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 Wisma Mulia, Suite 2602, 26th Floor, Jl. Jenderal Gatot Subroto No. 42 Jakarta 12710. 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.
4. Purposes, Legal Basis and Categories of Data
4.1. Our processing of your personal data
4.1.1. Provision of the Bluelink Services
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. 27 of 2022 on Personal Data Protection in Electronic System (“PDP LAW”) 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.
We collect and process your personal data in connection with the Services only insofar as the collection and processing is:
• necessary for the conclusion or the performance of the Bluelink contract (Art. 20 (2) b PDP LAW),
• where required by law (Art. 20 (2) c PDP LAW),
• where based on a consent (Art. 20 (2) a PDP LAW), or
• where it is necessary for the purposes of legitimate interests of us or third parties (Art. 20 (2) f PDP LAW).
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.
All (personal) data described in Sections 4.3 and 4.4 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 4.3 and 4.4 and its subsections below is required to provide the Services. Without the respective information, the Services cannot be performed.
4.1.2. Processing for other purposes
Apart from the provision of the Services, we will process your personal data also for other purposes as further described below.
• Product improvement/development: 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 4.4.
The legal basis for any such a processing is Art. 20 (2) f PDP LAW (legitimate interests of Hyundai and Distributor to process your personal data to develop and improve our Services).
• Monitoring of products/ product liability: 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 (Art. 20 (2) c PDP LAW), the legal basis for any such processing is Art. 20 (2) f PDP LAW (legitimate interests of Hyundai and Distributor to process your personal data to develop and improve our Services).
• Other purposes: We process your personal data for other purposes only if obligated to do so on the basis of legal requirements (Art. 20 (2) c PDP LAW, if you have consented to the respective processing or if the processing is for the needs of the other party who legally binded to you, under applicable law. If processing for another purpose takes place, Hyundai and/or Distributor will provide you with additional information, if appropriate.
• No automated decision-making: 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.
4.2. Provision of Bluelink Services – Vehicle infotainment system
4.2.1 Weather
In order to provide you our Local weather information based on your current location, it requires the collection and processing of your Vehicle Identification Number (VIN), geolocation data (e.g. GPS coordinates for “weather”).
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
Services may not be available depending on the vehicle or smartphone model.
4.2.2. Voice Command
Voice Command enables you to use spoken commands to access and control the infotainment system. For this function, we guarantee that your personal data (voice) are not processed and sent to our Bluelink cloud environment but there is available server for your voice recognition.
Services may not be available depending on the vehicle or smartphone model.
4.2.3. 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. We process your personal data for Vehicle Diagnostics to perform our Services (Art. 20 (2) b PDP LAW).
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 (Art. 20 (2) c PDP LAW). For processing the above data for the purposes of product improvement and development see section 4.4 below.
4.2.4. Connected Routing
Connected Routing allows calculating more accurate traffic forecasting, more precise times of arrival and more reliable route recalculations by processing the relevant data on our Bluelink cloud environment instead of only on your infotainment system.
For this function the following categories of personal data are processed and sent to our Bluelink cloud environment: Your VIN geolocation data (GPS coordinates) and navigation data (e.g. real time traffic; pattern of traffic information).
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
Services may not be available depending on the vehicle or smartphone model.
4.2.5. Wireless Update
Wireless Update allows to provide the latest maps and software updates to your vehicle. As a service requested by you the Wireless Update is activated by default and can be turned off by deactivating Bluelink connectivity via your infotainment system.
For this function the following categories of personal data are processed and sent to our Bluelink cloud environment: Your VIN, head unit manufacturer, head unit model, head unit firmware version, head unit system version, mobile network operator, vehicle model name, vehicle model year, vehicle region and your selected language.
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
Services may not be available depending on the vehicle or smartphone model.
4.2.6. Bluelink User Profile
Bluelink User Profile allows you to save various vehicle settings in our Bluelink cloud environment and apply them to different vehicles. If two or more drivers use the same vehicle but prefer different settings (e.g. for audio or map view etc.), these individual settings can be stored individually in up to two user profiles plus one guest profile per vehicle.
For each user profile the following categories of personal data are processed and sent to our Bluelink cloud environment: Vehicle Identification Number (VIN) of your vehicle and the target vehicle (if appropriate), driver number, account number, phone number, user picture, profile data as well as phone connection, Bluetooth settings, date/time settings, general settings, sound settings, display settings, settings, radio settings, vehicle settings, navigation settings and points of interest (POI).
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP Law).
Services may not be available depending on the vehicle or smartphone model.
4.2.7. Notification Centre
Through the Notification Centre we can send you important information about your vehicle. We will use this service only for important information. The information will appear as a pop-up in the infotainment system of your car. You can deactivate receipt of certain types of information in the settings or directly when receiving a pop-up.
For this function, the following categories of personal data are processed: read status; reading time.
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
4.2.8. Calendar
The purpose of collection and use is to provide schedule information service in conjunction with a calendar.
We collected ID of the calendar service (Google, iCloud etc.), authentication and schedule confirmation of the calendar service, information for synchronization *(access token, refresh token, client id, client secret, homeset url, ctag, event url, calendar display name, etag)
Immediate deletion when Bluelink Connected Service membership is withdrawn, account is deleted on the Bluelink Connected Service mobile application or when service is not provided anymore.
Service unavailable if you do not agree. You agree that our company collects and uses information for the above purposes.
The service provided by us is “linked” with the calendar (schedule) service, and if the service provided by the calendar service providers is interrupted or stopped, this schedule information service may be also disabled or discontinued without prior notice. We do not take any responsibility for failure / stoppage of this service for reasons of the calendar providers. You can use the schedule information service only if you agree to this.
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
4.3. Provision of Bluelink Services - App
4.3.1 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)
b) Remote engine start and stop (start and stop engine through Bluelink app; services may not be available depending on the vehicle or smartphone model)
c) Remote light and light-horn control (you can turn on hazard light and hazard light with horn for 30 second through Bluelink app)
d) Remote open and close window (you can remotely open or close window through Bluelink app; services may not be available depending on the vehicle or smartphone model)
e) Remote window ventilation mode (you can activate window ventilation mode through Bluelink app; services may not be available depending on the vehicle or smartphone model)
f) Remote charging (you can remotely activate the electric battery charging function; services may not be available depending on the vehicle or smartphone model)
g) Remote open & close charging port (you can remotely open or close charging port through Bluelink app; services may not be available depending on the vehicle or smartphone model)
h) Scheduled charging (you can remotely set the electric battery charging schedule (all Hyundai EV) including the target temperature; services may not be available depending on the vehicle or smartphone model)
i) Remote climate control (remote temperature setting and activation of A/C including activation of windscreen defogger, side mirrors heating, rear window heating and set temperature of passenger and driver seat; some services may not be available depending on the vehicle or smartphone model)
j) Find my car (function to localize the parking position of the Hyundai vehicle on the integrated map; all Hyundai vehicles)
k) Send to car (you can search online for points of interest (POI) and address data in order to send search results from your smartphone application to the infotainment system of your car; services may not be available depending on the vehicle or smartphone model)
l) My car POI (synchronizes your stored POI between the infotainment system and your App; services may not be available depending on the vehicle or smartphone model)
m) Last mile navigation (sends the current location of your car and information about your destination (e.g. name, address, geolocation data) to your smartphone to guide you from your parking spot to your destination; services may not be available depending on the vehicle or smartphone model)
n) EV Service (provide you information about the performance of your EV vehicle and helps you optimize and increase the efficiency of using your EV vehicle; services may not be available depending on the vehicle or smartphone model)
o) Valet parking mode (protects your private infotainment information by showing only the valet mode screen on your infotainment system unless you enter the password you have previously selected; sends information about current status of valet parking mode on/off, current vehicle location (GPS coordinates), valet mode start/end date, valet mode run/mileage/engine time, vehicle max speed, vehicle run distance and engine idle time to your smartphone)
p) Battery charging status (shows you the battery charging status of the electric engine; services may not be available depending on the vehicle or smartphone model)
q) Push notifications for certain use cases (the application sends to your mobile phone push notifications in certain cases (for example but not limited to: your Hyundai vehicle is unlocked and burglar alarm activation in your Hyundai vehicle, windows of your vehicle are open, rear seat alert (if equipped), engine idling alarm, high voltage battery discharge alarm, valet parking mode activated/deactivated etc.); some services may not be available depending on the vehicle or smartphone model)
r) 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; services may not be available depending on the vehicle or smartphone model)
You can deactivate all Remote Services 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).
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
4.3.2. Vehicle Status Information via Bluelink
Through the App we will provide you with the following Vehicle Status Information:
a) Vehicle report (provides information about total Hyundai vehicle usage and diagnostics)
b) Status (provides information about Hyundai vehicle status (such as but without limitation to open doors, open trunk, vehicle image etc.)
c) My trips (provides information about Hyundai vehicle usage per month/day)
Some services may not be available depending on the vehicle or smartphone model.
In order to provide you with the Vehicle Status Information once connected through the App, a connection is established between your vehicle and our Bluelink cloud environment which requires the processing of certain vehicle related data including your vehicle SIM card’s IP address, the VIN and further App user related data (your device’s IP address, PIN and further user account information such as your user name).
The provision of the Vehicle Status Information requires the collection and processing of certain data related to your vehicle (e.g. the driven time, mileage, vehicle average speed, vehicle max speed) and vehicle related technical data (e.g. vehicle status data such as engine on/off, door lock status etc. as further listed above).
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
4.3.3. 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, we process 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.
We process the personal data for sharing the Remote Services to perform our Services (Art. 20 (2) b PDP LAW) and for the purposes of our legitimate interests in delivering our Services (Art. 20 (2) f PDP LAW).
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.
4.3.4. Other location based services
a) View previous trips;
b) Send a destination to the car for a tour and add tourpoints to a planned tour;
c) Find your favorite and recent points of interest (POI);
d) Share your POI.
The provision of these Remote Services requires the collection and processing of certain vehicle related data such as the vehicle’s geolocation data (GPS coordinates).
We process your personal data to provide you with these other location based services to perform our Services (Art. 20 (2) b PDP LAW).
Some services may not be available depending on the vehicle or smartphone model.
4.3.5. Bluelink User Profile
Bluelink User Profile allows you to save various vehicle settings in our Bluelink cloud environment and apply them to different vehicles. If two or more drivers use the same vehicle but prefer different settings (e.g. for seat position, audio or map view etc.), these individual settings can be stored individually in up to two user profiles plus one guest profile per vehicle.
For each user profile the following categories of personal data are processed and sent to our Bluelink cloud environment: Vehicle Identification Number (VIN) of your vehicle and the target vehicle (if appropriate), driver number, account number, phone number, user picture, profile data as well as phone connection, Bluetooth settings, date/time settings, general settings, sound settings, display settings, settings, radio settings, vehicle settings, navigation settings and points of interest (POI).
We process your personal data for these purposes to perform our Services (Art. 20 (2) b PDP LAW).
Services may not be available depending on the vehicle or smartphone model.
4.3.6. Use of Touch ID and Face ID (iOS) or fingerprint and face recognition (Android)
You can use certain functions of our App with Touch ID or Face ID (iOS) or fingerprint and face recognition (Android) instead of your PIN.
Your biometric data are only stored locally on your smartphone device and is not transmitted to us and we cannot access this data. Only the information as to whether the verification of the biometric data was successful is transmitted to our App by a system function of your smartphone.
You can turn off the use Touch ID or Face ID (iOS) or fingerprint and face recognition (Android) at any time in our App.
4.4. 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, 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 4.2.3.
Legal basis for the processing of your data for these purposes is the legitimate interest of Hyundai in improving the Services and develop new products and services (Art. 20 (2) f PDP LAW; e.g. to identify technical malfunctions, analyze the performance of the vehicles or provide enhanced products or customer services).
In addition, your personal data as described above may be anonymised to perform our own analytics for improving and developing the products.
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.