1. Introduction
This Privacy Notice applies to the collection and processing of personal data in connection with the provision of Hyundai Bluelink services ("Services") via the car’s head unit and the Hyundai Bluelink app (“App”) to you (“User”, “you”).
We take your privacy very seriously and will process your personal data only in accordance with applicable data protection and privacy law.
We may change and/or supplement this Privacy Notice at any time. Such changes and/or supplements may be necessary in particular due to the implementation of new technologies or the introduction of new services. We will publish the changes on our websites and/or in the car’s head unit and in the App.
Any data processing regarding the registration of the underlying Bluelink Account (including data such as your name, your email address, your date of birth, your mobile phone number) is subject to separate Privacy Notices for the Bluelink Account.
2. Data Controller
The responsible data controller for any personal data collected and processed in connection with the provision of the Services is PT Hyundai Motors Indonesia, incorporated and registered in Indonesia whose registered office is at Wisma Mulia, Suite 2502, 25th Floor, Jl. Jend.Gatot Subroto No. 42 Jakarta 12710 (“Distributor”). The Distributor is the operator of the Services in relation to you while the Distributor will be acting as joint controller with PT. Hyundai Autoever Indonesia ("Hyundai") with registered office in Graha Surveyor Indonesia Unit 1903B 19th Floor, JL Jend Gatot Subroto Kav 56, Kuningan, South Jakarta . Distributor and Hyundai will be jointly referred to “we” or “us”.
The Distributor will provide you with guidance by e.g. providing support services when actively using the Services, while Hyundai will steer the provision of the App and the underlying services on an organizational and technical level. Both, Distributor and Hyundai may use your personal data for further purposes as described below. Distributor shall be the contact point for any data subject request concerning the processing of personal data in connection with the Services. However, data subject shall remain entitled to exercise his or her rights under the national data protection laws in respect of and against each of the controllers.
Further company details on each of Distributors can be taken from the respective Distributors website accessible under hyundai.com/id/id
Hyundai and Distributor enter into an agreement governing the processing of personal data. Upon request, Distributor will provide information on the essence of such agreement to the User.
3. Contact Point and Data Protection Officer
3.1. If you have any questions about or in connection with this Privacy Notice or the exercise of any of your rights, you may contact the Distributor’s customer call center. You will find the respective contact details under.
Hyundai Call Center 0 800 1 878
878
Bluelinkid@hyundaimotor.co.id
4. Purposes, Legal Basis and Categories of Data
In connection with the Services we collect and process your personal data only insofar as the collection and processing is necessary for the conclusion or the performance of the Bluelink contract, where required by Law of the Republic of Indonesia No. 11 of 2008 on Informatics and Electronic Transactions as amended by the Law of the Republic of Indonesia No. 19 of 2016 on the Amendment to the Law of the Republic of Indonesia No. 11 of 2008 on Informatics and Electronic Transactions, the Regulation of the Minister of Communication and Informatics of the Republic of Indonesia No. 20 of 2016 on Protection of Personal Data in Electronic System and Law of the Republic of Indonesia No. 27 of 2022 on Personal Data Protection and/or any other applicable laws in relation with the personal data protection, where based on a consent, or where covered by legitimate interests of us or third parties. For further details on individual Services, please consult the respective service description in the Bluelink Terms of Use – Head Unit and the Bluelink Terms of Use - Application. The (personal) data described in Sections 4.1, 4.2, 4.3 and their subsections below is collected directly from your vehicle (e.g. its sensors and related applications as made accessible through the head unit) or, were made available by you through the App (e.g. by entering certain personal data into the User via the App) and is processed in connection with the Services.
The data described in Sections 4.1, 4.2, And 4.3 and its subsections below is required to provide the Services. Without the respective information, the Services cannot be performed.
We will further analyze and improve the Services to develop new mobility and mobility related products and/or services, to secure our products and/or to improve our Services. For these purposes, we automatically analyze the data collected when providing Services based on statistical and mathematical models to identify potential for improvements. More details are provided in Section 4.3. The legal basis for any such a processing is the Regulation of the Minister of Communication and Informatics of the Republic of Indonesia No. 20 of 2016 on Protection of Personal Data in Electronic System and Law of the Republic of Indonesia No. 27 of 2022 on Personal Data Protection.
In this context we may process your personal data for the purpose of monitoring our products, providing sufficient IT security standards or to defend us or third parties against product liability and other legal claims made with regard to our products and services. As far as such a processing is not required by law already, the legal basis for any such processing is the Regulation of the Minister of Communication and Informatics of the Republic of Indonesia No. 20 of 2016 on Protection of Personal Data in Electronic System and Law of the Republic of Indonesia No. 27 of 2022 on Personal Data Protection. We process your personal data for other purposes only if obligated to do so on the basis of legal requirements, if you have consented to the respective processing, or if the processing is otherwise lawful under applicable law. If processing for another purpose takes place, Hyundai and/or Distributor will provide you with additional information, if appropriate. Neither Hyundai, nor Distributor do engage in automated decision-making including profiling in connection with the Services unless you have been expressly notified of such automated decision-making including profiling by other means.
4.1. Vehicle Diagnostics
Vehicle diagnostics gathers active trouble codes from all control units integrated in your vehicle together with the VIN. The active trouble codes and VIN will be sent to our server for further analysis. Within the section vehicle diagnostics of the on-board menu you can view all active trouble codes for your vehicle. This data is used to provide you information concerning whether there is any issue with your vehicle.
As far as Distributor or Hyundai are required to do so by law we might process such data for the purpose of monitoring the products and to comply with product security requirements.
For processing the above data for the purposes of product improvement and development see section 4.5 below.
4.2. Further purposes in regard to the App
4.2.1. Remote Services
Through the App the following Remote Services will be provided and will be activated as a pre-setting if not deactivated separately or entirely:
a) Remote lock and unlock (lock and unlock of the vehicle doors; all Hyundai vehicles)
b) Remote climate control (remote temperature setting and activation of A/C; all Hyundai vehicles)
c) Find my car (function to localize the parking position of the Hyundai vehicle on the integrated map; all Hyundai vehicles)
d) Vehicle report (provides information about total Hyundai vehicle usage and diagnostics; all Hyundai vehicles)
e) My trips (provides information about Hyundai vehicle usage per month/day; all Hyundai vehicles)
f) Status (provides information about Hyundai vehicle status (such as but without limitation to open doors, open trunk, vehicle image etc.); all Hyundai vehicles)
g) Push notifications for certain use cases (the application sends to your mobile phone push notifications in certain cases (for example but not limited to: Hyundai vehicle is unlocked and burglar alarm activation in your Hyundai vehicle etc.); all Hyundai vehicles)
h) User profile setting (user can upload sefl-portrait for profile picture from album or camera, adjust vehicle settings in applications related to sound settings, display settings, buttons/touchpads, general settings, vehicle settings, device connection settings as well as view/delete active self-portrait of driver profiles via bluelink app; not all Hyundai vehicles)
All services can be deactivated separately.
In order to provide the Remote Services once connected through the App a connection will be established between the vehicle and our backend which requires the processing of certain vehicle related data such as the vehicle SIM card’s IP address, the VIN and further App user related data (such as the User device’s IP address, PIN and further user account information such as user name).
The provision of the Remote Services requires the collection and processing of certain vehicle related data such as the vehicle’s geolocation and positioning data (e.g. longitude/latitude, address for “Find my Car”) and vehicle related technical data (e.g. vehicle status data such as “ignition on/off”, light status, lock status for other Remote Services as listed above).
4.2.2. Sharing the Remote Services with another user
You can share the Remote Services with another user through the “Request to Share Car” function in the application. When doing so, certain vehicle and user account related data such as primary User’s PIN, VIN, user name, secondary user’s phone number will be processed by us to initiate and process the sharing request. Share request information such as primary User name and PIN will be transmitted to and processed in the secondary user’s App. The secondary user can use the App in the same way as the primary User. He/she can also use the “Find my Car” option.
Please note that by this you will share all of your data, excluding your log-in details, stored in the App with another user. This function can be deactivated by you at any time. This results into the stop of the sharing and all data is deleted on the other user´s application.
4.3. Product Improvement / Development
Hyundai will collect telematics data regarding performance, usage, operation, and condition of vehicle from the vehicle and or the app for the purposes of product improvement / development and may transfer such data to Distributor to allow it to process the data for these purposes as well.
The data which is used for this purpose is limited to technical data and which does not allow the respective team members to identify a natural person. The data used to improve / develop for example the powertrain, hybrid/EV-vehicles and other car functions include ABS, ABS status, steering wheel info, parking brake, traction control system, cluster information, buckle, acceleration, battery condition, door key lock, head lamp, turn signal, light system, hands free trunk system, seat height, sunroof, wiper, navigation on/off and similar technical data and trouble codes as mentioned in section 4.1.
5. Data of other data subjects, sale or transfer of the vehicle to a third party
In case of letting the car to another person or where data of other data subjects (such as a co- driver) might be collected during the use of the Services you have to ensure that the data subjects are properly informed on the data processing as described herein.
In case of sale or permanent transfer of the vehicle to a third party, please ensure that none of your personal data can be accessed through the head unit (e.g. by erasing trip data or destinations in the settings).
You can disconnect the vehicle from a Bluelink app (may it be your own or another person’s app) by deactivating Hyundai Bluelink in the on-board menu. By deactivating Hyundai Bluelink in the on-board menu, your driving data will no longer be visible in the application and your vehicle is disconnected from the application. If you do not disconnect the vehicle the data might still be accessible through the app. Please be informed that your account data in the application will not be deleted until you delete your account.
6. Your Rights
If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Pursuant to applicable data protection law you may have the right to: request access to your personal data, request rectification of your personal data; request erasure of your personal data, request restriction of processing of your personal data; request data portability, and object to the processing of your personal data. Please note that these aforementioned rights might be limited under the applicable national data protection law.
You also have the right to lodge a complaint with a data protection supervisory authority. To exercise your rights please contact us as stated above.
6.1. Right of Access: You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
6.2. Right to rectification: You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
6.3. Right to erasure ("Right to be Forgotten"): Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
6.4. Right to restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
6.5. Right to data portability: Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
6.6. Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation and we can be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.
7. Recipients and Categories of Recipients
Due to their role as joint controller when offering Bluelink Services, Distributor as well as Hyundai will receive personal data. Any access to your personal data at Hyundai and Distributor are restricted to those individuals that have a need to know in order to fulfill their job responsibilities. Hyundai and Distributor may transfer your personal data for the respective purposes to the recipients and categories of recipients listed below.
•Hyundai - Hyundai receives personal data as to its role as technical operational body of the Bluelink services and will transmit certain data to Distributor as described above (e.g. for product development purposes).
•Other Private third parties – Certain private bodies who help us in offering the Services and will receive personal data for that matter. We i.a. rely on telecommunication services provided by telecommunication providers (singtel / Telkomsel).
•Data processors – Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data on behalf of Hyundai under appropriate instructions as necessary for the respective processing purposes. The data processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data, and to process the personal data only as instructed.
- The data processor for Bluelink is PT Hyundai Autoever Indonesia, which addressed at Graha Surveyor Indonesia, 19th Floor, Unit 1903B, Jl. Jend. Gatot Subroto Kav. 56, Kuningan Timur, Setiabudi, Jakarta Selatan – Indonesia.
- The data processors for call center services are affiliates of Hyundai, which are located in the Indonesia.
•Governmental authorities, courts, external advisors, and similar third parties that are public bodies as required or permitted by applicable law.
