个人信息处理方针

本方针的目的在于保护现代汽车集团通过HTWO网站及其服务器收集的客户个人信息，以及迅
速、圆满地处理与此相关的问题。

Effective Date: [December] [1st], 2022

Your privacy is important to Hyundai Motor Company and its subsidiaries and affiliates (collectively, “Hyundai” “we,” “us” or “our”), as is your trust in Hyundai’s products and services.

This Hyundai Privacy Policy (this “Privacy Policy”) describes how we collect, use, and share your personal information through our global website at htwo.hyundai.com/en/ including users who provide information through any of our website’s contact forms, and any features, offers, or services provided by this website (collectively the “Site”). This Privacy Policy also describes, as applicable, your rights regarding access, deletion, opting-out, and correction of your personal information.

Not Covered by this Policy: This Policy only applies to the Site and not to any other Hyundai website or online service, including the Hyundai Motor America website, unless specifically indicated. It does not apply to any third-party websites even though we may link to these sites on our Site.

User Consent

By disclosing your personal information to us or using our Site, you understand and agree that Hyundai may collect, transfer, use, and disclose your personal information in accordance with this Privacy Policy. For example, you consent to Hyundai’s transfer to and retention of your information within South Korea, which may have less protections for your personal information than the jurisdiction where you live. If required by applicable law, we will obtain your consent to our collection, use, transfer and disclosure of your personal information. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS, THEN PLEASE DO NOT DISCLOSE PERSONAL INFORMATION TO US OR USE THE Site.

Personal Information We Collect and How We Collect It

We collect information about you from several sources: directly from you, from third parties, and automatically through your use of our Site and interactions with us. For example, we collect personal information that you provide directly by completing one of the forms on our Site. We and our third party services providers also automatically collect usage data when you use the Site via cookies, web beacons, and other tracking technologies; web analytics; and log files. We may combine the information we collect from these various sources. We will not use cookies for purposes other than those described in this Policy and our Cookies Policy. For more information about cookies, see our Cookies Policy.

Categories of Personal Information Collected

Certain privacy laws, such as the California Consumer Privacy Act (“CCPA”), require that we disclose the categories of personal information that we may collect about individuals. While the actual information we collect varies depending upon the circumstances, generally we may collect the following categories of personal information:

Identifiers: such as a real name, alias, IP address and online identifiers, email address, or other unique personal identifiers. We collect this information when you fill out a form on or otherwise visit our Site.
Internet or other electronic network usage data: including, but not limited to, browsing history, clickstream data, search history, and information regarding your interactions with an internet website, application, or advertisement, including access logs and other usage data related to your use of the Site. We collect this information through the use of cookies and other tracking technologies.

Use of Personal Information

Hyundai uses the information collected above in several different ways. And we may use your information individually or combine it with other information to generate aggregate statistical information. The primary uses of your information include:

Running our business and providing our products and services: to provide, maintain and improve our products, services, and Site; to authenticate users; to perform technical operations; to communicate with you about our products and services, including fuel cell system and other products and services; to respond to your requests; to provide technical support; and for other customer service and support purposes.
Analyzing and improving our services and offerings: to better understand how users access and use our products, services, and Site; for research and analytical purposes, such as to evaluate and improve our products, services, Site, and business operations; to develop new features, products, or services; and to otherwise improve our Site and user experiences.
Personalizing content and experiences: to tailor content we send or display on the Site in order to offer location customization and personalized help and instructions, and to otherwise personalize your experiences; to reach you with more relevant ads and to measure ad campaigns.
Marketing and promotional purposes: to send you newsletters, offers or other information we think may interest you; to contact you about our products, services, or information we think may interest you; to administer promotions and contests; and to promote other products and services we offer.
In support of our general business operations: where necessary to the administration of our general business, accounting, record keeping, and legal functions.
Securing and protecting our rights: to protect our business operations, secure our network and information technology, assets, services, and legal rights; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our agreements with you, as well as fraud, illegal activities, and other situations involving potential threats to the rights or safety of any person or third party.
Complying with legal requests and obligations: to comply with the law or legal proceedings. For example, we may use information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

Anonymous and De-identified Information. We also may de-identify information and create anonymous and aggregated data sets and reports to assess, improve, and develop our business, products, and services; prepare benchmarking reports; and for other research and analytics purposes.

Disclosure of Personal Information

We disclose personal information to third parties to provide and improve our Site, products, and services; to reach you with more relevant information and offers; to provide you with information about third party offers you may be interested in; and to honor your consent or authorization. We also disclose personal information to the entities listed and for the purposes set out below:

Affiliates and Subsidiaries: Hyundai may share your personal information with Hyundai subsidiaries and affiliates located in your country or region for operational, analytic, and compliance purposes. For example, if you contact us via the “Online inquiry” webform with a business inquiry, maintenance, marketing and PR, we may communicate the content of your message and your personal information to the relevant department of Hyundai subsidiary located in your country or region in order to take action on or respond to your communication.
Service providers and suppliers: We may disclose personal information to our vendors, service providers, suppliers, contractors, or agents who use such data in order to perform functions on our behalf. These entities are contractually required to use the personal information we disclose exclusively to provide their respective services, and not for their own independent purposes.
Business transfers: We may disclose and transfer personal information as part of any merger, acquisition, financing, sale of company assets or interests in the company listed above, or in the case of insolvency, bankruptcy, or receivership, including during negotiations related to such business transfers.
Protecting rights and interests: We may disclose your information to protect or defend the safety, rights, property, or security of Hyundai, third parties, or the general public, including to protect the Services, to detect, prevent, or otherwise address fraud, security, technical issues, or other activity which we, in our sole discretion, consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity. We may also use personal information as evidence in litigation in which we are involved, and as necessary to enforce this Privacy Policy, our Terms of Use, and other applicable agreements with you.
Legal compliance and lawful requests: We may disclose your information in accordance with applicable law to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, in response to a subpoena, warrant, court order, or other legal process, or to cooperate with investigations or lawful requests, whether formal or informal, from law enforcement or government entities.
De-identified and Aggregated Data: We may share aggregate or de-identified information with third parties for research, analytics, and other purposes, provided such information does not reasonably identify you.

Categories of Personal Information Disclosed. Certain privacy laws, such as the California Consumer Privacy Act, require that we tell you about the categories of personal information that we have disclosed for a business purpose, as well as the categories that we have “sold.” Please review the section Categories of Personal Information Collected above for further descriptions of each category of personal information. This information is not limited to California users.

Disclosed for a business purpose. In general, we may disclose the following categories of personal information for the business purposes described above:

Categories of personal information disclosed for our business purposes	Categories of third parties to whom this information was disclosed
Cookies	Affiliates and subsidiaries; service providers and suppliers; analytics providers; and government entities.

Sale. We do not disclose personal information through the Site to third parties in exchange for direct monetary compensation from such third parties. We may disclose or make available personal information collected through the Site to third parties to receive certain services or benefits from them—for example, when we allow third party tags to collect information such as browsing history on our Site to improve and measure our ad campaigns. This disclosure can be considered a sale under certain laws, like the CCPA, and the information “sold” in this manner includes: identifiers, customer records, Internet or other electronic network usage data, and profiles and inferences to affiliates and subsidiaries, and analytics providers. These entities are contractually required to use the personal information we disclose exclusively to provide their respective services, and not for their own independent purposes.

Your Rights and Choices

Subject to applicable law, you may request access to, correction, or deletion of certain of your personal information by contacting us. We will endeavor to respond to those requests in the time periods required by applicable laws. We may request certain information from you to verify your identity before responding to a request. We offer these options to you as general rights, but you may have further specific rights that are outlined in our jurisdiction-specific sections below (for example, residents of California, Brazil, China, Saudi Arabia, the European Union and the United Kingdom should refer to jurisdiction-specific sections within this Privacy Policy).

Opting-Out of Certain Communications. Hyundai offers you the opportunity to opt-out from marketing communications from Hyundai, and to opt out of certain disclosures of personal information to third parties.

European Data and United Kingdom Protection Rights

If the processing of personal information about you is subject to European Union or United Kingdom data protection law because it was collected from you as a European Union or United Kingdom resident, you have certain rights with respect to that personal information:

You can request access to, and rectification or erasure of, personal information;
If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing;
You can object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, please email here. The controller of your personal information is Hyundai Motor Company, [12, Heolleung-ro, Seocho-gu, Seoul, 06797, Korea]. If you are a European Union resident, you have the right to lodge a complaint with a supervisory authority of the European Member state in which you reside. If you are a resident of the United Kingdom, you can submit a complaint to the Information Commissioner Office (see https://ico.org.uk/make-a-complaint/). However, we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary to provide the products and services you use, operate our Site, business, and meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

If you are a resident of the European Union, please be sure to review the Additional Information for EU Residents section below for vital information, as required by the GDPR.

Security of Your Information

We use security policies, procedures, and tools which are reasonably designed to safeguard the personal information we collect. However, the security of information transmitted through the Internet can never be guaranteed regardless of the level of security. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. In order to protect you and your data, we may suspend your use of any of the Site, without notice, pending an investigation, if any security issue arises. Access to and use of password protected and/or secure areas of any of the Site, if any, are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution or civil action.

Information Retention

We will also take reasonable and practical measures to ensure that unnecessary personal information is not collected. We will only retain your personal information for the period of time necessary to achieve the purposes stated in this Privacy Policy, unless longer retention is required or allowed by applicable law.

Third Party Sites

We may offer links to or from our Site to other websites within the Hyundai family as well as to websites, services, and resources operated by third parties. We offer links to third party websites so that you can conveniently visit our vendors and advertisers or locate other content likely to be of interest to you. We are not responsible for the privacy practices, content, or policies of websites operated by third parties and urge you to inquire about their privacy and information sharing practices before providing any personal information. In the event that you provide personal information to any third-party website or service, you understand that Hyundai is not responsible for such third parties’ use or misuse of your personal information. You further acknowledge and agree that Hyundai shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such third-party website, service, or resource.

Children’s Privacy

No part of our Site is directed to or designed to attract anyone under the age of eighteen (18). Our Site does not sell products or services for purchase by children, and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction from which you are accessing our Site), please do not provide us with your personal information. If you are a parent or guardian of someone under the age of eighteen, please do not provide us with their personal information. If you believe we have collected information about a child, please contact us so that we may take appropriate steps to delete this information.

Changes to this Privacy Policy

Hyundai reserves the right to change this Privacy Policy at any time. Hyundai will use, share, and disclose all personal and other user information in accordance with the Privacy Policy in effect at the time the information is collected. We will post any changes to this Privacy Policy on this page so check back frequently so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it. Continued interaction with us following changes to this Privacy Policy will mean that you accept the changes.

How to Contact Us

Please contact us if you have any complaints or questions about this Privacy Policy or our information practices.

Additional Information for California Residents

This section provides information for California residents about their rights regarding their personal information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”).

Right to Opt Out (“Do Not Sell”). California residents have the right to opt-out of our sale of their personal information. Hyundai does not sell your personal information for monetary consideration, but may share your personal information with third parties for marketing purposes. You can opt-out of such sharing by submitting a Do Not Sell request here. We do not sell or share personal information about California residents who we know are younger than 16 years old without opt-in consent. To opt-out of the sharing, including sales, of personal information with third parties that collect information from our Sites via cookies or similar tracking technologies, you can change cookie settings as below:
(Chrome) More > Settings > Privacy and security > Cookies and other site data > See all site data and permissions > Clear all data > Clear.

You will need to adjust these settings on all of the browsers and devices you use to access our websites. If you clear cookies on your browser, you will need to reset these settings. For more information about cookies, see our Cookies Policy.

Verifiable Requests to Delete, and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests:

Right of Deletion: California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes.

Right to Know: Specific Information. California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge.

Right to Know: Categories of Personal Information. California residents have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

categories of personal information collected;
categories of sources of personal information;
categories of personal information about them we have disclosed for a business purpose or sold;
categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
the business or commercial purposes for collecting or selling their personal information; and
a copy of the specific pieces of personal information we have collected about them.

Right to Non-discrimination. California residents have the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting Requests. You may submit requests to us. In order to make a request, you will need to provide us with your name, email address, telephone number, and mailing address.

Please note that we may require additional information from you in order to verify your request.

Authorized agents may submit requests to us. If you are submitting a request through an authorized agent, the authorized agent must confirm their relationship with you. We may also request that any authorized agents verify their identity, including by providing information about themselves, such as their name, email, phone number, and address. We may reach out to you directly to confirm your own identity or that you have provided the agent with your permission to submit the request on your behalf.

There may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. However, we will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

In the past 12 months, we have shared the following personal information with third parties for commercial purposes as follows:

Digital Analytics Companies (Google Analytics): Internet or other electronic network usage data, including, but not limited to, browsing history, clickstream data, search history, and information regarding your interactions with an internet website, application, or advertisement, including access logs and other usage data related to your use of the Site.
Affiliates and subsidiaries (Hyundai Autoever): Identifiers, such as a real name, alias, IP address and online identifiers, email address, or other unique personal identifiers.

Additional Information for EU Residents

The terms below apply to the processing of personal data in the context of activities of a controller or processor in the European Union as well as to the processing of personal data of data subjects who are in the European Union by a controller or processor not established in the European Union, where the processing activities are related to:

the offering of goods or services, irrespective of whether payment by the data subject is required, to such data subjects in the Union, or
the monitoring of data subjects’ behavior as far as their behavior takes place within the Union

Lawful bases for processing your personal data:
We process your personal data for the aforementioned purposes based on the following lawful bases:

If we process your data in order to run our business and to provide our products and services, Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR are our the legal bases for processing. We have a legitimate interest in maintaining an online presence in order to provide general information about our company.
If we process your data for analyzing and improving our services and offerings, Art. 6(1)(f) GDPR is the legal basis. We have a legitimate interest in obtaining information about the use of the Site, products, and services.
If we process your data for personalizing content and experiences, Art. 6(1)(f) GDPR is the legal basis. We have a legitimate interest in sending or displaying tailored content on the Site in order to offer location customization and personalized help and instructions.
If we process your data for marketing and promotional purposes, Art. 6(1)(a) GDPR is the legal basis.
If we process your data in support of our general business operations, Art. 6(1)(f) GDPR is the legal basis. We have a legitimate interest in supporting our general business where necessary to the administration of our general business, accounting, record keeping, and legal functions.
If we process your data for securing and protecting our rights, Art. 6(1)(f) GDPR is the legal basis. We have a legitimate interest in asserting and defending our rights and in particular to prevent and detect fraud, unauthorized activities, access, and other misconduct.
If we process your data for complying with legal requests and obligations, Art. 6(1)(f) GDPR is the legal basis. We have a legitimate interest in complying with the law or legal proceedings.

Data processing when using our contact form:
If you send us inquiries via our contact form here, your message, including the data you provide, will be stored and processed solely for the purpose of contacting you as well as for processing and answering your inquiry. We do disclose this data to third parties unless it is necessary in the context of processing and answering your request or you have given us your corresponding consent. This involves the following data:

First Name and Surname
Email address
Phone number
Company/department
Position
Inquiries

If you contact us within the scope of an existing contractual relationship or contact us in advance for information about our range of services or our other services, the data and information you provide will be processed in accordance with Art. 6(1)(b) GDPR along with Art. 6(1)(f) GDPR for the protection of our legitimate interests for the proper response to customer and contact inquiries. The data is deleted as soon as the purpose of the contact has been fulfilled.

Cookies:
Any use of cookies that is not strictly necessary constitutes data processing that is only permitted with your explicit and active consent pursuant to point Art. 6(1)(a) GDPR. This applies in particular to the use of advertising or analytical cookies. In addition, we will only disclose your personal data processed by cookies to third parties if you have given your explicit consent to do so pursuant to Art. 6(1)(a) GDPR. You can change or withdraw your consent at any time. For more information about cookies, see our Cookies Policy.

Recipients outside the EU:
Where processing in third countries takes place, in certain cases, this occurs only if the adequacy of the level of data protection in the third country has been confirmed by the European Commission in accordance with Article 45 GDPR, based on the EU standard contractual clauses, or if it has otherwise been ensured that the level of protection afforded to data at the recipient’s end is adequate.

Recipients (or categories of recipients) of the personal data:
Our company, our subsidiaries and affiliates (to the extent necessary to process and answer your request), and our third-party service providers (to the extent necessary to process and answer your request).

Additional Information for Data Subjects Located in Brazil

This section provides additional information for data subjects located in Brazil about their personal information, as required under Brazilian privacy laws, including the Brazilian General Data Protection Law (“LGPD”).

International transfer. You consent to Hyundai’s transfer to and retention of your information within South Korea, which may have less protections for your personal information than Brazil.

Retention Period. We will retain personal data for compliance with legal or regulatory obligations. If permitted by law, we may also retain personal data for longer periods of time than required by law if it is in our legitimate interests (or to protect our rights).

Your Rights

Under LGPD, when we act as controller of your personal information, you may exercise certain rights, as described below:

Right to Confirm and Access. You have the right to obtain confirmation as to whether or not your personal information is being processed by us and, if so, the right to obtain a copy of such information.
Right to Rectification. You have the right to request the correction of incomplete, inaccurate, or out-of-date personal information.
Right to Anonymization, Blocking or Erasure. You may request anonymization, blocking or erasure of unnecessary or excessive personal information, or personal information processed in non-compliance with the provisions of the LGPD.
Data Portability. You have the right to have your personal information transmitted to another service or product provider, subject to the protection of our commercial or industrial secrets.
Right to Erase. You may request the deletion of your personal information where it is being processed on the basis of your consent. This right does not arise to the extent that we use another legal basis for processing, such as where processing is necessary for compliance with a legal or regulatory obligation.
Right to Withdraw Consent. When we process your personal information on the basis of your consent, you may withdraw your consent at any time (without incurring any fees or charges) by contacting us as described below.
Right to Obtain Information About the Possibility of Denying Consent. You have the right to be informed about the possibility of denying your consent and the consequences of such denial.
Right to Obtain Information About Shared Data. You have the right to obtain information about the entities with which we have shared your personal information.
Right to Petition. You have the right to petition the Brazilian regulatory authority regarding the processing of your Personal Information.
Right to Revision of Automated Decision Making. You may request the revision of any decisions that we have taken solely on the basis of automated processing of your personal information that affects your interests.

Submitting Requests. You may submit requests to us. If you have any concerns about data protection, you can also contact our Brazilian data protection officer: [HMB, Gustavo Ierardi Goulart, através do e-mail dpo@hyundai-brasil.com] In order to make a request, you will need to provide us with your name, email address, telephone number, and mailing address.

Please note that we may require additional information from you in order to verify your request.

There may be circumstances in which we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or for other permitted purposes. However, we will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

Additional Information for Residents of the People’s Republic of China (PRC)

Separate Consent for Collecting Sensitive Personal Information

Sensitive personal information refers to personal information that, once leaked or illegally used, may easily endanger human dignity or cause harm to persons or property safety. Personal information such as identification card numbers, credit information, driver’s license information, and records of whereabouts, is sensitive personal information. Our Site does not collect information considered sensitive personal information. If we collect this information in the future, we will obtain your separate consent before processing your sensitive personal information.

Your Rights

If you choose to agree to our processing of your personal information, we will ensure your rights over your personal information, as follows, in accordance with relevant PRC laws, regulations, standards, and common practices in other countries and regions.

The right to access and obtain a copy of your personal information.
The right to correct your personal information. When you find a mistake in your information that we are processing, you have the right to ask us to correct it.
The right to delete your personal information. You can submit a request to delete your personal information to us under the following circumstances:
o If our processing of personal information violates laws or regulations;
o If we collected and used your personal information without your consent;
o If our processing of personal information breaches our agreement with you;
o If you no longer use our products or services or you have cancelled your account; or
o If we no longer provide you with products or services.
The right to change the scope of or withdraw your consent. If the processing of personal information is based on your consent, you can change the scope of or withdraw your consent with respect to future processing at any time. Please note that the withdrawal applies prospectively only. Processing that occurred before the withdrawal of consent is unaffected.
The right to cancel your account. You can cancel your account at any time. After cancellation, we will stop providing you with any product and service and delete your personal information according to you request
The right to restrict automated decision-making. If an automated decision-making process (e.g., marketing or push-based information delivery) significantly affects your legal rights and interests, you have the right to ask for our explanation and to refuse our making decisions solely by means of automated decision-making.

You may request to excise your right by emailing us here. For security, you might be required to submit a written request or prove your identity by other means. We might ask you to verify your identity before handling your request. We will normally respond in ten (10) business days.

Consent to Cross-Border Transfer of Personal Information

As a global organization, the personal information we collect may be transferred internationally throughout Hyundai’s worldwide organization to our headquarters in South Korea. Some of these foreign jurisdictions may not provide the same level of privacy protection as your local jurisdiction. We will take proper measures to protect your personal information at adequate or comparable levels of protection as your local jurisdiction. By providing personal information through your use of the Site or consenting to this Privacy Policy, you consent to such transfers or disclosures of your personal information.

Notice of Personal Information Security Incident

In the case of an unfortunate personal information security incident, we will, in a timely manner, and in accordance with laws and regulations, inform you of the basic conditions and possible impact of the security incident, the response measures taken or to be taken by us, suggestions for you regarding prevention and risk mitigation, and our remedial measures for you. We will inform you of such information by email, fax, telephone, push notification, etc., and when it is difficult to notify you individually, we will properly and effectively issue a public notice. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with regulatory requirements.