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User Manual | Privacy Policy | Contact Us

PRIVACY POLICY

 

BMW Personal Information Protection Policy

This Personal Information Protection Policy solely applies to the various MY ID
Portal products or services provided by BMW China (with respect to imported
vehicles, BMW China Automotive Trading Ltd.; with respect to domestic vehicles,
BMW-Brilliance Automotive Ltd.) (hereinafter “BMW China” or “we”) through web
and new forms emerging with technological developments.

Depending on the person who concludes a contract with, or provides services or
products to, or carries out marketing activities to you, BMW China Automotive
Trading Ltd. and BMW-Brilliance Automotive Ltd. will respectively determine the
purpose for and method of processing your personal information, and protect your
personal information in accordance with the provisions of this Personal
Information Protection Policy.

This Personal Information Protection Policy was updated in April 2023.

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

 

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

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

                 II.        How we use cookies and other similar technologies

                III.        How we entrust, share, transfer and publicly
disclose your personal information

                IV.        How we protect your personal information

                 V.         Your rights

                VI.        How we process personal information of children

               VII.        How your personal information will be transferred
globally

              VIII.        How this Personal Information Protection Policy will
be updated

                IX.        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. 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.

By affixing your signature hereto, or clicking on “read”, “agree” or other
similar options, or accepting the products or services that we provide, and
submitting to us your personal information, you have accepted 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. Please carefully read this Personal Information
Protection Policy before ticking or clicking on “read”, “agree” or other similar
options, accepting the products or services that we provide, filling in,
confirming, authorizing the export and import of personal information, or
signing the authorization document, and ensure a full understanding of the
meaning of this Personal Information Protection Policy and the corresponding
legal consequences.


 

 

          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 relates to an identified or identifiable natural person, including but not
limited to name, date of birth, identification number, personal biometric
information, address and telephone number, but excluding anonymised information.

Sensitive personal information means the personal information that is likely to
infringe on the personal dignity of, or endanger the personal or property safety
of, a natural person, once it is leaked, unlawfully used.  In general, biometric
information, religious beliefs, particular identities, medical health, financial
accounts, personal whereabouts and other information, as well as personal
information of minors under the age of fourteen are regarded as sensitive
personal information.  In this Personal Information Protection Policy, the terms
and articles concerning sensitive personal information will be marked in bold
for your special attention.  In scenarios where sensitive personal information
is actually collected, we will further bring to your attention by means of an
enhanced notification or an instant alert (such as a pop-up window) and obtain
your authorization, or request you to otherwise click confirm or sign a Separate
Consent.

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

Unless otherwise indicated in this Personal Information Protection Policy or
otherwise provided in laws and regulations, we will advise you in advance and
seek your prior consent if we use your information for purposes other than those
stated in this Personal Information Protection 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 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/login

In order for you to better use MY ID products and complete the registration of
supplier accounts and technical accounts, we will collect the following
information:

 (1) Required contact details (username, first name, email address, mobile
number)

 (2) Account information (Digital ID account login information)

 (3) Personal access information (including device model, IP address, operating
system version, device settings, unique device identifier, software and hardware
characteristics, search keywords, browser usage, language used, uploaded files,
date, time and duration of access).

 (4) If you are a BBA user creating supplier accounts in bulk, the supplier's
email address will be used as unnecessary personal information to obtain.

The above items 1-3 are necessary information for us to provide you with MY ID
related functions. If you do not provide the above information, we will not be
able to create supplier accounts and technical accounts for you and provide
related services.

After successful registration with MY ID, all your registration information
(including name, email address, phone number, login account, etc.) will be
stored in the company's "digital identity platform", and your supplier will
receive an online account, allowing your supplier to log in and use other
portals and online business platforms of BMW Brilliance at the same time.

For suppliers, the information listed in item 4 above is not necessary for MY ID
to complete registration, but it is of great significance for improving service
quality and developing new products or services. You can choose to provide or
allow us to collect the information listed in item 4. We will not force you to
provide such information. If you refuse to provide such information, it will not
affect your supplier's use of MY ID's basic products or services.

During your supplier's use of our services, your supplier continues to authorize
us to use the above information you provided. When your supplier cancels the
account, we will stop using it and promptly delete the above information
(including personal information generated during your supplier's use of the
account). Nevertheless, information related to contracts and/or financial
transactions will, in accordance with the applicable legal or regulatory
provisions, be retained for statutory time limit after the contract has expired
or the transaction is completed and be subject to reviews by the relevant
authorities.

 

2.       Providing the various functions of MY ID product

In the MY ID product, we shall provide you with the following services and
process the corresponding personal information:

(1)     [Registration Services]. Through this service, you will be able to
register the supplier and technical accounts of BMW Brilliance, and collect the
following information about your supplier and technical account:

·         [Firstname/Lastname]

·         [Password]

·         [Mobile]

·         [Company]

·         [BBA Owner]

·         [F工号]

·         [职称]

·         [技术账号类型]

(2)     [View/Modify Personal Information]. This service will enable you to
modify your password/email address/phone number, and collect your following
information:

·         [Password]

·         [Mobile]

·         [Email]

The above information is necessary for the fulfillment of various functions or
related specified services embedded in the MY ID product. Therefore, we cannot
provide the specified services under the various functions of MY ID product
unless you have submitted the information and we are authorized to process it.

The above personal information will be deleted when you cease to use the related
function of MY ID product and confirm that you need to cancel your account,
unless it is required to be retained under laws and regulations or your further
authorization and consent is obtained.

In addition to the above information necessary for the fulfillment of various
functions or related specified services embedded in the MY ID product, we will
also process the following personal information when providing the related
services:

(1)     [Registration Services]:

·         [Email]

The information listed above is not necessary for the use of related products or
services but has important meanings for improving service quality and for
researching and developing new products and services or other purposes of this
Personal Information Protection Policy. You can choose to provide to us or allow
us to collect the information listed above. We will not list such information as
mandatory or required. Your refusal to provide additional information listed
above will not affect your normal use of the related functions.

 

3.       Ensuring product quality and developing new products

Beyond the mere provision of services, the information collected under I.1 and
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
is related to BMW’s commitments to meet high customer demand for existing
products and services and to satisfy the future wishes of our customers with new
products and services still to be developed.

 

4.       Fulfilment of statutory obligations

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

Sometimes, parts of the information collected under I.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
statutory obligations.

We are subject to a variety of other statutory obligations. In order to fulfill
these obligations, we process your information to the extent required by laws,
regulations and regulatory requirements

5.       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 required to enter into and perform a contract to which you
are a party;

(2)       where it is required for us to perform statutory duties or statutory
obligations;

(3)       where it is required to respond to public health emergencies or
protect the life, health and property safety of you and others;

(4)       processing of your personal information to a reasonable extent in
order to implement news reporting, public opinion supervision or other acts for
the public interest;

(5)       lawfully processing of your personal information disclosed by you or
otherwise lawfully disclosed to a reasonable extent ;

(6)       other scenarios stipulated in laws and administrative regulations.

 

Please note that in accordance with applicable laws, if we take technical
measures to process personal information so that such information cannot
re-identify particular individuals and cannot be restored, such information
shall no longer be personal information. We may use such information for
research, statistics and analysis so as to improve the content of BMW products,
provide support to business decisions and improve our products and services, and
may share such statistics with the public or a third party to show the overall
usage trends of our products and/or services. It is not necessary to otherwise
inform you or obtain your consent for such use.

 

         II.          How We Use Cookies and Other Similar Technologies

We use cookies for session processing. Only in this way can operations be
reliably assigned to specific users and access permissions be established.
Cookies are only used during the session and only contain a separate session ID
as personal data, which can be assigned to registered users for future tracking.

 

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

1.        Sharing

 (1) Sharing information with our affiliated companies and dealers

Save for the case of entrusted processing, we may share your personal
information with our affiliated companies and dealers from time to time.
Different from entrusted processing, in the case of sharing your personal
information, our affiliated companies and dealers as the receiving party will
independently determine the purpose for and method of processing your personal
information. Therefore, in the case of sharing your personal information, we
will inform you of the details of such sharing and obtain your separate consent.

 (a) Sharing information with our affiliated companies. To realize the purposes
specified in this Personal Information Protection Policy, if you grant your
authorization and consent to use the services provided by BMW Automotive Finance
(China) Co., Ltd., your personal information may be shared with BMW Automotive
Finance (China) Co., Ltd.

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

(b) Sharing with authorized dealers. To realize the purposes specified in this
Personal Information Protection Policy only, subject to your authorization or
separate consent, we may share some of your personal information with our
authorized dealers, in order to offer you more convenient client services and to
enhance your 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 Personal
Information Protection 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) We will share the necessary personal information only for the purposes
specified in this Personal Information Protection Policy. Before sharing your
personal information, we will remind you again by means of pop-ups and obtain
your authorization, or request you to otherwise click confirm or sign a Separate
Consent.

2.        Provision

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

(1) Providing information with explicit consent: we will provide your personal
information to other parties after obtaining your explicit consent.

(2) If your personal information has to be provided to the successor of the
rights and obligations of a company in a merger, acquisition or bankruptcy
liquidation, we will inform you separately and 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.

3.        Disclosure

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

(1) Where it is necessary for our business and after obtaining your separate
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.

4. Exceptions to acquire authorization and consent for sharing, provision and
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 required to enter into and perform a contract to which you
are a party;

(2)       where it is required for us to perform statutory duties or statutory
obligations;

(3)       where it is required to respond to public health emergencies or
protect the life, health and property safety of you and others;

(4)       processing of your personal information to a reasonable extent in
order to implement news reporting, public opinion supervision or other acts for
the public interest;

(5)       lawfully processing of your personal information disclosed by you or
otherwise lawfully disclosed to a reasonable extent ;

(6)       other scenarios stipulated in laws and administrative regulations.

 

         IV.        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 only
collect such personal information as required to realize the purposes specified
in this Personal Information Protection Policy. 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 or it is protected under the law.

3. The Internet is not an absolutely safe environment. Although we are committed
to protecting your personal information, we cannot guarantee or warrant that it
is absolutely secure. Therefore, you shall also take active measures to ensure
the security of your personal information, e.g. changing your account password
on a regular basis, and not disclosing your account password information to
others.

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.

 

         V.          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:

1.        Accessing, review and copy 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 to personal information, you may access the information yourself by
visiting:

MY ID ->My Profile, access or edit your personal information.

If you are unable to access your personal information from the above link, you
may contact us by emailing IAM3rdLevelSupport@bmw-brilliance.cn to inquire about
your relevant personal information. We will respond to your request within 15
working days upon authentication of your identity.

You have the right to copy your personal information, or obtain a copy of your
information. You may contact us by emailing
IAM3rdLevelSupport@bmw-brilliance.cn.

If it is technically feasible, such as matching of data interface, and is in
line with the conditions stipulated by the national cyberspace administration,
we also can directly transfer a copy of your personal information to the third
party designated by you.

2.        Rectifying your personal information

If you find that your personal information we process is inaccurate or
incomplete, you have the right to request us to rectify your information. You
may make rectification by visiting:

MY ID ->My Profile, to make your personal information and application
information accurate and complete.

If you are unable to rectify your personal information through the above link,
you may contact us by emailing IAM3rdLevelSupport@bmw-brilliance.cn. Upon
authentication of your identity, we will respond to your request within 15
working days.

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 have achieved, or find it impossible or unnecessary to achieve, the
purpose of processing your information (for example, you no longer use our
products or services, or you cancel your account);

(5) When you revoke your consent to our processing your personal information.

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, due to the
restrictions under the applicable laws and regulations, we may not immediately
delete the corresponding information from the backup system, but we will store
the information safely without further processing until the backup could be
eliminated or anonymized. To fully protect your personal rights and interests,
we may retain the necessary information in the backup system whilst keep such
information unsearchable or inaccessible through technical means.

4.        Changing the scope of your authorization or revoking your consent
    You may at any time grant or revoke your authorization or consent for our
collection and use of your personal information. You may revoke your
authorization by means of emailing. Please note that each business function
cannot be realized without some basic personal information (see Part I of this
Personal Information Protection Policy); thus, we cannot continue to provide the
relevant services to you if you revoke your consent for our collection and use
of your personal information required for the business function.

After you have revoked your consent, we will no longer process the personal
information in respect of which your consent is revoked. 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 any of the following
means: Contact IT Helpdesk to provide the work order to IAM operations and
maintenance.

5.        Cancelling user accounts

You can cancel the previously registered account by emailing
IAM3rdLevelSupport@bmw-brilliance.cn.

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.

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

For some business functions, our decisions may only rely on the automatic
decision-making mechanisms, such as the information system and algorithms. If
these decisions have a significant impact on your legal rights and interests,
you have the right to request us to provide explanations, and we will also offer
proper remedy measures.

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

7.        Responding to your requests

You may make requests in respect of your personal information by the above said
methods. For the sake of security, you may be required to prove your identity.
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: emailing
IAM3rdLevelSupport@bmw-brilliance.cn.

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 our performance of the 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 we have sufficient evidence that you are intentionally 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 you or other individuals, but it is difficult to obtain your or
their consent;

(7) Where responses to your requests will give rise to serious damage to the
legal rights and interests of you or any other individual or organization; or

(8) Where requests involve trade secrets.

 

         VI.        How We Deal with Children’s Personal Information

Our products and services are designed primarily for adults. We will not create
a BMW ID for children, nor collect or use the personal information of children.
If it is necessary to collect and use the personal information of children, we
will inform their guardians beforehand to obtain their separate consent.

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

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

 

        VII.       How Your Personal Information Will Be Transferred Globally

In principle, 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. Nevertheless, as we offer products or services through a
global network of resources and servers, and because of other business needs,
your personal information is likely to be transferred to, or accessed from other
jurisdictions outside the place where you use our products or services. For
example, for intra-brand performance review on customer relationship management,
customer service, advertising and/or market research purposes, we may provide
your personal information to our affiliates located outside the PRC.

Prior to cross-border transfer of your personal information, we will inform you
again by giving an enhanced notification or an instant alert (such as a pop-up
window) to obtain your authorization, or will ask you to otherwise click confirm
or sign a Separate Consent.

Although such jurisdictions may have different data protection laws, we will
make sure that your personal information is protected as adequately and equally
as those stored in the PRC by entering into an agreement for cross-border
transfer of data with the relevant overseas information recipient. For example,
we will implement security measures prior to cross-border data transfer such as
personal information security impact assessment and data de-identification, and
require data recipients to use personal information strictly for the purpose as
agreed by means such as executing an agreement, and take technical and
management measures to effectively perform data security protection obligations,
etc.

 

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. If
cross-border data transfer is required in the future, we will otherwise ask for
your permission, comply with the applicable laws and regulations, and make sure
that your information will be under the same and equal protection as in the PRC.

 

       VIII.       How this Personal Information Protection Policy Will Be
Updated

Our Personal Information Protection Policy may be changed. We will not reduce
your rights under this Personal Information Protection Policy without your
explicit consent. We will publish any change to this Personal Information
Protection Policy at this page. We will keep the former versions of this
Personal Information Protection 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 Personal Information Protection Policy).

The major changes in this Personal Information Protection Policy 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; and

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, please contact us through the following means:

Email: IAM3rdLevelSupport@bmw-brilliance.cn

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

We will make every effort to reply all requests within 15 working days.

 



CONTACT US

Contact us (IAM 3rd Level Support)

Email : IAM3rdLevelSupport@bmw-brilliance.cn


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