Customer Personal Information Privacy Statement

Bentley Motors China
Volkswagen Group Import Co., Ltd.
Customer Personal Information Privacy Statement
Last Update: [2020.09]


Volkswagen Group Import Co., Ltd. (hereafter “VGIC”) is a national sales company registered in the People’s Republic of China, with registered domicile at Room 316, Kaili Building, No.188 Tianbao Road, Tianjin Free Trade Pilot Zone , China. Bentley Motors China is a division of VGIC, which has been granted the exclusive right to import the products of Bentley Motors Limited to the People’s Republic of China.

This VGIC Customer Personal Information Privacy Statement (hereafter “Statement”) applies to VGIC, VGIC affiliates, and VGIC authorized entities. It covers personal information collected from VGIC customers (including car owner, car user, potential customers, and other customers) through daily business operations, and the use, storage, sharing, transfer and otherwise processing of our customer’s personal information.

Personal information under this Statement refers to all kinds of information saved in an electronic form or otherwise that can be used independently or in combination with other information to identify a natural person. VGIC affiliates refer to Volkswagen AG and its direct and indirect subsidiaries (including Volkswagen (China) Investment Co., Ltd. and Bentley Motors Limited), and VGIC authorised entities refer to authorized dealerships and qualified third-party service providers who process information on our behalf, such as call center service provider, IT service provider and marketing service provider.

If our customers have any questions or concerns about this Statement, please contact us through our customer service hotline number 4001 198 880, or email contactcenter@bentleymotorschina.com

This VGIC Customer Personal Information Privacy Statement (hereafter “Statement”) will provide our customers with the following information:

This Statement will provide our customers with the following information:
1. How we collect and use your personal information
2. How we protect your personal information
3. Customer rights
4. How we handle the children’s personal information
5. How your personal Information will be transferred globally
6. How the statement will be updated
7. How to contact us

Responsible handling of personal information is part of the social and legal responsibilities of VGIC, and we are fully aware of the fact that personal information is important to customers and will do our utmost to ensure the security and reliability of customer’s personal information. This Statement is made in order to ensure adequate protection of customer’s personal information under the Cyber Security Law and other applicable laws and regulations of the People’s Republic of China. We will protect our customers’ personal information following the principles of fairness and lawfulness, definite purpose of data processing, proportionality, transparency, consent, security etc. as defined in applicable laws and regulations and our internal policy. We will have in place appropriate technical and organizational security measures to protect the personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.

We highly recommended that you to review the specification below and please contact us (4001 198 880) in case of any questions.
 

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1. How We Collect and Use Your Personal Information

1.1. What Kind of Your Personal Information We Collect
With our customers’ consent, for the following purposes we may collect the following types of personal information respectively:
• For the purpose of sales and pre-sales service, we may collect the customer’s name, title, address, phone number, IP address, email address, driving license information, personal ID, social network ID, birthday, preferred dealership, interested vehicle Model, vehicle license plate number, contact preference, operations in our applications and on our websites, and the customer's opinions, inquiries and requests communicated to us.

  • For the purpose of aftersales service, we may collect the customer’s name, title, address, phone number, IP address, email address, driving license information, personal ID, social network ID, birthday, vehicle Model, vehicle VIN Number, vehicle license plate number, contact preference, operations in our applications and on our websites, and the customer's opinions, inquiries and requests communicated to us.
  • For the purpose of product improvement, we may collect the customer’s name, title, address, phone number, IP address, email address, driving license information, personal ID, social network ID, birthday, vehicle Model, vehicle VIN Number, vehicle license plate number, contact preference, operations in our applications and on our websites, and the customer's opinions, inquiries and requests communicated to us.

For the purpose of marketing activities, we may collect the customer’s name, title, address, phone number, IP address, email address, driving license information, personal ID, social network ID, birthday, vehicle Model, vehicle VIN Number, vehicle license plate number, contact preference, operations in our applications and on our websites, and the customer's opinions, inquiries and requests communicated to us.

We will only collect customers’ personal information in accordance with relevant laws and regulations.

With our customers’ consent, we may collect customers’ personal information through the following channels:

  • Official websites;
  • Brand campaign websites and events;
  •  VGIC or brand software applications;
  •  Social networking platforms;
  •  Brand service hotlines;
  •  Authorized dealers or other authorized entities of Bentley.

For the proper function of relevant websites, we may store a small piece of data generally named cookie on our customer’s computer or mobile device. With the cookie, we may be able to collect our customer’s personal information. The types of personal information collected will be limited to the types described under this Statement, and will only be used for purposes described under this Statement. By using our websites or mobile device applications, our customers consent to the use and storage of cookies on their computers or mobile device. Our customers can manage the type of personal information collected by the cookie or delete the cookie from their computers or mobile devices by using the relevant functions in their computers or mobile devices.

1.2. How We Use Your Personal Information
We collect customers’ personal information with a view to providing customers with products and services and improving our customers’ product and service experience.

Customers’ personal information will be used for the following purposes:

  • Sales and Pre-sales service: inviting customers come to dealer store for product introduction, arranging customers test drives, responding to customer enquiries and requests, processing customer orders and arranging car delivery after customer purchasing.
  • Aftersales service: providing customers with product and maintenance services, product repairing, call center, customer care, product warranties and recall services, and other necessary support services for the product. 
  • Product improvement: inviting customers for satisfaction survey, obtaining customers’ feedback on our products and services, investigating business intelligence (including by way of profiling), responding to customer complaints and continuously improving and developing our products or services to customers, including developing new functions and new contents, which enable us to meet our customers’ increasing expectations and requirements.
  • Marketing activities (optional): we may get in contact with customers to provide the customers with the latest product information and service information and invite customers for market research (including by way of profiling) or marketing campaigns. Customers can choose their preferred contact method, e.g. through email, SMS, postal mail, phone call or not to receive such information.

1.3. How We Store Your Personal Information
We treats our customers’ personal information very seriously. Our customers’ personal information is stored in databases which are housed in facilities using strict physical security measures and IT security measures with limited authorized access only. Personal information collected by us will be kept in our database only to the extent necessary to achieve the purpose.

Subject to our customers’ consent and security assessment for cross-border personal data transfer, our customers’ personal information may be stored in the databases located in the People’s Republic of China, the United Kingdom of Great Britain and Northern Ireland and the Federal Republic of Germany. These databases may be hosted on our behalf by qualified third party service providers.

We generally store and process your personal information for no longer than 6 years, or for as long as you are a vehicle owner if that is longer than 6 years. After such period, we will permanently delete your personal information.

1.4. How We Share, Transfer, Publicly Disclose Your Personal Information
    1.4.1 How we share and transfer your personal information

We will not share, transfer or disclose our customers’ personal information (name, title, address, phone number, IP address, email address, driving license information, personal ID, social network ID, birthday, preferred dealership, interested or purchased vehicle Model, vehicle VIN Number, vehicle license plate number, contact preference, operations in our applications and on our websites, the customer's opinions, inquiries and requests communicated to us, and the documents and records we have created during our dealings with and provision of services for the customers) with any other entities or individuals, unless under one of the following circumstances:

  • We may share or transfer our customers’ personal information upon explicit consent from our customers.
  • We may share or transfer our customers’ personal information according to laws and regulations, law enforcement or compulsory requirements from government agencies or courts.
  • We may, in the event of a reorganization, merger or sale, require the new company or organization that holds your personal information to continue to be bound by this Statement, otherwise we will require the new company or organization to obtain your authorization and consent again.

Our customers’ personal information may be shared or transferred among VGIC, VGIC affiliates and VGIC authorized entities for purposes of sales and pre-sales services, aftersales services (e.g. warranty and recall), product improvement and marketing activities (if the customer has opted in).

VGIC affiliates and VGIC authorized entities are required to strictly follow this Statement, and take necessary measures to ensure confidentiality and security of our customers’ personal information. We will not and does not allow third parties to share, transfer, or disclose our customers’ personal information for unauthorized purposes.

   1.4.2 How we publicly disclose your personal information

VGIC will not publicly disclose our customers’ personal information unless under one of the following circumstances:

  • We may publicly disclose our customers’ personal information upon explicit consent from our customers.
  • We may publicly disclose our customers’ personal information according to laws and regulations, law enforcement or compulsory requirements from government agencies or courts.
     
2. How We Protect Your Personal Information

We use technical and organizational security measures which are in line with widely recognized industry standard in order to protect the personal information we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorized persons.

The security measures include access control, system hardening, network vulnerability scan and management, awareness training, logging and security event management, transmission and storage encryption, which are updated as necessary to meet our business needs, changes in technology, and regulatory requirements. 

In case of personal information security incident, we will follow internal designed emergency plan to investigate and take all necessary measures to eliminate the potential risks and inform you in accordance with applicable laws and regulations. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

3. Customer Rights

Our customers have rights to access, correct, delete their personal information, change the scope of their authorization or cancel their accounts through online and offline contact channels with our brands. Please contact us through our customer service hotline number 4001 198 880, or email contactcenter@bentleymotorschina.com.

To ensure safety, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.
We will reply within thirty (30) days. If a customer is unsatisfied with the received reply, the customer may refer the customer’s complaint to the relevant competent authorities. Upon queries from our customer, we will endeavor to provide the customer with information about relevant authorities which may be applicable to the customer’s particular circumstances.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. For those that are unreasonably repeated, require excessive technical means (for example, the need to develop new systems or fundamentally change current practices), bring risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes) request, we may decline your request.

In the following situations, we will not be able to respond to your request:

a) When it is related to personal information controllers fulfilling obligations stipulated by laws and regulations;

b) When it is directly related to national security and national defense security;

c) When it is directly related to public safety, public health, and major public interests;

d) When it is directly related to criminal investigation, prosecution, trial and execution of judgments;

e) When the personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuse of rights;

f) In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;

g) When responding to the request of the personal information subject will cause serious damage to the legal rights of the personal information subject or other individuals or organizations;

h) When it is involving trade secrets.

4. How we handle the children’s personal information

We do not knowingly solicit or collect personal information from children below the age of 14 without first obtaining parental consent in accordance with applicable laws. If we discover that we’ve accidentally collected information from a child below 14, we will remove that child’s information from our records as soon as feasibly possible. We do not knowingly use personal information from children for any purpose except to deliver the products that are designed to offer family-related or child-related products or services.

5.. How your personal Information will be transferred globally

Subject to our customers’ consent, the following types of customer personal information may be shared with, transferred to, accessed or otherwise processed by VGIC affiliates or authorized entities in the Federal Republic of Germany and the United Kingdom of Great Britain and Northern Ireland: the customer’s name, title, address, phone number, IP address, email address, driving license information, personal ID, social network ID, preferred dealership, birthday, interested or purchased vehicle Model, vehicle VIN Number, vehicle license plate number, contact preference, operations in our applications and on our websites, the customer's opinions, inquiries and requests communicated to us, and the documents and records we have created during our dealings with and provision of services for the customers. We will ensure that our customers’ personal information receives protection from VGIC affiliates and authorized entities in accordance with this Statement.

6. How the statement will be updated

We may update this Statement. When we post changes to this Statement, we will revise the update date at the top of this Statement. For important updates, we will also notify our customers via email, telephone, push notification or other methods. We encourage our customers to review our VGIC Customer Personal Information Privacy Statement from time to time to learn how we are protecting our customers’ personal information.

7.. How to contact us

If our customers have any questions or concerns about this Statement or if our customers would like to make a complaint about a possible breach of relevant laws and regulations, please contact us through our customer service hotline number 4001 198 880, or email contactcenter@bentleymotorschina.com.

Bentley
Volkswagen Group Import Co., Ltd.