PRIVACY POLICY

Abu Dhabi Motors as a Data Controller

Abu Dhabi Motors LLC (“Abu Dhabi Motors”) is the Data Controller of your personal information that we receive through our websites, telephone, electronic services such as email and in our sales and aftersales centres.

Changes to this Privacy Policy

We may modify or update this privacy policy from time to time.

If we change this Privacy Policy, we will notify you of the changes by publishing an updated policy on this website. Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have (e.g. to object to the processing).

How do we collect your personal information?

These are the main ways we collect your information:

• If you contact us directly via our websites, visit the retail centre or via our customer hotlines to request information about our products and services.
• If you buy a product or service directly from us.
• If you reply to our direct marketing campaigns.
• If your contact details are transferred from MINI Middle East or other third parties.
• If your vehicle data (incl. vehicle identification number) is transferred to BMW AG or BMW Group while you’re having your vehicle serviced or repaired.
• If other BMW Group legal entities or business partners transfer your personal data to us.
• If we acquired your personal data from other sources, for example: social media sites.
• If you give information on behalf of someone else you must ensure that they have been provided with this Privacy Policy before doing so.

If you are under 21 years of age please do not provide us with any of your information unless you have the permission of your parent or guardian to do so.

All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.

What information may be collected about you?

The following types of personal information about you may be collected:

• Contact Details - Name, address, phone numbers and email addresses.
• Interests - Information you provide us about your interests, including the types of vehicles you are interested in.
• Website and Communication Usage - how you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies.
• Call Recording - We record inbound calls to our switchboards.
• Closed Circuit Television - We use CCTV to monitor our premises
• Sales and Services Information - Relating to purchases and services, including complaints and claims.
• Credit and Anti-Fraud Information - Which establishes your identity, such as Emirates ID, Smartpass, driving licences, passports and utility bills. Information about transactions, requests for credit and non-payment of debts with us and third parties. Fraud, offences, suspicious transactions and sanctions lists where your details are included.
• Vehicle Configuration Details - Information about the features and current settings of your vehicle (identified by the Vehicle Identification Number).
• Vehicle Technical Information - About how the engine and systems within the vehicle perform.

Cookies

Cookies are small files which are temporarily installed on your hard drive. This website uses cookies solely to retrieve aggregate information to perform analyses of the characteristics and behaviours of website users and in order to make improvements to the site. Abu Dhabi Motors uses cookies to keep track of their users' preferences and thereby design the website to best meet users' requirements. This information is not used to identify individual website users. Information collected using cookies includes non-personal information such as:

• the Internet domain and IP address from which you are accessing the web site;
• the browser and operating system you are using;
• the date and time you access the site;
• the pages you visit; and
• whether you arrived at our website via a link from another site and the address

You can prevent cookies from being saved on your hard drive by selecting the appropriate setting on your browser – simply follow your particular browser's instructions. You may continue to use this website even if you deactivate cookies, however deactivating cookies may mean that you might no longer be able to enjoy offers from Abu Dhabi Motors in their entirety.

How your personal information may be used

Use of personal information under UAE’s data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this Privacy Policy.

The main uses of your information are:

Vehicle Sales & Service - To process your enquiry or sale and to configure and service your vehicle. Abu Dhabi Motors will obtain Contact Details, Vehicle Configuration Details, Vehicle Technical Information and Sales and Services Information when you purchase, service or repair a vehicle with us as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your vehicle. This information may be accessed by BMW Group and BMW AG to troubleshoot technical or other issues relating to the delivery of these services.

Compliance with legal requests for your information

To comply with our legal obligations to law enforcement, regulators and the court service. We may be legally required to provide your information to law enforcement agencies, regulators and courts and third party litigants in connection with proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Legal grounds for processing of your personal information

The use of your information set out above is permitted under UAE’s data protection laws on the basis of these principal legal grounds:

• Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time through the Abu Dhabi Motors websites or using the contact details in the “ Contacting Abu Dhabi Motors about this privacy policy” section of this Privacy Policy below.
• Where necessary to enter into or perform our contract with you.
• Where we need to use it to comply with our legal obligations.
• Where necessary for us to defend, prosecute or make a claim against you, us or a third party.

There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it you as soon as possible after becoming aware of the new basis.

Third parties to whom we may transfer your data

Personal information which we collect from you may be transferred to or accessed by third parties on our behalf, with your consent where necessary. The types of recipients, apart from the MINI companies already stated are:

• Marketing and research companies who run and manage marketing campaigns.
• Customer Services who provide customer support.
• Finance providers and Insurance Administrators.
• Logistics and courier companies who transport our products to you.
• Law firms who provide legal advice to us (e.g. where there is a customer dispute).

This is only shared in a secure manner. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.

Abu Dhabi Motors may also transfer your personal information to a recipient without your consent if it is deemed to be in public interest or if it is necessary for the purposes of carrying out the obligations and exercising rights of Abu Dhabi Motors or of the data subject in the field of employment, social security and social protection law, in accordance with UAE’s data protection laws.

How do we keep your personal information safe?

We use a variety of security measures, including encryption and authentication tools, to help protect and maintain security, integrity and availability of your information.

Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:

• Tightly restricted personal access to your data and for the communicated purpose only.
• Transferred collected data only in encrypted form.
• Highly confidential data stored only in encrypted form.
• Firewalled IT systems to prohibit unauthorised access.
• Permanently monitored access to IT systems to detect and stop misuse of personal data

How long we keep your personal information for

We retain your information only as long as is necessary and only for the purpose for which we obtained them. We restrict access to your information to only those persons who need to use it for the relevant purpose.

Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised or destroyed securely.

Use to perform a contract - In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus 10 years to deal with any queries or claims thereafter.

Where claims are contemplated - In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.

Who we share your information with

Abu Dhabi Motors is the exclusive importer for BMW, MINI, BMW ALPINA and the sole dealer for Rolls-Royce Motors Cars in Abu Dhabi and Al Ain. BMW Group is a global company. Your personal information may be accessed by our staff, agents or contractors from a country outside the United Arab Emirates (UAE) for any of the purposes set out, in which data protection laws may be of a lower standard than in the UAE. We will ensure that any of your information that is accessible outside the UAE is handled subject to appropriate safeguards.

In accordance with applicable data protection laws, the UAE’s Data Office is entitled to approve certain countries outside the UAE as providing essentially equivalent protection to UAE data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to the UAE Data Office’s approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such

Contacting Abu Dhabi Motors about this privacy policy.

If you have any questions in relation to our use of your information you should first contact Abu Dhabi Motors in one of the following ways:

Calling us on: 800- 269
Sending an email to mini@alsaqergroup.com
Writing to us at: P.O. Box 46468

Under certain conditions you have the right to require us to:

• Provide you with further detail on the use we make of your information.
• Provide you with a copy of your information.
• Update any inaccuracies in the information we hold about you.
• Delete any information about you that we no longer have a lawful ground to use.
• Remove you from any direct marketing lists when you object or withdraw your consent.
• Provide you with your personal information in a usable electronic format and transmit it to a third party (right to data portability).
• Restrict our use of your personal information.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and the rights of third parties.

If you are dissatisfied with our use of your information or our response to any exercise of these rights you have the right to complain to the UAE’s Data Office when it is established and functioning.

Privacy Policy Social Media Pages:

Abu Dhabi Motors is responsible for the content of the Social Media Pages; Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube.

When visiting our page, Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube collects as controller personal data of the user, e.g. via cookies. Such collection of user data by Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube can also occur even if the user is not logged in or registered at Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube. Information about the data collection and further usage by Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube can be found in the privacy policy of Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube.

Which user data Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube collects is not known to MINI. MINI does not gain full access to such collected user data or any user profiles. MINI can only access public profile information. Which information you share as public can be adjusted via your Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube settings. In addition you can actively hide your “likes” or unlike the page via the Facebook, (https://www.facebook.com/settings?tab=privacy) and on Instagram, Twitter, LinkedIN and YouTube settings. Your profile will then not be listed as fan of this page anymore.

MINI receives from Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube anonymous statistics about the usage of our page. For example, the following anonymous information will be provided to MINI:

• Follower: number of persons following MINI – including growth and development over a defined time frame.
• Range: Number of people who see a specific contribution. Number of interactions on a post. For example, you can deduce which content in the community is better than other.
• Advertisement performance: How much does MINI cost a click? How many people have seen an ad?
• Demography: Average age of visitors, sex, place of residence, language.
• Those statistics are used to steadily improve our Facebook, Instagram, Twitter, LinkedIN and YouTube online content and to better respond to the interests of our users. We cannot link statistical data with the profiles of our fans or individual users. You can use your Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube settings to decide in which form you would display targeted advertisements.

MINI receives via Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube personal data if you actively transmit your data by sending a personal Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube message. We use the provided data (e.g. name, surname, VIN) to respond to your query by our customer support. Your data will be saved for this purpose in our CRM system. MINI also receives via Facebook, Instagram, Twitter, LinkedIN, Snapchat and YouTube personal data of you if you are using a pre-filled web form. This form uses data of your profile. To send the data to us you actively have to click a send button.