI dealer service, Appointment service for after-sales service, Pick-up and delivery service, Road and accident rescue, Service status tracking, we may collect the information in the first (2) part above information anonymously provided or transmitted to selected third parties.

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

Organization

Function

Required System Rights

Collected User Information

OCR recognition SDK

Shanghai Hehe information technology Ltd.

Retrieve the mobile phone camera to identify the driving permission

Camera access permission, storage permission

Mobile phone version

Gaode Map SDK

Gaode Locating SDK

Gaode Software Ltd.

Call map and POI functions

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

Addressing information

Countly SDK

Countly Ltd.

Collect front-end user operation data

Network request, device information, file read and write

User browsing, click to view, search query, favourites and other behavioural information

Aurora push

Shenzhen Hexunhuagu information technology Ltd.

Push notification

Network access permission, notification permission, read and write permission, wifi status, mobile phone information (Locating is optional)

Terminal equipment operating system

Application version

Mobile network/country code

Time zone

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

Battery status

Application identifier

Device model

Terminal manufacturer

Terminal device operating system version

 

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.

  1. Sharing

(1) Sharing information with LingYue’s affiliated companies and MINI dealers  

We will  share your personal information with LingYue’s affiliated companies and MINI dealer, to provide you with the product and service

(a) Sharing information with our affiliated companies: your personal information may be shared with affiliated companies of LingYue. For instance, for the purpose of performance inspection, customer service, advertising communication and / or market research related to customer relationship management within the brand, we will share your personal information with Lingyue and its affiliated companies under the scenarios described in part 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 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., and any other companies or entities directly or indirectly controlling, controlled by or under common control with the aforementioned entities through the ownership of voting equity, shares or otherwise

 (b) Sharing with authorized MINI dealers. For the purpose of realizing the purposes specified in the Privacy Policy, we may share some of your personal information with our authorized MINI 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.

(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) In addition to the circumstances above, if you need to share your personal information due to other business needs or reasonable reasons, we will inform you of the purpose of sharing personal information, the type of data receiver, etc., and obtain your authorization.

  1. 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.

  1. 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 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.

 

  1. How We Protect Your Personal Information

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.

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.

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. 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.

 

  1. Your Rights
  1. 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: Accessing your personal information

You have the right to access your own personal information, unless there are exceptions in laws and regulations. You can contact BMW_Helpdesk@navinfo.com to consult the specific correction process.

We will respond to your request within 15 working days upon authentication of your identity.

  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 BMW_Helpdesk@navinfo.com to consult the specific correction process.

Upon authentication of your identity, we will respond to your request within 15 working 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, or cancel your user account; or

(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.

  1. 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 can change your authorization consent at any time by sending the email to BMW_Helpdesk@navinfo.com.

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 may unsubscribe by sending the email to BMW_Helpdesk@navinfo.com at any time.

  1. Cancelling user accounts

You may cancel at any time the account you registered for by sending the email to 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.

  1. Obtaining copies of your personal information

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

At your request, we can transfer the copies of your personal information to designated third party as long as technologies permit, such as data interface matching.

  1. 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.

  1. 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 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 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.

 

  1. How We Deal with Childrens 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 childs 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 childs parent, we will do our best to delete the relevant information as soon as possible.

 

  1. 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.

 

  1. How the Privacy Policy Will Be Updated

Our Privacy Policy may be changed from time to time.  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 ease of 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).

For the purpose of this Privacy 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; and

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

 

  1.  How to Contact Us

If you have any concerns or comments on this Privacy Policy, or if you have any questions about the way we use your personal information 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.