Kia Europe GmbH (hereinafter "Kia EU", "we", "us", "our") may collect and process personal data that concern you. The purpose of this privacy notice (the "Privacy Notice") is to inform you about our processing of your personal data.

Within this Privacy Notice you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what rights you have regarding your personal data processed by us. This Privacy Notice applies to personal data that we collect through the Official Kia Navigation Update Website for the purposes described below.
For more information regarding cookies and similar web-tracking technologies, please refer to our Cookie Policy.

You are not obliged to provide your personal data. However, your personal data may be necessary for the provision of certain services and functionalities (for example, searching for and downloading infotainment software updates). Therefore, without your personal data, we may not be able to provide the requested service.

Kia EU is the controller of the personal data processed in accordance with this Privacy Notice, unless expressly stated otherwise.

Contact Details:
Kia Europe GmbH
Theodor-Heuss-Allee 11
60486 Frankfurt am Main, Germany
Email: info@kia-europe.com

We have appointed an external data protection officer ("DPO"). You may contact our DPO at:

Kia Europe GmbH
- Data Protection Officer -
Theodor-Heuss-Allee 11
60486 Frankfurt am Main, Germany
Email: dpo@kia-europe.com

When you visit our website for informational purposes, i.e. without registering for any of our services and without otherwise providing us with personal data in any other form, we automatically collect your data in order to provide the website, ensure system stability and efficiency, and to implement appropriate safeguards for the security of our website and services. Data Categories and the legal basis on which we perform such processing are as follows:

Purpose	Data Categories	Legal Bases
A. Operating and improving our website: making the website available to you; displaying content on our website; improving content and features of our website; security and server stability. Further information about our processing of your personal data in connection with our website and the use of cookies is provided in our Cookie Policy.	Technical data (e.g., IP address, date and time of your access, pages you have visited, the volume of transferred data, the referrer URL of your previously visited website and your used browser type and version), automatically collected by the IT systems responsible for the correct operation of the website.	Your consent (Art. 6(1)(a) GDPR), where cookies or similar technologies are used; All other processing: legitimate interest (Art. 6(1)(f) GDPR) - namely ensuring the appropriate and efficient operation of the website, improving user experience and safeguarding the security of our website.
B. Providing digital services and functionalities: providing access to the latest infotainment software updates for your vehicle.	Note: The categories of personal data processed depend on how the service is used: - Search by vehicle type: no personal data is processed; - Search by Vehicle Identification Number (VIN): the VIN is processed; - If you are a registered user of other Kia services (for example, the MyKia), you may use the login function with your existing Kia account to automatically retrieve information from your user profile and registered vehicles. In this context, we will process the following personal data: a unique ID assigned to your account and user, name, contact details (e.g. email address), current software version of registered vehicles, and last login date.	Legitimate interest (Art. 6 (1)(f) GDPR) - enabling you to easily find and download the latest infotainment software version of your vehicle.

In some cases, we may disclose your personal data to third parties. This will be done solely in connection with the purposes of processing set out above and in compliance with applicable laws. The possible recipients of your personal data include the following companies, institutions, or persons:

In addition, we may transfer your personal data to other recipients who process your personal data under their own responsibility. These may include the following in particular:

Further information on whether and how your personal data is transferred to third countries and the safeguards applied can be found in Section 6.

We are a member of an international group of companies. Therefore, we may transfer your personal data within the Kia Group and to other recipients and sub-processors as described in this Privacy Notice. Some of the recipients or sub-processors of your personal data can be located or may have relevant operations outside the European Union or the European Economic Area (“Third Countries”). For some Third Countries, the European Commission has determined that they provide an adequate level of protection for personal data (for example, the Republic of Korea, the United Kingdom, or Switzerland). In such cases, we transfer personal data on the basis of such adequacy decisions. Transfers to recipients in the United States may take place where the recipient participates in the EU‑U.S. Data Privacy Framework. Where personal data is transferred to recipients or sub‑processors in Third Countries for which no adequacy decision exists, we ensure that appropriate safeguards are in place, on the basis of standard data protection clauses as adopted by the European Commission, or by taking other measures to provide an adequate level of data protection. You may request a copy of the respective measures we have taken by using the contact information provided in Sections 2 and 3 above.

We have reasonable state-of-the-art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. In order to protect your personal data transmitted via our website, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

Your personal data is generally stored only for as long as necessary to fulfil the purposes described in this Privacy Notice.

In addition, we may retain personal data to the extent necessary to comply with our legal obligations and to protect or exercise our legal rights, for example where data must be stored in accordance with statutory retention periods.

If you have any questions about our processing of your personal data, we are happy to provide you with information about the personal data concerning you and the related processing activities. Under the GDPR, you have the right to request access to your personal data and further information about our processing of your personal data (Art. 15 GDPR). Subject to the legal requirements being met, you also have a right to obtain: (a) rectification of your personal data (Art. 16 GDPR); (b) erasure of your personal data (Art. 17 GDPR); and (c) restriction of processing of your personal data (Art. 18 GDPR). You also have the right to data portability (Art. 20 GDPR) and the right to lodge a complaint with a data protection authority (Art. 77 GDPR).

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time (Art. 7(3) GDPR). The withdrawal of your consent will not affect the lawfulness of processing based on such consent before its withdrawal.

Your right to object: Where we process your personal data on the basis of legitimate interests, you have the right to object to such processing at any time on grounds relating to your situation (Art. 21(1) GDPR). Furthermore, where we process your personal data for direct marketing purposes, you have the right to object to such processing at any time (Art. 21(2) GDPR).

To exercise your rights, you may contact us at any time using the contact details provided in Sections 2 and 3 above.

This Privacy Notice may require an update from time to time (e.g. due to the implementation of new technologies or the introduction of new services). Therefore, we reserve the right to change or supplement this Privacy Notice at any time. We will publish any changes on the Official Kia Navigation Update Website: Privacy Notice.

This Privacy Notice only sets out the information for the processing of your personal data when visiting our website. In case we collect your information otherwise (for example when registering with other Kia services (e.g. MyKia), information on the processing of your personal data for such services will be provided separately. In any case, your above rights as set forth under Section 9 will apply accordingly.