4.1 Hyundai Processing Your Personal Data
A. 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, in accordance 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); and/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 read the respective service description in the Bluelink Terms of Use – Infotainment System 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 infotainment system) 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.
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.
B. 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 Hyundai 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 long 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 Hyundai 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 Hyundai will provide you with additional information, if appropriate.
• No automated decision-making: Neither Hyundai nor Hyundai 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
A. 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 model or smartphone model.
B. 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 model or smartphone model.
C. 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 Hyundai 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.
D. 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 model or smartphone model.
E. Over-the-air (OTA) Updates
OTA software update (OTA: Over-The-Air) refers to the technology that updates software programs in your car at the push of a button using wireless communication. This ensures your car is always up-to-date with all the latest software for peak performance and driving pleasure including providing 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.
The OTA software service can update your car’s system software remotely, allowing you to keep your vehicle up to date without visiting a dealership. The service is only available on selected models and will expand across the range of Hyundai vehicles.
When a new update becomes available, the car automatically downloads the software over the air, and gets ready to update. You will be prompted to install the software update via the in-car infotainment screen.
Only proceed with the installation when you have enough time as the vehicle cannot be driven, charged, or sent remote commands via the Bluelink app when the software is installing. Depending on the software version, the update time can vary.
When the vehicle software has been updated successfully. You can check the details of the update through the QR code on the in-vehicle infotainment screen or by visiting the Hyundai website.
This requires compatible device & app installation, third party info, mobile data, network reception and GPS signal to operate.
For this function the following categories of personal data are processed and sent to our Bluelink cloud environment: Your VIN, infotainment system manufacturer, infotainment system model, infotainment system firmware 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 model.
F. 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 model or smartphone model.
G. Notification Center
Through the Notification Center we can send you important information about your vehicle.
We will use this service only for important information. The information will appear as a popup 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).
H. 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.
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 – Application
A. Remote Services
Through the App, the following Remote Services will be provided and will be activated as a pre-setting if not deactived separately or entirely:
a) Remote lock and unlock (lock and unlock of the vehicle doors through Bluelink app);
b) Remote start engine and stop engine (start and stop engine through Bluelink app);
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);
e) Remote window ventilation mode (you can activate window ventilation mode through Bluelink app);
f) Remote start charging and stop charging (you can remotely activate the charging function);
g) Remote open & close charging door port (you can remotely open or close charging port through Bluelink app);
h) Scheduled charging & climate control (you can remotely set the charging schedule and including set the climate temperature);
i) Remote start climate control & stop climate control (remote temperature setting and activation of A/C including activation of windscreen defogger, side mirrors heating, rear window heating and activate ventilated or heating of passenger and driver seat);
j) Find my car (function to localize the parking position of the Hyundai vehicle on the integrated map);
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);
l) My car POI (synchronizes your stored POI between the infotainment system and your App);
m) Last mile navigation (When you park your car somewhere before you reach your actual destination. If you are within 200m up to 2km from your destination, you can hand over the navigation from your car to the Bluelink app. Your smartphone will then guide you exactly to where you want to go);
n) EV Service (allows you to configure your EV vehicle such as setting charging limits, setting charging notifications, and setting the allowable level of use of the V2L feature);
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;
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 (if equipped), engine idling alarm, high voltage battery discharge alarm, valet parking mode activated/deactivated etc.);
r) User profile setting (user can upload sef-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; 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).
Services may not be available depending on the vehicle model
B. 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, open sunroof, EV efficiency etc.)
c) My trips (provides information about Hyundai vehicle usage per month/day)
d) View around my vehicle (allows you to take pictures around the vehicle using the vehicle's 360 camera via the Bluelink app. The image displays on the top view, front view, right view, back view, left view)
Services may not be available depending on the vehicle 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).
C. 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.
D. Other Location Based Services
a) View previous trips;
b) Send a destination to the car for a tour and add tour points 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).
Services may not be available depending on the vehicle model.
E. 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 model.
F. 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 Hyundai 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, vehicle control – seat settings, climate settings – climate duration, EV services – V2L electricity use settings, vehicle status – sun roof status open/closed, vehicle status – EV efficiency (since last reset, after charing, and current trip), notification – V2L start/completed, notification – AC/DC charging started notification, vehicle status – view around my vehicle and image stored as mentioned in section 4.3.B.
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.
