This section explains what types of personal data BMW Group collect about you.

The following categories of personal data may be collected about you in the ways described in the section of this Privacy Policy titled ‘How do we collect your personal data?’. After each type of personal data, we give examples – but it is not a complete list.

Contact data: Name, address, telephone number, email address, date of birth, nationality, place of birth.

Contract data: Customer number, contract numbers, MINI Connected services, relevant payment information.

Online account data: MINI ID, MINI ID settings, MINI Connected services of interest, the ways you interact with BMW Group, payment card information that you have placed on file.

Interests: Information you provide about your areas of interest, such as vehicles that interest you, preferred MINI Retailer(s), hobbies, and other personal preferences.

Other personal data: Information that you provide regarding education, size of household or professional status.

Disabilities, health issues or vulnerabilities: Information you disclose to us that is needed to adapt our services, ensure you receive tailored support, or obtain certain entitlements like Motability Scheme access or VAT exemption. We may need your permission to process this data.

Website usage and communications: Information about how you use the website and whether you open or forward communications from us. Including any data collected via cookies and other tracking technologies. For more information, see the MINI Cookie Policy here.

Sales and service information: Relating to purchases and services, including complaints and claims.

Credit and Anti-Fraud Information: Needed to establish a business relationship with BMW Group UK, and apply for motor finance or insurance, examples include:

• identity information, such as driving licences, passports, and utility bills,
• information about payment transactions, requests for credit, non-payment of debts with us and third parties, and credit ratings from credit reference agencies,
• data about fraud, criminal offences, suspicious transactions, politically exposed persons, and sanctions lists where your details are included,
• employment history,
• address history,
• bank details,
• MINI FS may ask you about disabilities, health issues, or vulnerabilities so they can provide tailored support or assess your ability to repay finance without difficulty. They will ask for your permission to process this data.

If you buy a new or Young Used MINI from us, and choose for someone else to collect it for you, we will ask you to provide their full name, date of birth and contact details so we can check their details against sanction lists; so, you must have the person’s permission to provide their data and you must tell them how we will use it.

If you apply for a MINI branded insurance policy, MINI FS will also ask you to provide:
• certain information about your driving history, your past insurance claims (if any) and any accidents or motoring convictions,
• information about any other drivers that may be on the policy,
• confirmation that other drivers on the policy have:
   - given you permission to provide the information to us,
   - been provided with this privacy policy,
   - no objection to us using or sharing their information in line with this privacy policy.

Use of MINI Connected and MINI App: Information about your use of MINI Connected, the MINI App or other apps offered by BMW Group on your mobile device. Data is collected in the ways described in this privacy policy and the data privacy policies related to those services which you will be asked to accept if you sign up for those services.

Information about vehicle functions, and settings: For example, MINI Teleservices, MINI Connected Services, or MINI CarData. To do this, we will use the vehicle identification number.

Vehicle geolocation data: Information about the location of your vehicle or mobile device. BMW Group may receive this data when we provide MINI Connected Services, MINI Teleservices, MINI CarData, and the MINI App.

We will only use this data in the ways described in the terms and privacy policies for those services. Location data is carefully protected, as described later in this policy.

If you test drive a new or Young Used MINI, BMW Group, or the MINI Retailer, may access location and other vehicle data for safety and security reasons. We will only use this data if the vehicle is not returned, stolen, lost, or involved in a collision or other incident.

If MINI FS provides your vehicle under a motor finance or lease agreement, they may use tracking data to locate the car if you fail to make repayments and they can lawfully take possession of the vehicle.

Your vehicle location will be shared with our road assistance partners if you use the breakdown call facility within your vehicle. If you use the MINI app to contact roadside assistance, the location of your mobile device will be shared with assistance partners.

Technical data related to the vehicle: Data that is generated or processed in the vehicle about how it is configured, being used, performing or malfunctioning. You can configure your vehicle to decide what data is transmitted by it.

Comfort, convenience, and infotainment functions: You can save convenience and custom settings in the vehicle. Data is stored in the vehicle locally; and can be downloaded onto a personal storage device like smartphone or USB stick. This type of data is only transmitted from the vehicle if you use online services related to your settings. Examples of this data include:
o seat and steering wheel position,
o suspension and climate control preferences,
o interior lighting choices,
o multi-media content,
o internet services.

Smartphone integration e.g. Apple CarPlay: You can connect your smartphone or mobile devices to the vehicle. This enables you to use Apps and operate the device using the vehicle’s controls. To do this, data is exchanged between the vehicle and your smartphone and may be collected. Note that smartphone App providers may also process your data when you use your device in this way.

Online services: Your personal data may be collected by app and online services providers if you use your vehicle’s mobile internet connection. This enables external data exchange so you can use online services and apps. This happens through the vehicle’s own transmitter, or through a smartphone that you have in the car.

Third-party services - BMW Group is not responsible for the personal data you provide to third party online service providers. We recommend you read the privacy policies for those services.

MINI Online Services: Your personal data may be collected if you use MINI online data services – like MINI Connected. These services have their own guides and data privacy policies which will be provided to you if you use them.

We will only process personal data not required to deliver these services if the law allows it. For example, to operate the vehicle’s emergency call system, if there is a valid contractual reason, or you give your consent.
 

This section explains how your personal data may be used; and the legal grounds we rely on to collect and use your personal data.

Legal grounds for using your personal data.

To use your personal data, we must have grounds under UK data protection law, these grounds are explained below:

• if you have given us permission to use your data for marketing. This can be done in your online account, or the MINI App. You can change or withdraw your consent at any time using your online account or by contacting us here,
• where needed to form or perform our contract with you,
• where we need to use it to comply with our legal obligations,
• where we have legitimate reasons to use your data, and our reasons for using it outweigh the impact on your data protection rights. Our legitimate reasons for using your data may include:
   - research and development of vehicle related products and services,
   - to inform you about safety recalls or important maintenance,
   - assessing your credit worthiness and detecting fraud and criminal activities,
  - protecting our selective distribution system, for example identifying unauthorised retailers selling MINI products.

MINI ID

To use some BMW Group services, you will need an online account. When you set up an online account you will get a MINI ID which is normally your email address. Your MINI ID can then be used to login to your online account, customer portals, or MINI App in the future.

Your MINI ID can also be used to identify yourself when you visit MINI Retailers or need help from BMW Group UK.

To provide your MINI ID, BMW AG stores your MINI ID, password, and name. This information is provided to BMW Group companies so you can login to your account on their website and other customer portals.

Important note: If you have more than one MINI ID, changes to one account may not automatically update your other accounts. Please make sure you update all your online accounts with important changes, like your contact details, or marketing preferences.

How we use your personal data.

We use your personal data in the following ways:

Sales & Service

BMW Group UK and MINI Retailers will collect and use your personal data:

• as part of the vehicle sales process,
• when your vehicle is serviced, maintained, or repaired,
• to improve the service we provide you,
• to provide you with customer service and support,
• to send you marketing promotions if you have consented to this,
• to arrange vehicle finance for you.

Further details are provided here:

Vehicle sales process

During the sales process, BMW Group UK and MINI Retailers use your personal data to help you with your choice of MINI, set up test drives, and administer your purchase. The following types of data are collected and used during the sales process:

• contact details;
• contract data;
• identification information;
• payment data;
• online account data;
• vehicle technical data;
• vehicle configuration data;
• vehicle ownership data;
• credit and anti-fraud information.

To give you the best purchase experience, some of your data will be shared between BMW Group UK and MINI Retailers. Each party will be a controller or joint controller of your personal data. What this means is explained later in the section titled ‘Joint control of your data with MINI Retailers’.

Vehicle servicing, maintenance, and repair

Technical data will be read from the vehicle and used by technicians to diagnose and repair problems. BMW Group UK and MINI Retailers may use your personal data to inform you about any problems found.

Service improvement

BMW Group UK will share personal data with MINI Retailers to improve the service you are provided. This data is used to improve processes, and train staff so they can deliver better service to you and other customers.

Customer service and support

BMW Group UK and MINI Retailers may use your personal data to:

• process your contract; or provide you with service or support. This includes dealing with problems or complaints,

• contact you if there is a problem with your vehicle or it needs to be recalled for safety reasons,

• identify you when you contact us for help,

• send you a Welcome Pack, customer surveys or information about related products after you have made a purchase. You can tell us to stop sending these types of communications at any time.

We may communicate with you using email, phone, SMS, or in writing. We may also contact you through Apps of the BMW Group or via in-car messaging.

Marketing promotions

When you create a MINI ID, you will be asked whether BMW Group, and selected partners, can send you marketing information. You will also be asked how you want to receive information, for example by email, telephone, post, SMS, in-car and in the Apps of the BMW Group. We will use the data you provide us, and the products you show an interest in, to send you information that is relevant to you.

You can withdraw consent at any time in your online account or by contacting MINI Customer Support:

To arrange vehicle finance for you

If you apply for finance with us, MINI FS will use your personal data to decide whether to offer it to you. In doing this, MINI FS must comply with certain legal rules; and offer finance that is suitable for your needs.

Your personal data will also be used by MINI FS to make sure services function correctly, your data is accurate; and to prevent fraud and money laundering.

When you apply for finance from MINI FS you must provide certain personal data. MINI FS will share it with credit reference and fraud prevention agencies to help us decide whether to offer you finance.

MINI FS must use your data in this way to make a lending decision. If you do not provide it to MINI FS, they may not be able to offer you finance. Your personal data will be used by MINI FS and these agencies in the ways explained below:

• MINI FS will check their own records and those held by credit reference and fraud prevention agencies. This is done to assess your application for credit, verify your identity, and prevent crime and money laundering. Credit reference agencies will place a search footprint on your credit file that may be seen by other lenders. They will also send MINI FS public information (for example information held on the electoral register) and shared credit and fraud prevention information. Fraud prevention agencies will use your personal data to prevent fraud and money-laundering, and to verify your identity.

• Credit reference agencies may also link your records with other people. The link stays until you or the other person successfully asks Credit Reference Agencies to break the link. Your records will be linked to other people if:

• you are making a joint application,
• you have a spouse,
• you are associated with someone else financially,
• you are a company director, and your company has other directors.

You must ensure these people give you permission to disclose their details to MINI FS.

• If you are an owner, director, or partner in a small business, we may also check on your business.

• If you give MINI FS false or inaccurate information, or MINI FS suspect or identifies fraud, they will record this and may also pass on the information to fraud prevention agencies and other organisations involved in crime prevention. Law enforcement agencies may also access and use this information. If fraud is detected, you could be refused certain services, finance, or employment.

• MINI FS, may use fraud prevention agency information from other countries. This can include publicly available sources.

If you want general information about how your personal data will be used by MINI FS, Credit Reference Agencies, and Fraud Prevention Agencies, click on the links below.

MINI FS uses the following credit reference agencies:

• Experian: www.experian.co.uk/crain, Tel. 0344 481 0800. Address: Experian, PO Box 8000, Nottingham, NG80 7WF
• Transunion: www.transunion.co.uk/crain, Tel. 0330 024 7574. Address: TransUnion Information Group, One Park Lane, Leeds, West Yorkshire, LS3 1EP

MINI FS uses the following fraud prevention agencies:

• National Hunter Limited: www.nhunter.co.uk, National Hunter, PO Box 4744, Stone, ST15 9FE
• CIFAS: www.cifas.org.uk/fpn, Tel. 0330 100 0180. Address: Cifas, 6th- Floor, Lynton House, 7-12 Tavistock Square, London, WC1H 9LT.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to 6 years. A record of any fraud or money laundering risk will be retained by the Fraud prevention agencies; and may result in others refusing to provide services or financing to you. If you have any questions about this, please contact the fraud prevention agencies using the details above.

MINI FS uses automated decision-making tools to help it to decide whether to offer you finance. We will compare the information you provide us with other data to decide whether you meet the eligibility criteria for finance, or to decide whether you will be able to make repayments on a vehicle without difficulty. If your application for finance is rejected using automated means alone, you will be given the opportunity to ask for the decision to be reviewed manually. This does not mean that the decision will be changed.

In certain circumstances, to prevent fraud, money laundering, or breach of sanctions or export controls, MINI FS may share anti-fraud information with MINI UK, BMW Holdings or BMW AG.

MINI FS will also use your personal data to manage its contractual obligations, and to enforce its rights under the finance agreement.

For example, if you fall into arrears or break any other term of the agreement, MINI FS may pass on your details to a debt collection agency to collect the debt, to a vehicle recovery agent to repossess the vehicle, or to solicitors to issue court proceedings against you.

MINI FS may also use vehicle location data or check publicly available information to trace your whereabouts. For full details of how MINI FS processes your personal data please refer to the “Use of Your Information” clause in your finance agreement.

If MINI FS reasonably suspect that the vehicle’s odometer has been tampered with or ‘clocked’, and if the vehicle is a BMW or MINI, we will use MINI UK data to remotely retrieve mileage data from the vehicle’s in-car system.

MINI FS may pass on your agreement details (term, monthly payment, rate, mileage, final payment, agreement number and vehicle details) to MINI UK or your preferred MINI Retailer. This is so they can discuss your end of contract options with you, and if you agree, to discuss any future financing with MINI FS.

MINI FS may also provide MINI UK with your contact details and the start and end dates of your agreement so they can send you news on products and services which may interest you.

MINI Connected digital vehicle services and the MINI App

If you login to your vehicle or the MINI App using your MINI ID, you will be able to use MINI digital services.

When you sign-up for MINI Connected, MINI UK, BMW AG, and MINI Retailers receive data about your vehicle, some of which may be personal data. Examples are listed below:

• vehicle status data, such as mileage, and battery voltage,
• vehicle position and motion data,
• maintenance data, e.g., next service date, oil level, brake wear,
• vehicle health data, for example malfunctions or defects in important system components, battery health, tyre wear,
• dynamic traffic information, like congestion, hazards, parking issues,
• environmental information, such as air temperature and weather,
• user profile data, like configured news, email, audio providers,
• vehicle sensor information, e.g., radar, ultrasound, gestures, speech.

Some MINI Connected services and functions are required by law so cannot be deactivated, like the emergency call system.

Further information is available in the MINI Connected, and the MINI App Privacy Policies.

Quality assurance, research and development – to improve our products and services.

BMW Group and MINI Retailers may use data collected about you or your vehicle to improve the service we provide, and the quality of our products. This can include location data.

However, before it is used, this data will be changed so it cannot be directly linked to you. This data will also be kept secure, and access will be carefully managed.

Compliance with legal obligations

BMW Group may need to use your personal data to comply with its legal obligations. Examples are given below.

Legal requests for your information

We may have to provide your information to law enforcement agencies, regulators, courts, and others taking legal action. This can happen in civil or criminal proceedings, and in investigations anywhere in the world.

If we are allowed to, we will direct these requests to you, or tell you before we respond. Sometimes the law prevents us from telling you about the request. Examples of when we may have to provide your data are shown below:

• to demonstrate compliance with laws that apply to us,
• when the police request information during an investigation,
• to provide environmental or vehicle data to the authorities.

Certain consumption data (so-called “OBFCM data”, such as fuel consumption and distance driven) on your vehicle will be collected during service visits and are transmitted directly to the EU Commission via the manufacturer (BMW AG). You can refuse the collection and transmission of data for this purpose when you are at a MINI Retailer.

Security of IT systems

BMW Group must protect your personal data using secure and reliable IT systems. We use your data to ensure this, for example we:

• regularly back-up systems and data,
• check data quality to make sure systems are working properly,
• prevent unauthorised access to systems,
• deal with incidents and troubleshoot issues.

Other legal obligations

We may also have to use your personal data to:

• contact you to recall your vehicle for safety reasons,
• tell you about an important repair that is needed to your vehicle,
• carry out certain checks on you when you want to form a contract with us,
• check BMW Group or MINI Retailers have met regulatory compliance rules.

Sharing your personal data within BMW group

BMW Group companies may need to use your personal data for important administration, for example:

• to comply with accounting standards,
• to provide you with access to IT systems, apps, websites, or other customer portals,
• to run sales and service processes,
• to assess the residual value of vehicles on finance agreements.

Your data will also be shared with BMW Group companies if you have given us permission to send you promotions and marketing information.

Other organisations that we share your personal data with

Your personal data may be passed to other firms, or they may be given access to it. Types of firms, and reasons for sharing your data, are explained below:

• marketing and research companies who run and manage marketing and research campaigns,
• event companies who run and manage sponsored events,
• BMW Group UK Customer Interaction Centre that provides customer support,
• BMW Group UK Business Development Centre that helps customers with the sales process,
• BMW Group service centres that assist with issues like payment queries, contract validation, and problem management,
• MINI Retailers who provide services to you, MINI Retailers in your region who can help with your query, or MINI Retailers in your online account address list so they have up to date contact details for you,
• IT providers who provide us systems and services for customer support,
• driving licence authorities, or other third-parties to confirm your licence details,
• card payment services providers who operate payment platforms,
• logistics and courier companies who transport our products to you,
• companies who provide transport to you, or offer you mobility services (e.g., chauffeurs),
• companies who manage traffic offences, traffic contraventions and private parking fines that involve our vehicles whilst in your care,
• law firms who provide legal advice to us (e.g., where there is a customer dispute),
• with authorised repairers to provide vehicle data,
• with companies that buy one of the businesses that make up BMW Group; and to whom we assign our rights,
• with our, or your legal advisors,
• in anonymised form to third parties who provide mobility services, maps, and other tools. For example, to support automated and autonomous driving capabilities,
• with your consent, data collected through the MINI CarData platform may be provided to other organisations. This transfer enables the other organisation to provide the services you have requested. As part of the MINI CarData platform, basic information about your vehicle’s telematics capability may be shared with third parties to help them determine whether your vehicle is eligible to use MINI CarData.

o You can find more information about MINI CarData within your online account by navigating through to the page "My Vehicles".

Your personal data will be shared securely, and only for the reasons explained in this policy. We will take reasonable steps to make sure other organisations keep to the agreement we have with them about how your data will be protected and used.

BMW Group UK may also transfer your personal data to a third party without your consent if it is in our legitimate interest or if there is a contractual obligation to do so. For example, MINI FS may pass on your personal details to a third-party debt recovery agent if you fail to make the payments due under your finance agreement, or to a vehicle recovery agent to collect the vehicle at the end of your finance agreement. For full details of how MINI FS uses and shares your personal data please refer to the “Use of Your Information” clause in the finance agreement.

Joint control of your data with MINI Retailers

MINI UK and MINI Retailers work closely together to deliver the best customer experience.

Using your MINI ID, you can switch between the MINI website, the MINI App, and in-person visits to MINI Retailers. With your permission, a MINI Retailer can access information in your online account to help you with test drives; and choosing and buying a vehicle. They can also help you with questions and problems during the buying process.

To allow this to happen, MINI UK provides MINI Retailers with a customer management system. MINI UK and MINI Retailers use this system to exchange personal data in your account so we can jointly keep your records up to date and deliver services to you.

When we exchange data in this way, MINI UK and the MINI Retailers are joint data controllers. This means that both MINI UK and the MINI Retailer jointly decide why and how your personal data will be processed.

You can stop this exchange of data by removing the MINI Retailer as a preferred Retailer in your online account. If you do this, your personal data will remain in the MINI Retailer’s customer management system, and they will become the sole controller of that data.

Outside of this exchange, for example when using your data for marketing or setting up a contract, MINI UK and the MINI Retailer are independently responsible for processing your data as controllers.

If you would like more information about how joint control of your data works, or to stop data exchange, please contact us.

Cookies and access to information on your devices

BMW Group may read or write information to or from your devices, this includes your vehicle. For example, when you visit our websites or use the MINI App cookies will be stored on your device.

To do this, we will either:

- ask for your permission; or,

- store or access information on your device if it is essential to the service you have requested.

Click here to view the MINI Cookie Policy.

For example, in your vehicle we must store or access information to provide you with MINI Connected services, or to operate safety features like emergency call.

Please read the document here to learn more about how your data is used for this service.

This section explains how long your personal data will be kept for.

BMW Group keeps your personal data only as long as needed; and only for the reasons explained in this policy. We restrict access to your data to only people who need to use it for the reasons explained in this policy.

Data retention periods are based on business needs and legal reasons. When your data is no longer needed, it is either irreversibly anonymised or securely destroyed.

You can ask for your personal data to be deleted or put beyond use. We will do this if there are no contractual or legal reasons that prevent it. If we are unable to meet your request, we will tell you why.

We explain below how long your personal data may be kept for certain examples.

Use for marketing and customer support:

• We keep your personal data for as long as is needed to meet the reason we collected it. For example, if you purchased a vehicle using BMW finance, we will keep your personal data for the life of your finance contract so we can get in touch with you about your options at the end of the finance term.

Use to perform a contract:

• Personal data used to meet our contractual obligations is kept while the contract is in force. We will then keep relevant personal data for another six years to deal with queries or claims that come up after the contract has finished. This includes personal data collected for the identity checks that we are required to carry out by law.

MINI Connected and MINI App:

• We explain how long we keep vehicle location and device information in the privacy policies for these services.

Where claims are being investigated or considered:

• If we think a claim will be made against us; or we are going to claim against you or someone else, we will keep your personal data for as long as the claim could go on for. This includes situations where you or we are being prosecuted by a public authority.

Use of vehicle data for sales, service, and administration:

• Data related to your vehicle, like service and maintenance information, will be kept for the lifetime of the vehicle. Some of this data may be Personal Data because it can be traced to you.

Use of vehicle data to ensure product quality, and for research and development of new products:

• This data will be kept for 10 years from when it was created. It will be depersonalised but may still be personal data because it could be combined with other information to identify you. This would only happen for one of the reasons explained in this policy.
 

Contacting BMW Group UK

If you have any questions about our use of your personal data, please first contact MINI Customer Support in one of the following ways:

• Call on 0800 0836 464 (calls are free of charge plus your phone company's access charge).

• Send an email to customer.information@mini.co.uk

• Write to us at:

MINI Customer Information Centre
MINI UK
Webhelp
Aldwick Park
Manvers
Rotherham
S63 5NA

You can also contact the responsible data privacy officer – listed below:

BMW (UK) Ltd
Data Privacy Officer
DataPrivacyOfficer@bmw.co.uk

BMW Financial Services (GB) Ltd
Data Privacy Officer
DataPrivacyOfficer@bmwfin.com

BMW (UK) Holdings Ltd
Data Privacy Officer
DataPrivacyOfficer@bmw.co.uk

BMW Aktiengesellschaft
Data Privacy Officer
Datenschutz@bmw.de

Your rights under data protection law

Under certain conditions, you have the right to ask us to:

• provide you with further information on how we use your personal data,
• give you a copy of your data,
• correct the data we hold about you,
• delete any data about you that we no longer need for reasons explained in this policy,
• remove your data from marketing lists,
• provide you with your data in an electronic format so you can share it with another organisation,
• restrict how we use your personal data,
• stop using your data for our legitimate interests. Unless our interests outweigh your data protection rights.

If we cannot comply with your request, we will explain why. Reasons can include:

- safeguarding the public interest – like prevention of crime,
- our interests – like protecting legal privilege, and
- certain rights of third parties – like other organisations or public bodies.

Other important points

- Where we are relying on your consent to process your personal data, you can withdraw this at any time. This policy explains when this is the case.
- If you choose not to provide personal data that we need to set-up or fulfil our contract with you, we may not be able to deliver the product or service you are asking for, and the agreement could be cancelled.

Your right to complain to the regulator

If you are unhappy about how we use your data, or our response to your requests, you can complain to the Information Commissioner's Office. They regulate how personal data is collected and used.

Click here for more information.