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Policy Guide
  1. 1. What is this Privacy Policy about?
    Hyundai Connected Mobility GmbH (“HCM”, “we”, or “us”) is committed to protecting the privacy and the security of your personal data. Within this Privacy Policy you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what rights you have with regard to your personal data processed by us. This Privacy Policy applies to personal data that we collect through our website for the purposes described below. For more information regarding cookies and similar web-tracking technologies, please refer to our Cookie Policy. You are not obliged to provide your personal data. However, your personal data may be necessary for the provision of certain services and functionalities (for example, “contact us”, etc.). Therefore, without your personal data, we may not be able to provide the requested service.
  2. 2. Who is responsible for processing my personal data and how can I contact the controller
    Hyundai Connected Mobility GmbH, with registered office in Kaiserleipromenade 5, 63067 Offenbach am Main, Germany is responsible controller for the processing of your personal data. If you have any questions about or in connection with this Privacy Notice or would like to complain about our handling of your personal data or exercise any of your rights, please contact us by using the above contact details or you may also contact us by email to hcm.dataprotection@hyundai-europe.com. Alternatively, you may also contact the Data Protection Officer of HCM: Hyundai Connected Mobility GmbH, c/o Data Protection Officer of Hyundai Connected Mobility GmbH, Kaiserleipromenade 5, 63067 Offenbach, Germany.
  3. 3. What categories of personal data are processed, for what purposes and on what legal basis?
    3.1. Informational use of our website
    When you visit our website for informational reasons, i.e. without registering for any of our provided services and without providing us with personal data in any other form, we automatically collect your data in order to provide you with our website and to ensure system stability and efficiency and to implement proper safeguards as to the security of our website and services.
    Purpose of processing:
    • To provide access to the contents on our website;
    • To ensure system stability and efficiency;
    • To implement proper safeguards as to the security of our website and services.
    Scope of personal data processed:
    • Access data and server log files (IP address, date and time of your access, which pages on our website you visited, including the notification if access was successful, the volume of transferred data, the referrer URL of your previously visited website and your used browser type and version). The IT systems responsible for the correct operations of the website automatically collect your data.
    Legal basis for processing:
    • Our legitimate interest (Art. 6 (1) lit. f) GDPR): To enhance our systems, make your usage of the websites more convenient or ensure the security of our websites.
    Period of processing:
    • As long as required to ensure a stable operation and security of our website.Recipients of your personal data:
    • Data processors that provide us with services relating to our IT infrastructure (e.g. hosting or operation and maintenance of our IT systems and platforms).
    Recipients of your personal data:
    • Data processors that provide us with services relating to our IT infrastructure (e.g. hosting or operation and maintenance of our IT systems and platforms).
    3.2. Check for infotainment software updates
    Through our website you can search for and download the latest version of infotainment software for your vehicle.
    Purpose of processing:
    • To check and download the latest infotainment software version of your vehicle.
    Scope of personal data processed:
    If you use the function to search for the infotainment software updates by vehicle type, we don’t process any personal data.
    If you use the function to search for the infotainment software updates by the Vehicle Identification Number, we will process the following personal data:
    • The entered Vehicle Identification Number
      If you are a registered user to other Hyundai Services (for example our myHyundai application), you can use the function to login with your existing account and automatically retrieve information from your user profile and registered vehicles. In this context we will process the following personal data:
    • A unique ID assigned to identify your account and user;
    • Your name;
    • Your contact details such as email-address;
    • The current software version of your registered vehicles; and
    • The last login date.
    Legal basis for processing:
    • Our legitimate interest (Art. 6 (1) lit. f) GDPR): To enable you to easily find the latest infotainment software version of your vehicle.
    Period of processing:
    • For the duration of the active session.
    Recipients of your personal data:
    • Data processors that provide us with services relating to our IT infrastructure (e.g. hosting or operation and maintenance of our IT systems and platforms).
  4. 4. With whom is my personal data shared?
    Within our organization any access to your personal data is restricted to those individuals that have a need to know in order to fulfil their job responsibilities. Your personal data may be transferred for the respective purposes to the recipients to be processed as indicated in Section 3 above:
    • Hyundai group – We are part of the Hyundai Motor Group, a globally acting group of companies. In some cases, after careful review, we may transfer your personal data to other entities in the group (e.g. our local entities in your country of residence).
    • Data processors: Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data on behalf of us under appropriate instructions as necessary for the respective processing purposes. The data processors will be subject to contractual obligations to ensure the implementation of appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only as instructed. The current data processors are involved in particular, but not limited to in the following processes:
      • We are using data processors for providing us with services relating to our IT infrastructure (e.g. hosting or operation and maintenance of our IT systems and platforms).
        The current data processor is Hyundai AutoEver Europe GmbH, Kaiserleistrasse 8A, 63067 Offenbach am Main.
    In addition, we may transfer your personal data to other recipients who process your personal data under their own responsibility. These may include the following in particular:
    • Governmental bodies and authorities: If required or permitted by applicable laws, for example if necessary for the establishment, exercise or defence of legal claims, we may also share your personal data with public authorities such as courts or administrative authorities.
  5. 5. Is my personal data transferred abroad?
    Some of the recipients or sub-processors of your personal data can be located or may have relevant operations outside of your country and the EU/EEA, where the data protection laws may provide a different level of protection compared to the laws in your jurisdiction and for which an adequacy decision by the European Commission does not exist. With regard to data transfers to such recipients outside of the EU/EEA, we provide appropriate safeguards, in particular, by entering into data transfer agreements which include standard clauses adopted by the European Commission with the recipients, or by taking other measures to provide an adequate level of data protection. A copy of the respective measure we have taken is available via the contact information in Section 2.
  6. 6. How is my data secured?
    We have reasonable state of the art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. In order to protect your personal data transmitted via our website, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
  7. 7. How long will my data be stored?
    Your personal data is generally stored for as long as necessary in relation to the purposes. Beside we generally store your data to the extent necessary in order to meet our legal obligations and to protect our rights, for example we will store your data in accordance with statutory retention periods. Insofar more specific retention periods will apply, you can refer to the information on the period of processing of your personal data as indicated in Section 3 above.
  8. 8. What rights do I have and how can I exercise them?
    You have certain rights in relation to your personal data that you can exercise towards us. In accordance with applicable data protection laws these rights may be restricted under certain conditions. You can always exercise your rights at any time by contacting us via the contact information as stated in section 2 .
    Generally, you have the following rights:
    • Right of access: You have the right to obtain from us confirmation as to whether or not we process your personal data, and where that is the case, to request access to your personal data. You also have the right to obtain a copy of your personal data which we process.
    • Right to rectification: You have the right to the rectification of any inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data updated, including by means of providing a supplementary statement.
    • Right to erasure (“right to be forgotten”): Under certain circumstances, you have the right to the erasure of your personal data and we may be obliged to erase your personal data.
    • Right to restriction of processing: Under certain circumstances, you have the right to ask that the processing of your personal data will be restricted in certain aspect. This means that your personal data may be made unavailable to certain recipients or that the data will not be processed beside mere storage, etc.
    • Right to data portability: Under certain circumstances, you have the right to receive the personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You have the right, without hindrance from us, to transfer this data or have it transferred directly by us to another entity.
    • Right to object: You have the right to object to processing of personal data for the purposes of direct marketing at any time. Based on your objection, we will be required to no longer process your personal data for that purpose. On grounds relating your particular situation, you also have the right to object to the processing of your personal data processed also for other purposes at any time.
    • Right to complain: You also have the right to make a complaint with the competent data protection supervisory authority in your country. The data protection authority competent for us is: The Hessian Commissioner for Data Protection and Freedom of Information, Gustav-Stresemann-Ring 1, 65189 Wiesbaden.
    • Right to withdraw consent: If you have given your consent to the processing of your personal data, you can withdraw your consent at any time. The withdrawal of the consent does not affect the legality of the processing which took place prior to the withdrawal of the consent.
  9. 9. Changes to the Privacy Policy
    This Privacy Policy may require an update from time to time – e.g. due to the implementation of new technologies or the introduction of new services. We reserve the right to change or supplement this Policy at any time. We will publish the changes on https://update.hyundai.com/EU/EN/privacy.
  10. 10. Data Processing for other Hyundai Services
    This Privacy Policy only sets out the information for the processing of your personal data when visiting our website. In case we collected your information otherwise (for example when registering with other services of us), information on the processing of your personal data for such services will be provided separately. In any case your above rights as set forth under Section 8 will apply accordingly. If you have any questions in regard to the processing of your personal data related to other services by us, please contact hcm.dataprotection@hyundai-europe.com.