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Hyundai Connected Mobility Middle East and Africa Information Technology L.L.C. PRIVACY NOTICE - BLUELINK SERVICES

1. WHAT IS THIS PRIVACY NOTICE ABOUT?

The purpose of this privacy notice (“Privacy Notice”) is to inform you about the collection and processing of your personal data in connection with the provision of Hyundai Bluelink MEA services (“Bluelink” or “Services”) to you via the car’s infotainment system (this is the head unit of your vehicle) and the Hyundai Bluelink MEA app (“App”).
We take your privacy very seriously and will only process your personal data in accordance with applicable data protection laws.
Any processing of your personal data regarding the registration of the underlying Account (including personal data about you such as your name, email address, date of birth or mobile phone number) is subject to a separate privacy notice.

2. WHO IS RESPONSIBLE FOR PROCESSING MY DATA?

Hyundai Connected Mobility Middle East and Africa Information Technology L.L.C. with its registered office in P.O. Box 34406, L01, L02, Podium Level, U-Bora Tower, Business Bay, Dubai, United Arab Emirates (“Hyundai”) is the provider of the Services and responsible for the processing of your personal data as explained in this Privacy Notice.
Hyundai will be referred to as “we”, “our” or “us”.
We may use your personal data for the purposes as described below.
In regard to specific Services as listed in Section 6, we will act as a data controller.

3. HOW CAN I CONTACT THE CONTROLLER AND THE DATA PROTECTION OFFICER?

3.1. If you have any questions about or in connection with this Privacy Notice or the exercising of any of your rights, you may contact the Bluelink Support Centrre at the phone number +971-4-543-6888
You may also contact Hyundai by sending an email to BluelinkMEA@hcmmea.com.
3.2. Alternatively, you may also contact our data protection officer at the email address HCMMEA@hyundai.com, or by writing to:
c/o Data Protection Officer
Hyundai Connected Mobility Middle East and Africa Information Technology L.L.C.
P.O. Box 34406, L01, L02, Podium Level, U-Bora Tower, Business Bay, Dubai, United Arab Emirates

4. WHAT CATEGORIES OF PERSONAL DATA ARE PROCESSED, FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS?

4.1. OUR PROCESSING OF YOUR PERSONAL DATA
4.1.1. PROVISION OF THE BLUELINK SERVICES AND LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA
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 performance of contractual requirements. We need to use your personal data to fulfil a transaction that you have entered into or expressed interest in entering into (including the Bluelink contract). This includes accepting applicable terms and conditions or specific terms related to our Services. If you do not provide your personal data for these purposes, we may not be able to deliver our Services or enter into a contract with you, which could lead to the cancellation of a Service.,
– where required by law or regulatory. We may collect your personal data to comply with any applicable laws and/or regulations,
– where based on consent. Where we use your personal data obtained directly from you and your registration to our Services for marketing of our own similar products and/or services (e.g. to notify you about new Services or other similar Hyundai services), we rely on consent, or
– where it is necessary for the purposes of legitimate interests of us or third parties. We may process your personal data based on our legitimate business interests when we improve and operate our Services, when we detect and prevent fraud and abuse in order to protect the security of our customers, ourselves, or others.
For details on individual Services, please refer to the respective service description in the Bluelink Terms of Use.
All (personal) data described in Sections 4.2, 4.3, 4.4, 4.5 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 was made available by you through the App (e.g. by entering certain personal data via the App) and is processed in connection with the Services.
The data described in Sections 4.2, 4.3, and 4.4 and their subsections below is required to provide the Services pursuant to the conclusion or performance of contractual requirements, unless stated otherwise below. Without this information, the Services cannot be performed.
Furthermore, we will additionally process your Vehicle Identification number (VIN), the categories of Services that you have activated and the initial activation date. The legal basis is entering into a contract and performing our Services.
4.1.2. PROCESSING FOR OTHER PURPOSES
Apart from the provision of the Services, we will also process your personal data for other purposes as described below.
– Product improvement / development: We will analyse and further improve the Services in order to develop new mobility-related products and/or services, to make our products more secure and/or to improve our Services.
• For these purposes, we automatically analyse the data collected when providing Services based on statistical and mathematical models to identify potential for improvements if you have either activated all Services or selected the “Product/Service Improvement” service category in the privacy settings of your App. More details are provided in Section 4.5.
• The legal basis for any such processing is for legitimate interests of Hyundai to process your personal data in order to develop and improve our Services.
– Monitoring of products / product liability: In this context, we process your personal data in order to monitor our products, ensure sufficient IT security standards or to defend ourselves or third parties against product liability and other legal claims made with regard to our products and Services.
• Insofar as such processing is not required by law, the legal basis for any such processing is for the legitimate interests of Hyundai to process your personal data for the purposes as indicated above.
– Fulfilling legal obligations: We process your personal data in order to fulfil various legal obligations, in particular laws applicable to car manufacturers. Examples of such obligations include:
• provision of certain functionalities in the car such as the “eCall”, to the extent available ,
• reporting of certain information (i.e. VIN – ICCID matching information) to the relevant national authorities to fulfil various legal obligation;
• provision of information to courts or criminal prosecution authorities based on applicable criminal or administrative laws.
– Other purposes: We process your personal data for other purposes only if we are obliged 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 will provide you with additional information where appropriate.
4.1.3. NO AUTOMATED DECISION-MAKING
Hyundai does not engage in automated decision-making including profiling in connection with the Services unless you have been expressly notified otherwise by other means.
4.2. HYUNDAI ACCOUNT
To use our Bluelink Services it is necessary to create a Hyundai Account or to log in with an existing Hyundai Account. Hyundai Account will require your first and last name, phone number, email address, your country and date of birth.
For more information, please refer to the separate Privacy Notice for the Hyundai Account which can be accessed here: [web page link to Hyundai Account Privacy Notice]
4.3. PROVISION OF BLUELINK SERVICES – VEHICLE INFOTAINMENT SYSTEM
4.3.1. Live traffic: Live traffic information for calculating routes, including precise arrival times and displaying the traffic situation based on your current location (Service may not be available in certain countries)
4.3.2. Weather: Local weather information based on your current location
4.3.3. Live POI: Information on nearby POIs based on your current location
4.3.4. Camera / danger zone alerts (if legally permissible in your country): The system provides alerts in areas where accidents are particularly common and warns you about accident black spots or speed cameras.
The provision of the above Services requires the collection and processing of your Vehicle Identification number (VIN), geolocation data (e.g. GPS coordinates for live traffic information), the Integrated Circuit Card Identifier of your vehicle’s SIM card (ICCID) and a unique request ID for any transaction.
4.3.5. VOICE RECOGNITION
Voice recognition enables you to use spoken commands to access and control the infotainment system and to draft and send text messages via a connected mobile device.
For this function, the following categories of personal data are processed and sent to our Bluelink cloud environment: voice recording, geolocation data (GPS coordinates), point of interest (POI) and the Cerence user ID.
The latter is a unique ID for registration on the server of Cerence GmbH, Aachen, Germany, our data processor for these specific services.
There is no link between the Cerence user ID and the Vehicle Identification number (VIN) or any other identifiers, which means that Cerence GmbH cannot identify a natural person from the data transmitted to it.
Once you start your vehicle, voice recognition is activated as a presetting in its online mode. We process your personal data for the purpose of performing our Services.
When using online voice recognition, we process your personal data in our Bluelink cloud environment.
In addition, we collect voice samples and GPS coordinates and store them for up to 90 days in order to perform and improve the voice recognition service.
We process your personal data for the purpose of performing our Services and where related to the improvement of the Services, based on our respective legitimate interests.
When you use the online voice recognition function, your voice samples and GPS coordinates are processed by our service provider Cerence GmbH, Aachen, Germany (data processor) and its sub-processors, which may be located in countries outside the jurisdiction in which you reside.
You can deactivate online voice recognition and use the voice recognition services in an offline mode where no data is transmitted outside of your vehicle.
If you do not want us to process your voice samples and GPS coordinates, you can use offline voice recognition, which does not use your voice samples and GPS coordinates to improve the voice recognition service.

4.3.6. VEHICLE DIAGNOSTICS
Vehicle diagnostics gathers active trouble codes (i.e. the vehicle’s error messages) from all control units integrated in your vehicle together with the Vehicle Identification number (VIN).
The active trouble codes and VIN will be sent to our server for further analysis.
In the Vehicle diagnostics section of the infotainment system, you can view all active trouble codes for your vehicle.
We use this data to provide you with information concerning whether there is an issue with your vehicle.
We process your personal data for Vehicle diagnostics for the purpose of performing our Services.
To the extent that we are required to do so by law, we process your aforementioned personal data for monitoring the products and to comply with product security requirements
For information on the processing of the above data for the improvement and development of the products, see also Section 4.5 below.
4.3.7. CONNECTED ROUTING
Connected Routing allows 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 Vehicle Identification number (VIN), geolocation data (GPS coordinates) and navigation data (e.g. real-time traffic; pattern of traffic information).
We process your personal data for the purpose of performing our Services.
4.3.8. OTA (OVER-THE-AIR) UPDATE
OTA updates allow you to receive wireless (“over-the-air”) software updates (“OTA updates”) for the vehicle system as well as the map and infotainment system.
Your infotainment system will regularly check whether new software versions are available and automatically download any available software updates to your vehicle and prepare the respective installation.
You can choose whether you want to complete the OTA Update now or later.
However, if you turn off OTA updates, your vehicle or the services provided (such as security-related systems, infotainment system, Bluelink) may not function properly.
4.3.8.1. VEHICLE SYSTEM OTA UPDATE
We may provide you with OTA updates concerning the vehicle system for various reasons and purposes, in particular to remedy a defect within the warranty period, within the scope of the manufacturer’s guarantee or for other security-related reasons.
In this we will also ensure an efficient deployment and monitoring of OTA updates concerning the vehicle system.
For this purpose, the following categories of personal data are processed and sent to our Bluelink cloud environment: your Vehicle Identification number (VIN), usage history (OTA Update), diagnostic information (error codes, OTA result, software recovery result) and software version information (electronic control unit).
We process your personal data for the purpose of complying with the legal obligations of the vehicle manufacturer (e.g. in the area of product safety requirements)) as well as for performing our Services, and based on our legitimate interest to effectively steer our OTA update processes.
4.3.8.2. INFOTAINMENT OTA UPDATE
OTA update enables you to receive the latest maps and infotainment software updates for your vehicle.
For this function, the following categories of personal data are processed and sent to our Bluelink cloud environment: your Vehicle Identification number (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 the purpose of performing our Services.
4.3.9. NOTIFICATION CENTRE
The Notification Centre allows us to 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.
For this function, the following categories of data are processed: read status; reading time.
We process your personal data for the purpose of performing our Services.
4.3.10. LIKE FEATURE
The like feature for USB music allows you to select and create a playlist with your favourite songs.
You can like or unlike songs via the “thumbs-up” or “thumbs-down” button integrated in the music function of the infotainment system.
For this function, the following categories of personal data are processed: the name of the song, artist and album, the like/unlike information, VIN, location information (GPS), ambient air temperature, vehicle speed, weather (based on your current location) and time information.
We process all of the above personal data to perform our Services and for the purpose of pursuing our legitimate interest in improving and developing our products, including the Services.

4.4. PROVISION OF BLUELINK SERVICES – APP
4.4.1. REMOTE SERVICES
Some feature under this Services may differ depending on each vehicle's model/trim, and/or each country's regulation
Through the App we will provide you with the following remote Services. They will be activated as a presetting if not deactivated separately or entirely:
– Remote lock and unlock (you can lock and unlock the vehicle doors)
– Remote window ventilation (you can remotely open and close the windows of your vehicle for ventilation purposes)
– Remote horn and light (you can remotely activate both the headlights and the sound of the horn of your vehicle)
– Remote light (you can remotely flash the headlight of your vehicle)
– Remote charging (you can remotely activate the electric battery charging function; EVs only)
– Scheduled charging (you can remotely set the electric battery charging schedule including the target temperature; EVs only)
– Remote start & climate control (you can start the engine and set the temperature and activate the air conditioning remotely)
– Remotely open and close the charging door (you can open and close the charging door of your vehicle remotely; EVs only)
– Remote control of hazard lights / sidelights (you can turn off the lights remotely from the App when your vehicle is left with its hazard lights and/or sidelights on
– Remote battery conditioning (you can optimise the battery temperature in order to improve the charging performance of the vehicle; EVs only)
– Departure time (you can activate scheduled climate by setting the departure schedule; EVs only)
– Charging current (you can adjust the current supplied from the slow charger; EVs only)
– Find my car (you can localise the parking position of your Hyundai vehicle on the integrated map)
– 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)
– My car POI (synchronises your stored POI between the infotainment system and your App)
– 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 via Google Maps)
– First mile navigation (sends the current location of your car to your smartphone to guide you from your location (e.g. name, address, geolocation data) to your car via Google Maps)
– 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 the current status of valet parking mode (on/off), current vehicle location (GPS coordinates), the start/end date of valet mode, the run/mileage/engine time of valet mode, maximum vehicle speed, vehicle run distance and engine idle time to your smartphone)
– Battery charging status (shows you the battery charging status of the electric motor; EVs only)
– Push notifications for certain use cases (the application sends push notifications to your smartphone in certain cases, for example: your Hyundai vehicle is unlocked and the burglar alarm is activated in your Hyundai vehicle, the windows of your vehicle are open, rear seat alert, engine idling alert, high-voltage battery discharge alarm, climate control status, charging status, software update status, valet parking mode activated/deactivated, etc.)
You can deactivate remote services separately by category in the App. (“More” → “Service List” → “Remote”).
In order to provide you with the remote Services 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 Vehicle Identification number (VIN) and further user-related data in the App (your device’s IP address, PIN and other user account information such as your user name)
The provision of the remote Services requires the collection and processing of certain data relating to your vehicle including a password, your vehicle’s Vehicle Identification number (VIN) and geolocation data (e.g. GPS coordinates for “Find my car”), the Integrated Circuit Card Identifier of your vehicle’s SIM card (ICCID), address data and vehicle-related technical data (e.g. vehicle status information such as ignition on/off, vehicle speed, light status, lock status).
We process your personal data for the purpose of performing our Services.

4.4.2. VEHICLE STATUS INFORMATION VIA BLUELINK
Some feature under this Services may differ depending on each vehicle's model/trim, and/or each country's regulation.
Through the App, we will provide you with the following vehicle status information:
– Monthly vehicle report (provides you with information about the usage of your Hyundai car and diagnostics information covering the airbag, brakes, tyre pressure, etc.)
– Status update (provides you with information about the vehicle status of your Hyundai car regarding the distance to empty, fuel level, engine on/off, door lock status, climate control status, tailgate open/closed, bonnet open/closed, windows open/closed, sunroof open/closed 12V battery status, steering wheel heating on/off, side mirror heating on/off, defrost windscreen on/off, rear window heating on/off(all Hyundai vehicles); high-voltage battery charging status, scheduled charging on/off, charging door open/closed, (scheduled climate control on/off (EVs only))
– My trips (provides you with information about the Hyundai vehicle usage per month/day, including driven time, mileage, average vehicle speed, maximum vehicle speed)
– Energy consumption (provides you with information about your Hyundai vehicle’s energy consumption per day and per month, including the total and average energy consumption, driving distance and recuperation; EVs only)
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 Vehicle Identification number (VIN) and further user-related data in the App (your device’s IP address, PIN and other 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. vehicle location, the driven time, mileage, average vehicle speed, maximum vehicle speed) and vehicle-related technical data (e.g. vehicle status data such as engine on/off, door lock status, etc., as listed above).
We process your personal data for the purpose of performing our Services.
4.4.3. CAR SHARING
You can share the remote Services with other users through the “Request to Share Car” function in the application.
When you do so, we process certain vehicle-related and user account-related data such as your PIN, Vehicle Identification number (VIN), your username and the other user’s phone number to initiate and process your sharing request.
Share request information such as your name and PIN will be transmitted to and processed in the other user’s App.
The other user can use the App in the same way as you. He/she can also use the “Find my car” function.
We process all of the above personal data for sharing the remote Services for the purpose of performing our Services and for the purpose of pursuing our legitimate interest in improving and developing our products, including the Services.
Please note that when you use this service, your vehicle data will be shared with your shared users, except your login details.
You can stop sharing the Services at any time by removing any other user under the “Shared car settings”. Then the vehicle will be unlinked from the shared user’s Bluelink app [and we will delete all shared data on the other user’s App/ the other user will no longer be able to access your data on their App].

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