1.1 BMW Concessionaires (HK) Ltd. ("MINI HK", "we", "our" or "us") appreciates your interest in us and our products and services. Your privacy is important to us and we are committed to preserving the confidentiality of your personal data ("Data"). We set out below our privacy information and practices to help you better understand how we collect, process, transfer, retain and delete your Data.

1.2 This Privacy Policy applies when you:

1.2.1 visit our websites or online stores;

1.2.2 use our mobile applications;

1.2.3 drive your vehicle and use features provided with your vehicle (including but not limited to BMW ConnectedDrive);

1.2.4 join our membership and loyalty programs;

1.2.5 contact our Showrooms, Service Centres, or Customer Care hotlines to engage with our customer service, or any other time you contact us or attend our Showrooms and Service Centres for products, services and test drives; and

1.2.6 any other time when we collect and process your Data.

2.1 It is voluntary for you to provide your Data. However, if you do not wish to provide your Data as requested by us, we may not be able to provide you with our products and services, fulfil your requests, or respond to your enquiries.

2.2 We do not intend to collect Data from minors. If a child has provided us with Data without the consent of his/her parent or guardian, the parent or guardian may contact us (please see section 10 below for contact details) to request the removal of the Data.

2.3 You further acknowledge and agree that where you provide us with Data of persons other than yourself, for example of an alternative or emergency contact, that you have notified such persons of this BMW Privacy Policy and that you have the consent of such persons to provide their Data to us for processing in accordance with this BMW Privacy Policy.
 

Information that you provide us

2.4 Whenever you interact with us, you may be asked to provide us with Data relating to you. For example:

2.4.1 When you use or purchase products and services from us, we may collect your Data such as gender, name, age group, phone number, email and/or postal address, identity card number, your credit or debit card information and billing information, including name of cardholder, card number, expiry date and billing address, and we may also store information related to your purchase such as order information including without limitation to the order agreement, trade-in information, pre-delivery information and other documentation required for your order ;

2.4.2 When you conduct test drives of our vehicles, we may need to collect additional Data from you such as your driver's license or government identification ;

2.4.3 Some of our services require you to create an account, such as when you use the BMW Concessionaries App, and we may ask you to provide Data such as your name, contact details, age, month of birth, gender, identity card number, interests, account and newsletter preferences, purchase details, place of purchase, product registration;

2.4.4 When you contact our Customer Care services for assistance, via email, telephone, messaging service (e.g. WhatsApp), live chat, in-person or otherwise, we may record and keep information about the call, including your name, phone number, email address, enquiry details, and the reason why you contacted us, for the purposes of monitoring the quality of our customer service and responding to your request;

2.4.5 When you participate in one of our prize draws or competitions, we may collect information such as your gender, name, contact details, email address, age, and submitted materials; and

2.4.6 When you visit us at a public event, such as our shows, exhibitions, seminars, workshops, or participate in one of our redemption activities, we may collect your contact details, survey information, interests, age, gender, demographic information, redemption activity information.

Information from or about your vehicle

2.5 When you purchase or use your vehicle, including when you use features provided with your vehicle such as BMW ConnectedDrive, or when you bring your vehicle to us for servicing, we may collect the following information from or about your vehicle:

2.5.1 Vehicle type, including year, make, model, vehicle identification and configuration;

2.5.2 Vehicle data, including information regarding the performance, functionality, maintenance and operation of your vehicle;

2.5.3 Vehicle technical data (e.g. service information concerning wear of parts, vehicle status information such as check-control notifications, battery-charge status);

2.5.4 Location data of your vehicle when your vehicle requires assistance or servicing;

2.5.5 Diagnostics information, for the purposes of identifying and troubleshooting problems with your vehicle including software or connectivity issues; and

2.5.6 Repair and maintenance history, including service history, mileage, repairs, car part details and other similar information.

Information we may collect automatically when you visit our websites or apps

2.6 Our websites and apps may automatically collect certain types of information when you use them, for example your IP address, browser type, operating system, pages you visit on our website, which website you came from or go to and the date and length of your visit , device information, etc. We may use and evaluate such information for the purposes of website administration and understanding our customers better.

3.1 The Data provided by you will be used by us for the purpose for which it was requested, and for the following purposes:

3.1.1 Application, administration, continuation and termination of the use of our products or services, including the provision of updates on warranty and maintenance information on your vehicle;

3.1.2 Processing billing and payment, maintaining a credit history, determining amounts outstanding and where necessary, collection of outstanding payments;

3.1.3 Providing you with the BMW ConnectedDrive service, which includes but is not limited to:

(i) completing, managing and executing agreements concluded within the framework of BMW ConnectedDrive (including invoicing);

(ii) providing you with TeleServices , Intelligent Emergency Call, ConnectedDrive, eDrive, Real Time Traffic Information, Remote Services, Remote Software Upgrade, and Smart Maintenance services;

(iii) managing the commercial relationship with customers including the handling of requests raised for the BMW ConnectedDrive services;

(iv) optimizing the management and quality of BMW ConnectedDrive services;

(v) producing and analysing statistics and market studies (for marketing and quality control purposes) from the BMW ConnectedDrive services; and

(vi) fight against fraud in the automobile sector and the improvement of security.

For more information on the BMW ConnectedDrive service, you may request a copy of the BMW ConnectedDrive Terms and Conditions by email to crm@bmwhk.com.

3.1.4 Considering or fulfilling requests or application of any nature submitted by you, whether online, over the phone or through other channels;

3.1.5 Handling and following up service calls, enquiries and complaints;

3.1.6 Verification of your identity, including for the purposes of vehicle registration, insurance registration, and for test drives of our vehicles ;

3.1.7 Administering contests, sweepstakes, draws and other promotional offers conducted by us, including disclosing the winners of any such contests;

3.1.8 Enforcement of any contract entered into between you and MINI HK;

3.1.9 Updating and enhancing our records;

3.1.10 With your consent (see section 4 on Direct Marketing below), conduct direct marketing including but not limited to promoting, marketing or selling of our vehicles and related products and/or services and contacting you directly to inform you of new services or opportunities;

3.1.11 Conducting surveys and research, statistical analysis and behavioural analysis, to enable us to better understand the demographics and preferences of our customers and provide products/services better tailored to your needs;

3.1.12 Conducting customer profiling and analytics of your purchasing preferences;

3.1.13 Meeting our legal obligations and making required disclosures to any governmental, legal or regulatory authority within or outside of Hong Kong in accordance to any legal requirements which apply to us;

3.1.14 Complying with any recall notices or directives issued by the manufacturer or the Hong Kong Transport Department;

3.1.15 Investigation and settlement of claims and disputes, defending and/or protecting the rights or property of MINI HK, our affiliates within the Sime Darby Motor Group, BMW AG and affiliates including BMW Financial Services Hong Kong Limited, our customers and users, and ensuring the safety of MINI HK, our affiliates, our customers and users;

3.1.16 Compliance with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Sime Darby Motor Group, BMW AG and affiliates including BMW Financial Services Hong Kong Limited, and/or any other use of data and information in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities or actions adverse to our interests and the Sime Darby Motor Group; and

3.1.17 Any other purposes relating to any of the above.

3.2 Where requested, we will collect and submit as applicable a copy of your government identification to the Transport Department of the Government of the HKSAR for vehicle registration and licensing purposes, and to the relevant insurance company for applicable insurance arrangements. We will also request your government identification for identity verification purposes for test drive arrangements, but not for any other purposes.

4.1 We intend to use and transfer your Data for the purposes of conducting direct marketing, and may not do so unless we have received your consent or written consent (in the case of transfer).

4.2 With your consent or written consent (in the case of transfer) (which includes an indication of no objection), we may:

4.2.1 use your contact information (including name, phone number, email and/or postal address) for direct marketing purposes;

4.2.2 conduct direct marketing (including but not limited to sending newsletters) in relation to the following products, services and promotional events of MINI HK, BMW AG, BMW Financial Services Hong Kong Limited, Sime Darby Motor Group, and brands owned by Sime Darby Motor Group (including but not limited to BMW, MINI, Rolls Royce, Peugeot, Suzuki, Mitsubishi, Fuso, JAC, Denso, Sime Darby Managing Agency (Hong Kong) Limited, Sime Darby Insurance Brokers (Hong Kong) Limited, Sime Darby SD Charging), etc. and our selected business partners with whom we may collaborate from time to time;

(i) New or used cars;

(ii) Car valuation services;

(iii) Car launches, test drives, designated customer gatherings and related lifestyle events;

(iv) Financing and insurance services;

(v) BMW ConnectedDrive products and services;

(vi) Events, contests, sweepstakes, programs and promotions;

(vii) Discounts, loyalty, privilege, co-branding and gifts;

(viii) Holiday and birthday greetings; and

(ix) Updates on warranty and maintenance information and aftersales programmes and purchases.

The above products, services and promotional events may be provided by us, our affiliates or our joint promotion collaborators.

4.3 If, in future, you wish to stop receiving direct marketing materials, you may, at any time, request that we cease to use your Data for direct marketing purposes by visiting the following link to unsubscribe https://www.bmwhk.com/en/ssl/unsubscribe.html . You may also inform us in writing by email to crm@bmwhk.com.

5.1 We do not sell or trade your Data with third parties and we strive to protect your privacy. Your Data may however be transferred within or outside Hong Kong to the following transferees:

5.1.1 Other companies (including branch offices, subsidiaries, holding companies, associated companies or affiliates) within the Sime Darby Motor Group, BMW AG and its affiliates including BMW Financial Services Hong Kong Limited;

5.1.2 Governmental, legal or regulatory departments or authorities;

5.1.3 Where you use the BMW ConnectedDrive Support Services, we may transfer your vehicle's technical data, and the name and email address provided by the vehicle owner and/or users to our designated service providers for such purposes;

5.1.4 Any agent, contractor or third party service providers who provide services to us, including but not limited to administrative, accounting, call centre, customer service, data hosting, data processing, legal, logistics and distribution, financial, debt collection, surveys, payment, telecommunications, regulatory compliance, advertising, marketing and research, website, and other professional services ;

5.1.5 Insurance companies for the application of car insurance and related insurances;

5.1.6 Credit information or financial service companies for the application of financial services;

5.1.7 A third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation;

5.1.8 Any of our actual or proposed assignees or transferees of our rights during our, or the Sime Darby Motor Group's re-construction, re-organization or other similar situations; and

5.1.9 Any person or authority to whom we are under an obligation to make disclosure under the requirement of any law, regulations, rules, codes of practice or guidelines binding on or applicable to us or any affiliate within the Sime Darby Motor Group.

6.1 Our employees and service providers designated to handle Data will be instructed to do so only in accordance with this privacy policy.

6.2 We shall take reasonable measures to keep your Data as accurate, complete, secure and up-to-date as is necessary for the purposes for which it is to be used. Data that is used on an ongoing basis, including information that is disclosed to third parties (please see section 5 for details), will generally be kept accurate and up-to-date. You can update or correct the Data held by us in accordance with section 10 below.

7.1 We retain your Data for as long as necessary for the purposes set out in this Privacy Policy, unless otherwise required or permitted under applicable law. Where we no longer require your Data for the purposes under this Privacy Policy or applicable law, we will take appropriate steps to securely delete or destroy your Data.

8.1 When you access our website, we store information about your visit in a small text file called a "cookie" on your hard disk to:

8.1.1 Recognize you whenever you visit this website;

8.1.2 Obtain information about your preferences, viewing and browsing behaviour, online movements and use of the Internet;

8.1.3 Keep track of the items stored in your shopping basket and take you through the checkout process;

8.1.4 Carry out research and statistical analysis to help improve our services and to help us better understand our visitor and customer requirements and interests;

8.1.5 Target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests;

8.1.6 Make your online experience more efficient and enjoyable; and

8.1.7 Enable tighter security.

8.2 Only information that you have provided will be stored in the cookie, and only the website which created the cookie can read it. This does not allow it access to the rest of the computer.

8.3 You can configure your Internet browser not to accept cookies, or to alert you every time a cookie is offered, letting you decide whether or not to accept it. However, some features of our website may not be available if you prevent the use of cookies.

9.1 Our Privacy Policy does not extend to third-party websites that may be linked from our website, or from any other broadcast affiliated with us. You should note that you visit these third-party websites or links at your own risk.

10.1 You may at any time request access to or update/correct your Data held by us. In accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of Laws of Hong Kong), we have the right to charge a reasonable fee for the processing of any data access request.

10.2 You may also at any time request that we cease to use your Data for direct marketing purposes, as mentioned in section 4 above.

10.3 To exercise any of your rights above, please contact: Customer Care Officer, BMW Concessionaires (Hong Kong) Limited, M/F, BMW House, 163 Matauwei Road, Kowloon, Hong Kong.  

11.1        We may revise this privacy policy from time to time, and we will provide notifications and/or obtain consents as required by applicable law.  We encourage you to review our most up-to-date privacy policy from time to time at https://www.bmwhk.com/en/footer/metanavigation/legal-disclaimer-pool/privacy-policy.html.

12.1       In the event of any inconsistency between the Chinese version and English version of this Privacy Policy, the English version shall prevail.