Audi on demand Privacy Policy and Important Information

Audi on demand (“Audi on demand”) is a service operated by Grand Star Rental Limited (“GSRL”). This statement provides you with general information about Audi on demand as well as its privacy policy.

For a full description of the services and features available through Audi on demand, please visit https://app.audiondemand.com.hk (“the Web Portal”). The Privacy Policy below describes the policies and practices in respect of the handling of personal data collected from you under Audi on demand.

Important! Please only use the mobile website of Audi on demand when it is safe and appropriate, and do not use the mobile website or directly interact with your mobile device while driving. Always pay careful attention to the road, and do not drive while distracted.

Some features, functions, and technology of Audi on demand may require certain features to be present and functioning in your vehicle. Standard text and data usage rates may apply when using the Audi on demand mobile website.

ABOUT AUDI ON DEMAND
Audi on demand is the fastest and easiest way to drive the Audi vehicle of your choice, available exclusively at selected locations.

Whether it’s a leisurely visit to spectacular scenery, business travel with style, or just an evening drive to downtown, getting behind the wheel of an Audi is a complete driving experience. Book an Audi for up to seven days. Our timeframes are flexible. Register Audi on demand, enjoy the freedom to experience, explore and discover. Enjoy Audi on demand.

AUDI ON DEMAND´S PRIVACY POLICY
Your privacy is important to us. We are committed to protecting your Personal Data (as defined hereinafter) by complying with the requirements of Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”). We will ensure compliance by our staff with the strictest standard of security and confidentiality.

We are providing this Privacy Policy to inform you about how we collect, use and transfer data of you and your Audi vehicle that is associated with your use of Audi on demand. You are strongly recommended to read this Privacy Policy carefully to have an understanding of our policies and practices with regard to the handling of Personal Data collected from you. If you have any questions or concerns regarding this Privacy Policy, you may contact our Audi on demand Customer Center by writing to the following address: [No. 59-63, Chai Wan Kok Street, Tsuen Wan, N.T., Hong Kong] or email to [contact.aod@audi-klm.com.hk]

Audi on demand is a system comprised of hardware and software contained in the Audi vehicle, an Audi on demand mobile website which is accessible via your mobile device, the Web Portal, and back-end services supplied by [Kam Lung Motor Group Limited (“KLMGL”)], [GSRL], their affiliates, and third-party business partners. Third parties are engaged for payment processing, credit card handling, and other related functions.

Collection of Personal Data
“Personal data” refers to any data or information from which an individual may be directly or indirectly identified (“Personal Data”). We and our partners may, on different occasions (including online or in person), collect the following Personal Data that we believe to be relevant and necessary to provide services to you under Audi on demand:

(a) Information About You
- Contact information such as your first, middle, and last name, email address, mailing address, telephone number, and fax number;
- Unique identifiers such as your date of birth, driver’s license number and related information;
-Billing information such as your credit card information and billing address.

(b) Identifiers, Device Information, and Geo-Location.
We also collect the following identifiers and tracking information from your mobile device(s), the Audi on demand hardware installed on your Audi vehicle(s), or your Internet browser on your desktop(s) or laptop(s):
- Vehicle Identification Number (VIN)
- Authorization tokens
- Mobile device identifiers
- Geo-location, including both precise (GPS) and network-based geo-location
- Log-in information
- Bluetooth pairing information for your mobile device, including device identifiers
- Unique identifiers contained in browser or Flash cookies
- IP address
- Information collected from web beacons, including data stored in cookies
- The last page you visited before coming to the Web Portal and other browser related information
- Language settings and device information
- Data related to your usage of the Audi on demand system

(c) Vehicle Operations and Usage Data
When you are using Audi on demand, the following information will be stored in the Audi vehicle and may be transmitted to GSRL during or after your use of the vehicle:
-The operation status of the Audi vehicle, including the record of the engine, mirrors, brakes, temperature, fluids, vehicle speed, transmission, fuel level, battery, inspection information, key access, steering wheel, headlights, whether doors or hood are opened; and
- Other data points relating to the access, status, location and operation of the vehicle.

Some of these information may be transmitted while the vehicle is operating, while the other categories of information are available to us after the vehicle(s) is returned.

Use of Personal Data
The Personal Data provided by you or on your behalf to us from time to time as well as all other Personal Data related to you collected and held by us will be used for any of the following purposes (collectively, the “Purposes”):
- maintaining our vehicle fleet,
- providing the full range of Audi on demand services;
- performing other Audi on demand functions;
- finding missing or stolen vehicles;
- conducting market analysis, statistical or other surveys, research, studies and product development (We may on occasions de-identify and aggregate certain records so that the relevant information no longer reasonably identifies you or the Audi vehicle you used);
- marketing other Audi services and products (including vehicles) to you (Please refer to the section “Notice on Direct Marketing” below for further information);
- verifying your identity and identify you/any membership you held with us;
- managing your preferences;
- assessment, maintenance and improvement of our services;
- providing you with customer service and responding to your queries, feedback or claims;
- notify you of any changes to our website or to services that may affect you;
- anticipating and resolving problems with any products/services supplied or to be supplied;
- processing billing and payment, determining outstanding amounts and, if necessary, collecting outstanding payments;
- assessment, maintenance and improvement of our services;
- complying with the applicable laws of any jurisdiction;
- making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines binding on us and/or our affiliates, subsidiaries or associated companies;
- assisting in law enforcement and/or investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;
- achieving any other lawful purposes relating to any of the aforesaid purposes; and
- any other purposes incidental and directly related to any of the above.

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.

Audi on demand will not be entitled to use your Personal Data for any purposes other than the Purposes without your express and informed consent in writing.

Usage and Other Information
In addition to the Personal Data described above, we may collect certain information about your use of our Web Portal. For example, we may capture the IP address of the device you use to connect to the Web Portal, the type of operating system and browser you use, and information about the site you came from, the parts of our Web Portal you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our Web Portal. In addition, we may later associate the usage and other information we collect online with Personal Data about you.

When you interact with us through the Web Portal, we may collect information such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information (such as precise geo-location information) through these channels.

Use of Cookies
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access the Web Portal. We use cookies on the Web Portal to:
(a) recognize you whenever you visit thesite;
(b) obtain information about your preferences, viewing and browsing behavior, online movements and use of the Internet;
(c) [keep track of the items stored in your shopping basket and take you through the checkout process;]
(d) carry out research and statistical analysis to help improve our services and to help us better understand our visitor and customer requirements and interests;
(e) target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are customized to your interests;
(f) make your online experience more efficient and enjoyable; and
(g) enable tighter security.

The information we obtain from our use of cookies may not contain your Personal Data. Although we may obtain information about your computer or other electronic device such as IP address, browser settings, browsing records, referring/ exit pages, operating systems, date/time stamp and/or other Internet log information, we may not be able to identity you personally. To the extent that non-Personal Data is combined with Personal Data, we treat the combined data as Personal Data for the purpose of this Privacy Policy.

In most cases we will obtain your consent in order to use cookies on the Web Portal. The exception is where the cookie is strictly necessary in order for us to operate the Web Portal and/or to provide you with a service you have requested.

If you want to disallow the use of cookies, you can do so on your own web browser. If you disable cookies, you acknowledge that you may not be able to use some of the functionality of the Web Portal.

Disclosure of Personal Data
Personal Data supplied to us will be kept confidential. We do not sell or trade your Personal Data with third parties and we strive to protect your privacy. However, we may disclose such data to or such data may become accessible or known to all or any of the following persons or entities to the extent necessary for achieving the Purposes:
- our affiliates and business partners;
- purchasers of all or part of our assets;
- our agents, service providers, contractors, and consultants who process data on our behalf, provide maintenance services of our database or data entry services or who otherwise provide us with administrative, telecommunications, computer, payment, data processing or storage, technical support, or other products/services;
- our duly authorized employees who need to know such data in order to process it for us or for the performance of their duties;
- our affiliates, subsidiaries or associated companies for Purposes mentioned above and all other incidental and associated purposes relating thereto for fulling the purposes for which it was collected (subject to any consent requirement relating to “Direct Marketing” below);
- other companies to bring you co-branded services, products or programs;
- any actual or proposed assignee, transferee, participant or sub-participant of GSRL’s rights or business;

We may disclose the Personal Data to third parties under the following circumstances:
- in cases where it is required by law, rules, regulations, codes of practice on guidelines binding on us, Audi on demand or law enforcement agencies or a court order;
- when we believe in good faith that disclosure is necessary to protect your safety or the safety of others or for the detection, investigation or prevention of illegal activities including fraud;
- as a result of a sale, merger, acquisition, consolidation, group reorganization, change of control, liquidation, or transfer of our asset;
- where we need to protect and defend legal rights and property of our corporate affiliates, our customers, the public, or other; and
- where we consider necessary to do so in order to comply with any applicable laws and regulations, or any orders or directions made or given by a court of competent jurisdiction.

We will ensure that any disclosure is made in accordance with this Privacy Policy and is properly documented. Other disclosure of your Personal Data will only be made after we have obtained your prescribed consent, or as may be required by law.

OUR COMMITMENT TO DATA SECURITY
We take appropriate measures to ensure that your Personal Data will be protected. We use a variety of physical, technological and organizational measures to safeguard and secure your Personal Data from unauthorized or accidental access, processing, erasure or other use. Please however note that no data transmission over the internet can be guaranteed to be completely secured. As such, we do not guarantee the security of any data that are transferred from you or to you via the internet.

All of our staff members, contractors and service providers are required to strictly adhere to this Privacy Policy. All Personal Data provided by you are only accessible by us or our authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such Personal Data. You may rest assured that your Personal Data will only be kept for as long as is necessary to fulfill the purpose for which it is collected.

STORAGE OF PERSONAL DATA
[Your Personal Data may be processed and stored outside Hong Kong in a secured Audi system, a third party system under contract with Audi HK, an affiliate, a subsidiary or associated companies. We may process and store your Personal Data outside Hong Kong. We may therefore transfer your Personal Data to our affiliate, subsidiary or associated companies outside Hong Kong for data processing and storage. This may involve a transfer of your Personal Data to a jurisdiction where the level of personal data protection may be different.

By submitting your Personal Data to Audi on demand, you understand and consent to such transfer.

DATA RETENTION
All Personal Data that has been collected from you may be retained for a period of time necessary for achieving the purposes for which it is collected or as long as required by applicable law.

In the event any law enforcement agency or regulatory body requests that any Personal Data collected by us be preserved for the purpose of an active investigation of a crime, the relevant Personal Data may be retained until such time when it is collected by the relevant law enforcement agency or regulatory body.

PERSONAL DATA OF MINORS
We take minors’ privacy seriously. In general, we do not knowingly collect Personal Data from minors. If you are under the age of 18 , please do not submit any Personal Data through Audi on demand.

In any event, we will delete such Personal Data collected as soon as practicable after it is discovered.

OPEN-SOURCE LICENSES
Audi on demand incorporates certain software and/or resources that are subject to the following open source software licenses:

Nginx
URL: http://nginx.org
License: http://nginx.org/LICENSE

Laravel
URL: http://laravel.com
License: http://opensource.org/licenses/MIT

jQuery
URL: https://jquery.org
License: http://opensource.org/licenses/MIT

AngularJs
URL: https://angularjs.org
License: http://opensource.org/licenses/MIT

Twitter Bootstrap
URL: http://getbootstrap.com
License: http://opensource.org/licenses/MIT

CHANGES TO THIS PRIVACY POLICY
We hereby expressly reserves the right to update, revise, modify or amend this Privacy Policy at any time as we deem necessary.

We will notify you of any material changes to this Privacy Policy on the Web Portal or by email. We encourage you to check this Privacy Policy periodically. Your continuous use of Audi on demand affirms your agreement to such changes.

NOTICE ON DIRECT MARKETING
We intend to use your Personal Data for direct marketing carried out by KLMGL, GSRL and/or their subsidiaries, affiliates and associated companies, and for such purpose, your Personal Data held by us may be provided to any of our affiliates, subsidiaries or associated companies for their use for direct marketing. The intended kinds of Personal Data to be used and the intended classes of marketing subjects are specified in this Privacy Policy.

For direct marketing use, we intend to send you direct marketing communications for promotional and customer relationship management purposes, including but not limited to:
(a) news, offers, promotions on our vehicles and services;
(b) joint marketing offers about travel services and packages;
(c) redemption gifts, loyalty, reward or privileges programs;
(d) sales and other auto or auto club related auxiliary services such as travel insurance, automobile insurance, accident & health insurance;
(e) conducting market research;
(f) car shows and customer activities; and
(g) motor-related insurance.

We may also provide your Personal Data to any of our affiliates, subsidiaries, associated companies or third parties including our marketing partners, financial service partners, etc. for the purpose of direct marketing of their products and services, including all the items mentioned in the above paragraph.

We will only use your Personal Data for direct marketing after we have obtained your consent or where the use is permitted under the law.

Suitable measures are implemented by Audi on demand to make available to you the option to “opt-out” of allowing your Personal Data to be used in any of the described direct marketing purposes. You may opt-out of receiving direct marketing communications at any time, free of charge, by:
1. Following the opt-out instructions contained in the direct marketing communications sent by us; or
2. Writing to our Audi on demand Customer Center at the address at: [ No. 59-63, Chai Wan Kok Street, Tsuen Wan, N.T., Hong Kong]

UPDATING OR CORRECTING YOUR PERSONAL DATA
You are entitled at any time to request our confirmation as to whether your Personal Data has been collected by us and/or Audi on demand, and if so, access to your Personal Data held by us, or and to request for correction or deletion of such data, or to withdraw your consent regarding its future use by us and/or Audi on demand. In accordance with the Ordinance, we may charge a reasonable fee for the processing of such data access or correction or deletion requests.

You may review, or update your Personal Data by logging in and accessing the “Customer Center” section [on the Web Portal]. Alternatively, you may direct your request using the Contact Us option or call us at [852 3665 9380] or email us at [contact.aod@audi-klm.com.hk] or write to our Audi on demand Customer Center at: [No. 59-63, Chai Wan Kok Street, Tsuen Wan, N.T., Hong Kong]

In the event that you wish to access or amend your Personal Data, we may request you to provide proof of your identity and all such requisite information to ascertain your identity. Miscellaneous
This Privacy Policy does not extend to third-party websites that may be linked from our website, or from any other broadcast affiliated with us.

This Privacy Policy shall be read in conjunction with other policy documents issued by KLMGL and GSRL. If there is an inconsistency between any of the provisions in this Privacy Policy and other policy documents, the provisions in this Privacy Policy shall prevail.

[This Privacy Policy is available in the Chinese and English versions. In the event of inconsistencies or discrepancies between the two versions, the English version shall prevail.]

This Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong.