Customer Personal Information Privacy Statement

Bentley Motors China

Volkswagen Group (China) Import Co., Ltd.

Effective Date: 01/09/2018

Bentley Motors China is a division of Volkswagen Group (China) Import Co., Ltd. (hereafter “VGIC”), the national sales company of Volkswagen Group in the People’s Republic of China, 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 regarding the collection, use, storage, sharing, transfer and disclosure our customer’s personal information, etc.

This Statement will provide our customer the following information:

1. Objectives

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. VGIC 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 VGIC internal policy. VGIC 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.

2. Scope

This 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, which include but not limited to vehicle sales and maintenance services, brand official websites, brand campaign websites, social media accounts, group or brand events, customer contact through brand official service hotlines, and car connectivity services, etc. 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.

3. Collection and Usage of Personal Information

VGIC collects customers’ personal information with the purpose of providing customers with products and services, improving our customers’ product and service experience, and enhancing our business operation efficiencies.

The collected customers’ personal information will be used for purposes including:

Sales and Pre-sales service: invite customers come to dealer store for product introduction, arrange customers test drive; arrange the car delivery after customer purchasing, etc.

Customer service: customers’ personal information will be used to provide customers product and maintenance services, product repairing, call center, customer care, car connectivity services (i.e. road site assistant) and other necessary support services for the product.

Product improvement: customers’ personal information will be used to continuously improve and develop our products or services, including developing new functions, new contents etc., which enable us to meet our customers’ increasing expectations and requirements.

Business operation: customers’ personal information could be used to investigate business intelligence in order to better support our business operations and keep us updated on the operational performance, i.e. how to install sufficient dealers according to the geographic spread of customers.

Marketing activities: we may get in contact with customers to promote customers the latest product information, service information, invite customers for marketing campaigns or get customers’ feedback of our products. Customers can choose their preferred contact method, e.g. through email, SMS, postal mail, phone call or not to receive such information from VGIC.

Satisfaction survey: we may get in contact with customers to invite them for satisfaction survey regarding our products or services, customers’ feedback are always important to us for our continuous improvement.

• 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.

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

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

For the proper function of relevant websites, VGIC may store a small piece of data named Cookie on our customer or potential customer’s computer or mobile device. With the Cookie, VGIC 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 customer or potential customer consents to the use and storage of cookies on his/her computers or mobile device. Our customers or potential 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.

With our customers’ consent, VGIC may collect the following types of personal information under different circumstances:

• When a customer raises inquiries online through brand official websites or mobile device applications, or a customer contacts our brand service hotline for information related to product, purchase of car, car service and repairing, or marketing campaigns etc., we may for purposes of answering the inquiries and providing relevant services, collect the your personal information, which may include but not limited to customer’s Name, Address, Phone Number, Email Address, Social Network ID, Birthday, Vehicle Model, Vehicle VIN Number, Vehicle License Plate Number, Contact Preference etc.

• When a customer submits test drive request online or contacts our brand service hotline for interested car product test drive, we may for purpose of providing the relevant services, collect the customer’s personal information, which may include but not limited to the customer’s Name, Address, Phone Number, Email Address, Driving License ID, Social Network ID, Birthday, Contact Preference etc.

• When a customer raises complaint online or contacts our brand service hotline with sales or aftersales complaints, we may collect for purpose of handling the complaints, the customer’s personal information which may include but not limited to the customer’s Name, Address, Phone Number, Email Address, Social Network ID, Birthday, Vehicle Model, Vehicle VIN Number, Vehicle License Plate Number, Contact Preference etc.

• When a customer registers online or off-line for Bentley campaign or event, we may collect for purpose of providing the relevant services, the customer’s personal information, which may include but not limited to the customer’s Name, Address, Phone Number, Email Address, Social Network ID, Birthday, Vehicle Model, Vehicle VIN Number, Vehicle License Plate Number, Contact Preference etc.

• When a customer gets in contact with VGIC authorized entities for production information, test drive, product or service purchasing, car maintenance or repairing, etc. we may collect for purpose of providing the relevant services, the customer’s personal information, which include but not limited to the customer’s Name, Address, Phone Number, Email Address, Social Network ID, Birthday, Vehicle Model, Vehicle VIN Number, Vehicle License Plate Number, Personal ID, Driving license ID, Contact Preference etc.

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

4. Storage of Personal Information

VGIC 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 internal security assessment for cross-border data transfer, our customers’ personal information may be stored in the databases which include:

• Bentley: Customer personal information database located in the People’s Republic of China, the United Kingdom of Great Britain and Northern Ireland, the Federal Republic of Germany;

5. Sharing, Transfer and Disclosure of Personal Information

VGIC will not share, transfer or disclose our customers’ personal information with any other entities or individuals, unless under one of the following circumstances:

• We may share, transfer or disclose our customers’ personal information upon explicit consent from our customers.

• We may share, transfer or disclose 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, transfer any and all personal information collected to the relevant third party.

• We may share or transfer our customers’ personal information with VGIC affiliates, and VGIC authorized entities for purposes of providing products, product improvement, providing services, service improvement or market communication. The VGIC affiliates, and VGIC authorized entities include but not limited to Volkswagen AG, Volkswagen (China) Investment Co. Ltd., Bentley Motors Limited (to understand how Bentley Motors Limited use your personal data, please visit www.bentleymotors.com/Privacy-Policy), brand authorized dealership, and service providers such as road side assistant service provider, call center service provider, connectivity service provider and marketing service provider etc.

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. VGIC will not and does not allow third parties to share, transfer, or disclose our customers’ personal information for unauthorized purposes.

For purpose of providing imported products and relevant services, upon our customers’ consent, our customers’ personal information may be shared with, transferred to or accessed by VGIC, VGIC affiliates or authorized entities in the Federal Republic of Germany, the United Kingdom of Great Britain and Northern Ireland, and the Republic of Italy. We will ensure that our customers’ personal information receives equivalent protection from VGIC affiliates and authorized entities as it does under this Statement.

6. 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. The contact channels are listed in section 9.

7. Information Security

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 are updated as necessary to meet our business needs, changes in technology, and regulatory requirements, i.e. Access Control, System Hardening, Network Vulnerability Scan and Management, Awareness Training, Logging and Security Event Management, Transmission and Storage Encryption.

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.

8. Children’s Privacy

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.

9. Privacy Questions

If our customers have any questions or concerns about VGIC Customer Personal Information Privacy 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.

All such communications will be examined and replied where appropriate as soon as possible. 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.

VGIC may update the VGIC Customer Personal Information Privacy Statement. When we post changes to this Statement, we will revise the update date at the top of this Statement and we will post the updated Statement on our websites. 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.