RR Connected Privacy Policy

Version Date: November 29, 2023

BCAT is committed to personal data protection and will only collect, use, transfer, store and retain your personal data in accordance with this Privacy Policy and applicable law.

Unless otherwise stated, capitalized terms used but not defined herein shall have the meanings set forth in the Terms and Conditions.

By using the App or click “I accept”, “Confirm”, “Next Step” or other similar options, you agree to this Privacy Policy.

If you have any questions in relation to this Privacy Policy, you may contact us via the contact information in “Contact Us” below.

If you do not agree to this Privacy Policy (as updated from time to time), please refrain from registering an account or using the App immediately.


Who is responsible for data collection and processing?

BCAT is the owner of the App. The App is developed by BCS for and on behalf of BCAT.

BCAT is mainly responsible for collecting and processing data through the App in accordance with this Privacy Policy.

BCAT may transfer data collected through the App (1) out of Hong Kong to BCS located in the PRC so BCS can provide data storage and data processing services for the App; (2) out of Hong Kong to BMW AG so that BMW AG can provide data processing services for the App, (3) out of Hong Kong to Rolls-Royce Motorcars Ltd in United Kingdom (“RRML”, a limited liability company incorporated under the laws of the United Kingdom) so that RRML can provide data processing services for the App, and (4) to other third-party service providers (including service map providers) located in or out of Hong Kong so they can provide services for the App, details which are set out in the Terms and Conditions.


What data is collected and how is such data used?

The services and features of the App (collectively “Services”) are designed to be a highly personalized mobile partner of your vehicle. In order to provide the personalized features of the Services, BCAT will collect, use, transfer, store and retain your personal data under the prerequisite that it complies with relevant laws and regulations.

Personal data is collected by BCAT for and only for the following purposes:

A. Account Registration and Login

To enable your use of the Services, BCAT will collect and process the following data categories:

To use the Services, you must register in the App by providing your first name, surname, gender, a mobile phone number, and set-up your account name and password. After registering, you will receive an OTP SMS with activation code (sent to your input mobile phone number). After input the activation code, your account will be successfully registered and activated.

In order to provide you with the RR Connected account login management service, your data will be transferred to the relevant BMW Group entities, which will process the data as the provider of such management service.

BCS is responsible for storing the data provided by you in relation to the registration. Such data will be transferred to the PRC and stored at facilities managed by BCS and will be stored separately from other personal data obtained by BCS.

Deletion

You can delete your account at any time. For details, please refer to the “Your data privacy rights” section.

B. Personalized features used to provide the Services

The Services collect and process the following data to provide users with the personalized features of the Services:

Please note that the above list may not be comprehensive. You can find in “Services and Features” section of the Terms and Conditions a complete list of services and features, detailed descriptions of each service and feature, types of data collected, used, and transferred through such service and feature, how these data can be deleted and how long they will be retained.

Deletion

You can delete your data in the App at any time. Depending on data category, they may be deleted in the following ways:

Consent

When you start the App for the first time (after downloading), you will receive a prompt asking whether you accept this Privacy Policy and whether you give us consent to collect and use specific types of data. Immediately before your first use of Services that require certain data from your mobile device, you will receive another prompt asking for your consent to collection and use of such data. If you decline such request, the relevant services and features of the App which require those types of data will be disabled.

If you choose “I accept”, “Confirm”, “Next Step” or other similar options to the above prompts, you will be deemed to have consented to allow the Services to collect and process the relevant types of data.

If you have expressed consent to the processing of your personal data for direct marketing and/or market research purposes or for profiling purposes, the same personal data will be processed for such purposes and to send you offers from BMW Group entities (within the limits of the specific consent form).

Opting out of data collection

You may opt out of data collection at any time. If you wish to continue using the App but opt-out of data collection for specific data types listed above, you should separately turn off location, calendar access, contact person access, camera access, photos access and notifications in the App’s settings menu or your mobile device’s settings menu.

Please note that if you opt out of any types of data collection, certain services and features of the App or the App itself will not be able to run.

In addition to turning off relevant settings, you may also delete the App together with all App data from your mobile device.

C. Assurance of product quality and development of new products

Beyond the provision of Services, the data collected under Section B will also be used to assure the quality of Services and development of new products and services for BMW Group entities. Based on the legitimate rights and interests of BMW Group entities, these processing activities are used to help us provide the highest quality of products and services, as well as to launch the latest innovative products.

In order to protect your data privacy, the data used to improve our products and create new services will be stored in a special anonymized form so others are unable to use the data to directly trace you or your vehicle.

The quality of the Services is constantly monitored. In the event a critical system defect / failure is detected, some data collected under Section B may be reviewed to help identify the cause and correct the problem. Access to data for such purpose is strictly limited and may only be used to resolve critical issues.

D. Fulfillment of the sales, service and administrative processes of BMW Group Entities

In order to optimize the customer experience and collaboration with dealers continuously, we create evaluations and reports based on certain data of you and we share these evaluations and reports with the applicable dealers. These evaluations are predominantly used for introducing appropriate measures (e.g. training courses for sales personnel) to improve the request and sales process We will create the aforementioned reports only in an aggregated and anonymized form, and the recipients of the reports will not be able to draw any conclusions about you personally.

BCAT is a company within the BMW Group entities. In part, we process your data in order to make the administration of the various companies within the BMW Group entities as efficient and successful as possible, including but not limited to common group accounting in accordance with international accounting regulations for companies (such as the International Financial Reporting Standards (IFRS)). In conducting these administration tasks, your data will be used in aggregated and anonymized form, and no one will be able to draw any conclusions about you personally.

E. BMW Group Entities’ legal obligations

BCAT will also use your personal data when required under applicable law, including but not limited to instances where we need to contact you because a recall or technical action is required for your vehicle.

In fulfilling our legal obligations, we will process your data for, including but not limited to, the following purposes:

We may also use your personal data for internal compliance management, such as to check whether we have fulfilled our disclosure obligation at the time you signed the contract for purchasing the relevant vehicle and whether the dealer has fulfilled all legal obligations.

BMW Group entities are subject to many other legal obligations. In order to fulfill these obligations, we may use your personal data as needed and, if necessary, transfer the data to the responsible authorities within the scope of statutory reporting obligations.

F. Data transmission to specific third parties

The Services include services and features that may require specific third parties to cooperate or provide support, such as sending requests to the map provider to retrieve the map image for your location. Unless otherwise specified in the Terms and Conditions, the data provided to such third parties will be anonymized.

Some services and features may require the transfer of your personal data to third-party service providers. By agreeing to this Privacy Policy and use the relevant services and features, you agree to us transferring your personal data to such third-party service providers. Please note that if you decline the request, you will not be able to use the relevant services and features. For details of transfer of your personal data to third-party service providers, please refer to respective description of each service and feature in the Terms and Conditions.

How is my personal data collected?

BCAT may collect your personal data in the following ways:


How is my personal data protected?

We protect your personal data using the most advanced technology. Amongst other things, we take the following measures to protect your personal data against misuse or any other form of unauthorized processing:


How long will my data be retained?

We retain your personal data only until its purposes have been met. For data that has multiple purposes, it is automatically deleted or transformed and stored in a form that it cannot be used to trace back to you as soon as the last purpose has been met.

How long your personal data is retained varies according to the type of personal data. You can find in “Services and Features” section of the Terms and Conditions the retention period of different types of personal data in relation to each service and feature.

In general, personal data retention period may be categorized as follows:


To whom will personal data be shared and how will such data be protected?

Your personal data is processed by BCAT employees, domestic sales companies, dealers, and our service providers within Hong Kong, PRC (and other jurisdictions as may be specified in the Terms and Conditions and this Privacy Policy) and in accordance with all applicable data privacy laws and regulations.


How to see and change privacy preference settings

You can see and change your privacy settings at any time in the settings menu. Depending on the vehicle model, you can also enter the privacy menu from your vehicle and change the settings related to the vehicle there.


Your data privacy rights

Right to access information:

You can view certain personal data collected by the Services in the App. The data in the App is part of what is displayed by the features that collect or use data.

If you have further enquiries about access to your personal data, you may contact us. We will process your data access request in accordance with applicable laws and regulations.

Right to correction:

You can correct or amend certain personal data collected directly in the App.

If you have further enquiries about the correction or amendment of your personal data, you may contact us. We will process your data correction or amendment request in accordance with applicable laws and regulations.

Contact Us

Please contact us by email customer.relationschina@rolls-roycemotorcars.com or call: phone number: +86 400 818 7979 (Monday to Sunday, 8:00 am to 8:00 pm)