BMI Privacy Statement

As you interact with BMI and its websites, mobile applications, vehicles, products and services, we may collect certain information from or about you or your vehicle from the following sources:

1.1 Directly from you. We collect the information you provide to us directly or when you interact with us, such as when you visit or use our website, use BMI and third-party digital properties (including social media sites and sweepstakes microsites), use BMI mobile applications, or during other interactions such as product and related events, test drives, surveys, promotion entries, and when you interact with our customer call centers.

1.2 Cookies and online technologies. When you access or use our website, BMI and third-party digital properties (including social media sites and sweepstakes microsites), or BMI mobile applications, we may collect data through cookies and other tracking technologies.

1.3 Authorized BMI Retailers. We receive information through leasing, service and other records provided to us by Authorized BMI Retailers.

1.4 BMI-authorized sellers of consumer merchandise.

1.5 Bentley Financial Services (if you finance your Bentley vehicle purchase or purchase products from BFS) and other companies within the Volkswagen Group family of companies.

1.6 Third-party service providers, Integrated Content Providers and Optional Third Parties (defined below).

1.7 Other third parties, such as companies that provide or sell lists of potential vehicle purchasers and current owners (data brokers), business partners, social media platforms and networks.

We may combine information that we receive from the various sources described in this Privacy Statement, including third-party sources, and use or disclose it for the purposes identified below.

As you interact with BMI, its products and services, we collect different types of information from you, based on the interaction, such as when you purchase a vehicle and subscribe to Connected Car Services.

The types of information that BMI collects about you include:

2.1 Identifiers, characteristics and other information you provide, including contact information; authentication information you create; your preferences, photographs and other user-generated content; other materials that you may submit; demographic information; account information, including billing (as well as financial data used for payment purposes); settings; personalized services and authentication information.

2.2 Commercial information regarding vehicle purchase/lease/service, including contact information (such as name, address, telephone number, email) and vehicle purchase, lease or service information (such as VIN, make, model, year, dealer, date of purchase or lease, purchase/lease price, vehicle equipment, and service history) as well as other purchasing or consuming histories or tendencies.

2.3 Commercial and electronic activity information, such as vehicle data transmitted from your vehicle, or collected or inferred from your use of the vehicle or services, including general status data (such as warning lights, upcoming service schedule, fuel level, battery level, and tire pressure); service history and fault or trouble codes; ambient data (such as outside temperature and brightness); vehicle performance data and other data about your vehicle including its identification, condition, equipment status, or collision information; vehicle/technology usage data (such as usage of lock/unlock and remote start technology); driver behavior data (such as vehicle speed, seat belt use, and information about braking habits); information that you provide when using Connected Car Services, including information you send and information you request; and information about your interactions with us, our affiliates, our service providers or Integrated Content Providers or Optional Third Parties (defined below).

2.4 Electronic activity, such as data gathered by technology when you visit our website or use our mobile applications (such as IP address, browser information, ICCID, device type, app and OS version, etc.) as well as information about your use of Connected Car Services, MyBentley and Bentley Network mobile applications, and the Bentley website.

2.5 Geolocation data.

2.6 Audio, electronic, visual, thermal, olfactory, or similar information, such as call recording for emergency and customer service and voice command data (including any personal data included therein).

2.7 Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences and characteristics, demographics and vehicle usage patterns. 

If your vehicle is equipped with an Event Data Recorder (“EDR”), crash or near-crash information about the vehicle or driver’s behavior will be recorded in the vehicle. EDR data are recorded by your vehicle only if a non-trivial crash situation occurs, not under normal driving conditions. For information about your vehicle’s EDR data or other crash or near-crash information collected and how we might receive and use it, please see your owner’s manual.

We collect and use your information for a number of business purposes, such as:

3.1 To provide you with products and services, such as to provide products and services you request; support your vehicle, products and services; diagnose, repair and track service and quality issues; communicate with you about your vehicle, products or services; install and configure changes and updates to your services; authenticate users of our products and services; verify your eligibility for certain programs or benefits; or to provide you with Connected Services.

3.2 For our own internal business purposes, such as to evaluate the usage, performance and safety of our vehicles, products and services; improve the quality of our vehicles, products and services and design new products and services; operate the BMI website and digital properties and customize the content; and maintain internal records.

3.3 For legal, safety or security reasons, such as to comply with legal requirements; protect the safety, property or rights of BMI and the Volkswagen Group family of companies); owners, registered users, drivers, passengers or others; or prevent and detect fraud or misuse of the vehicles, products or services.

3.4 For marketing, however, please note that precise GPS location data or your driver behavior data will not be used for BMI marketing purposes or shared with unaffiliated third parties to use for their own marketing purposes without your affirmative consent.

3.5 In a de-identified or aggregated format, we may also use or share your information in a de-identified or aggregate manner for any purpose.

3.6 For services of third parties that you authorize, with your consent, we will provide the information needed by third parties that we introduce or with whom you independently engage in order to provide their services to you.

We also provide your information to third parties who use it for the commercial purpose of marketing their products and services to you

We may share your information:

4.1 Within the Volkswagen Group family of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership, including Bentley Motors Limited, which is located outside of the United States.

4.2 With third-party service providers working on behalf of BMI, such as advertising agencies and other third parties that assist us with marketing efforts, emergency responders, IT and call center service providers.

4.3 With BMI Retailers for sales, leasing, and customer service purposes, such as responding to quote requests, vehicle diagnosis, maintenance and repair, scheduling service appointments, and contacting you and providing the requested services.

4.4 With others for legal, security or safety purposes, we may share your information with third parties, law enforcement or other government agencies to comply with law or legal requirements; to enforce or apply our Terms of Service and other agreements, or those of the Volkswagen Group family of companies; and to protect our rights and the property or safety of our users or third parties. We also may disclose information about you and your vehicle when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the websites or anyone else that could be harmed by such activities.

4.5 With other companies in connection with a BMI corporate transaction, if we or some or all of our assets are acquired by another company, including through a sale in connection with bankruptcy, we will share the information that we hold with that company.

4.6 With third parties for their own marketing purposes, we share your contact information and vehicle identification data with third parties for their own marketing purposes such as Sirius XM, BMI Retailers and select companies with whom we may partner to offer you products or services.

4.7 Integrated Content Providers. The Connected Car Services include offerings from various third parties with whom we contract and to whom you directed us to share personal information to provide products and services through BMI vehicles (“Integrated Content Providers”) whose services are integral to the Connected Car Services, and without which many of the Connected Car Services would not work. BMI does not create or control the content offered by these Integrated Content Providers, nor does BMI determine how they handle your personal information for purposes of providing their services. The Integrated Content Providers are exclusively responsible for the content and the availability of the content accessible through the Connected Car Services. Integrated Content Providers have the right to use your data for their own purposes and therefore, services from Integrated Content Providers will be subject to their Terms of Service and Privacy Statement. If you have any concerns regarding the collection, use or sharing of your personal information or wish to exercise any rights that you have, please contact the Integrated Content Provider directly at the web address provide below. BMI collects and shares information with these Integrated Content Providers and receives information from these Integrated Content Providers for the purposes described above and in order for you to receive the services and/or content requested.

At present, depending on the generation of your vehicle, the following third-party Content Providers offer services via Bentley Connected Car Services:

• Charging station location information: National Renewable Energy Laboratory, 15013 Denver West Parkway, Golden, CO 80401 – www.nrel.gov; Electrify America, 300A Victory Dr, Herndon, VA 20170 – www.electrifyamerica.com;

• Fuel price information: OPISNAVX c/o IHS, 18 rue du Quatre Septembre, 75002 Paris, France - www.opisnavx.com;

• Natural Voice Recognition: Nuance Inc., 1 Wayside Road, Burlington, MA 01803 – www.nuance.com;

• News: www.afp.com, www.npr.com and any other RSS feed providers that you may choose to add;

• Point-of-interest searching (POI), including voice control, navigation with Google Earth images : Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA – www.google.com;

• Predictive Route Guidance: INRIX Inc., 10210 NE Points Dr., Suite 400, Kirkland, WA 98033 – www.inrix.com;

• Traffic light information: Traffic Technology Services, Inc., 17933 NW Evergreen Pkwy #240, Beaverton, OR 97006 – www.traffictechservices.com;

• Weather: MeteoGroup Ltd., 292 Vauxhall Bridge Road, London SW1V 1AE - www.meteogroup.com;

• Yelp: Yelp Inc., 140 New Montgomery, San Francisco, CA 94105 – www.yelp.com

4.8 Optional Third Parties. In addition to the Integrated Content Providers’ services available as part of the Connected Car Services, you can obtain or purchase additional services or offerings from other third parties that we introduce or with whom you independently engage that rely on the Connected Car Services platform (“Optional Third Parties”). These Optional Third Party services are not integral to the basic operation of Connected Car Services, but may be added by you in order to receive additional services and/or content from the Connected Car Services platform. The Optional Third Parties contract directly with you and are exclusively responsible for their services accessible through BMI’s Connected Car Services platform. Optional Third Parties have the right to use your data for their own purposes and therefore, services or offerings from such Optional Third Parties will be subject to their Terms of Service and Privacy Statement. If you have any concerns regarding the collection, use or sharing of your personal information or wish to exercise any rights that you have, please contact the Optional Third Parties directly. Examples of Optional Third Parties include streaming audio content providers, remote package, fuel or other in-vehicle delivery; car sharing; tolling pricing; usage-based insurance; or other third-party services.

To opt-out of receiving promotional email messages from us, please click on the "Unsubscribe" link contained at the bottom of each email. Opting out of promotional email will not affect BMI’s communication with you by email about your vehicle or other product or service-related matters.

Your vehicle may be equipped with a “Privacy Mode” that allows you to control what information is collected from the vehicle, including the ability to enable full privacy restrictions and discontinue any sharing of identifiable vehicle data except for emergency call and stolen vehicle locator purposes. Please note that disabling the data sharing capabilities will inhibit BMI’s ability to provide you with Bentley Connected Car Services and other functionalities.

You can discontinue the Connected Car Services data collection described in this Privacy Statement at any time by unenrolling your vehicle from Connected Car Services. However, this will result in loss of Connected Car Services. You can unenroll from Connected Car Services by contacting the Connected Car Contact Center at (307) 203-1002 and by deleting the MyBentley mobile application.

Please note that the information stored in your BMI vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your BMI vehicle or mobile device, and thus may be deleted, altered, or transferred.

Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.

Nevada residents: please contact us at privacy@Bentley-usa.com to inquire about your right to opt out of the sale of your personal information.

California residents: please see the Your California Rights section for more information about your privacy choices.

To provide you with a more relevant and interesting experience, BMI may work with third-party companies to display ads or customize the content of the BMI digital properties. These companies may use cookies (a small text file), pixels, tags, or similar technologies that are placed in browsers to gather information about your visits to a BMI digital property, as well as your visits elsewhere on the Internet over time. These companies use this information to provide you with more relevant advertising known as interest-based advertising. Some of these companies participate with the Digital Advertising Alliance ("DAA"). The DAA offers a choice mechanism with respect to certain types of data collection and use. We adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. Visit www.aboutads.info to exercise choice with respect to DAA participants or click on the AboutAds icon on a BMI advertisement and follow the instructions on how to opt out. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from BMI or its representatives.

The BMI websites also collect information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access the BMI website, the pages you have accessed while visiting the BMI website, and the Internet address from which you accessed the BMI website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content.

You may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you previously accepted cookies and directed us to share your information on one of our sites, you can change your cookie preference by clicking on the cookie settings link in the footer of that site. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. Some browsers have incorporated Do Not Track (“DNT”) preferences. If you set your browser to signal that you do not wish to be tracked online, we will honor your preference by disabling social media and targeted advertising cookies.

In addition to the MyBentley mobile application designed to allow you to use your Connected Car Services, BMI may have mobile applications that you can download to your mobile device or vehicle (“BMI Applications”). When you download a BMI Application, there may be an opportunity for you to provide us with or for us to obtain information about you or your vehicle. Each BMI Application will display a Privacy Statement that will inform you about how any new or different information shared via the application will be handled.

Through the Infotainment system, BMI may also offer applications developed by third parties, for example Apple CarPlay or Android Auto (“3rd Party Application”). When you download a 3rd Party Application to your mobile device or vehicle, the 3rd Party Application may collect information about you or your vehicle in connection with your download or use of that application. BMI is not responsible for the collection or use of information by 3rd Party Applications. We recommend that you carefully review the privacy statement and terms of use of each 3rd Party Application prior to downloading or using them.

BMI does not knowingly collect, use, share or sell the information of children under the age of 16. In the event that we learn that we have collected information from a child under age 16, we will delete that information. For questions or additional information, see the “Contact Us” section below.

The BMI websites may contain links to other websites, including social networks, advertisers, BMI Dealer websites, other Volkswagen Group websites, including websites operated by Bentley Motors Limited, and websites belonging to other third parties. Some of these sites may share a similar “look and feel” to the BMI websites. Please be aware that we are not responsible for the privacy practices of other websites. We encourage you to read the privacy statements provided by other websites before you provide information to them.

BMI maintains reasonable safeguards to protect your information. Some services, including Connected Car Services, may involve the transmission of voice and data from your BMI vehicle over wireless and cellular telephone networks and therefore, we cannot guarantee the privacy and security of conversations or data transmitted to and from your BMI vehicle.

From time to time, we may update this Privacy Statement by updating this page and by displaying the date of the last update at the top of the page. We encourage you periodically to check this site to learn about the information we collect, use, and share. Your continued use of any of the BMI websites, products or services affirms your agreement to such changes.

Should you have other questions or concerns about this Privacy Statement, please email us at:

privacy@Bentley-usa.com.

You may also contact us by phone at: 1-800-777-6923.

And by mail at:

Office of General Counsel

Volkswagen Group of America

Bentley Motors, Inc.

Attn: Privacy Office

2200 Woodland Pointe Avenue, Herndon, VA 20171

In addition to the information provided above about the data we collect and how we use and share it, in accordance with the California Consumer Privacy Act (CCPA), below is a list of the categories of personal information collected and for each category, the categories of third parties with whom we share the personal information for a business or commercial purpose.

As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information. You can submit a Data Subject Rights Request by clicking (privacy.vwgoa.com), and following the instructions in the web form, or you can call (800) 777-6923.

Please note that certain rights may be limited where your personal information is subject to certain state or federal laws, such as the Fair Credit Reporting Act (“FCRA), the federal Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act.

14.1 Right to Opt-Out/Do Not Sell

California Consumers have the right to request that we not sell your personal information to third parties. However, even if you opt-out, we are allowed to continue sharing with service providers as permitted by law.

Where our web properties use cookies or other tracking technologies to transfer your personal information to third parties, those web properties will offer you an option to set preferences for online data sharing, found by clicking the link in a cookie banner.

14.2 Right to Delete

California Consumers have the right to request that we delete personal information about you that we have collected from you.

14.3 Right to Know

California Consumers have the right to request that we disclose personal information that we have about you. You can request that we provide you with the categories of personal information we have collected in the 12 months preceding your request, and information about how we used and shared those categories of information. You can also request that we provide you the specific pieces of personal information that we have about you.

California Consumers can submit a Request to Know twice in a 12-month period and the report will be provided free of charge.

14.4 Verification

In order to verify your identity, match you to our records, and to reduce fraud, we will ask you to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also ask you to provide a signed declaration, under penalty of perjury, that you are the person whose personal information is the subject of the request. We also use third party verification companies to help us verify your identify.

14.5 Household request

If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above.

14.6 Use of authorized agent

If you are making any of the requests above as an authorized agent, we will require written authorization or a valid Power of Attorney. Additionally, we will seek to verify your identify in the manner stated above. To make a request using an authorized agent please call (800) 777-6923.

14.7 Timing of Response

We will respond to Requests to Delete and Requests to Know within 45 calendar days, unless we need more time, in which case, we will notify you. It may take up to 90 calendar days in total to respond to your request. We will respond to Requests to Opt Out/Do Not Sell within 15 business days.

In accordance with applicable law, we will not discriminate against you for exercising your privacy rights.