DATA ACT INFORMATION NOTICE

FOR USERS OF HYUNDAI COMMERCIAL VEHICLES AND RELATED SERVICE(S)September 2025

GENERAL INFORMATION

This Information Notice is aimed at providing to Users details related to the data collected in relation to the use of Vehicle and Related service, User’s rights to this Data and related Data Holder’s obligations.

The Data Holder of the Relevant Data is Hyundai Hydrogen Mobility Germany GmbH, Landsbergerstrasse 155, 80687 München.

Other Parties involved in data processing are entities of Hyundai Motor Group, in particular Hyundai Motor Company 12, Heolleung-ro, Seocho-gu, Seoul 06797, Republic of Korea providing technical support to Data Holder subject to separate agreements.

In case of discrepancies between this Information Notice and Agreement on Data Access and Use (as defined below), the Agreement on Data Access and Use prevails.

DEFINITIONS

“Agreement on Data Access and Use” – means agreement between the Data Holder and the User, as further described in section 4.

“Bluelink Fleet service” or “Related service” – related service available to Users of the Vehicles, subject to the Bluelink Fleet Service Terms of Use and Bluelink Fleet Service Privacy Notice

“Business user” – User who uses the Product and /or Related Service for the purposes related to User’s business activity

“Data Act” or “DA” – Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonized rules on fair access to and use of data.

“Data Act Information Notice” or “Information Notice” – this information notice provided to the user of Product and/or Related Service under art. 3.2 and 3.3 of the Data Act.

“Data Holder – Hyundai Hydrogen Mobility Germany GmbH

“Data Protection laws” – GDPR as well as any other legal regulations related to data protection and privacy, applicable to either of the Parties.

“GDPR” – the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of data, and repealing Directive 95/46/EC (General Data Protection Regulation

“Hyundai Affiliate” – any entity controlled by, controlling or under common control of the Data Holder.

“Privacy notice” – applicable Bluelink Fleet Services Privacy notice

“Relevant Data” or “Data” – the data collected or generated by the Product or Related Service, which is not directly accessible to the User, that the Data holder lawfully obtains or can lawfully obtain from the Product or Related Service, without disproportionate effort going beyond a simple operation,  further specified in the Annex 1, including relevant metadata. If, during terms of Agreement on Data Access and Use, new data is made available to the User, Appendix 1 will be amended accordingly.

“User” – means a natural or legal person that owns the Product or to whom temporary rights to use that Product have been contractually transferred, or that receives Related service.

“Vehicle” or “Product” – any Hyundai Commercial Vehicle (mention Hydrogen)vehicle which has been placed on the EU market which obtains, generated or collects data concerning its use or environment and that is able to communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the User.

SCOPE OF DATA

  • The Vehicle, as well as the Related Service, generate Data which is directly accessible to the User (directly accessible data) or is or can be lawfully and without disproportionate effort obtained from the Vehicle or Related Service by the Data Holder (readily available data).
  • The annex no 1 to this Information notice includes:
    • Indication of Relevant Data including its type, format and estimated volume;
    • Indication whether the Relevant Data is generated continuously and in real time
    • Indication whether the Relevant Data is stored in the Vehicle or on a remote server, including the retention period;
    • Indication whether or not the Data constitutes a trade secret of the Data Holder or a third party.

AGREEMENT ON DATA ACCESS AND USE

  • Data Holder uses the Relevant Data:
    • in relation to non-personal data, based on the agreement with the Business User, concluded at the moment of signing of such agreement by both Parties or Business User’s acceptance of General Terms of data access and use for Business Users;
      (“Agreement on data access and use”)
    • in relation to personal data, as required for the provision of specific service, legal requirements or other legitimate interests pursued by either of the Parties, as described in Bluelink Fleet Services Privacy Notice.The Agreement on Data Access and Use is concluded for as long as the User owns the Product, holds the temporary rights to use the Product or receives Related Service.
  • The Agreement on Data Access and Use terminates Upon the destruction of the Product or permanent discontinuation of Related Servies, or when a Product or Related Service is otherwise put out of service or loses its capacity to generate the Data in an irreversible manner.
  • Business User can terminate the Agreement on Data Access and Use under conditions specified in the Agreement.
  • Data Holder cannot terminate the Agreement per convenience, but can discontinue to provision the Related Service under the conditions specified in the terms of this Related Service.

PURPOSES OF DATA USE

Data Holder intends to use the Data for the Purposes specified in the Agreement on data use. As a matter of principle, and unless the Parties have agreed otherwise, those Purposes include:

  • provision of services on behalf of the Business User, as described in respective agreements,
  • providing support, warranty, guarantee or similar services or to assess Business User’s, or third party’s claims related to the Product or Related Service
  • monitoring and maintaining the functioning, safety and security of the Product or Related Service and ensuring quality control
  • improving the functioning of any product or related service offered by the Data Holder or Hyundai affiliate to the Users;
  • analysis of the data and aggregating it with other data or creating of services data for the purpose of provision of improvement of services offered to the Users by the Data holder;
  • developing new products or services, including artificial intelligence (AI) solutions, by the Data Holder or third parties acting on behalf of the Data Holder or in collaboration with such other parties;
  • aggregating these Data with other data or creating of derived data, for any lawful purpose, including with the aim of selling or otherwise making available such aggregated or derived that data to third parties, provided such data do not allow specific data transmitted to the Data Holder from the connected product to be identified or allow a third party to derive those data from the dataset.

 ACCESS TO DATA

  • The User can access the Data upon request.
  • When requesting the Data, the User may be required to demonstrate the right to Data under the Data Act, namely:
    • The proof of ownership of the vehicle OR
    • The proof of lease or other title for temporary use of the vehicle OR
    • The proof of other rights to use the Related service.
  • When the User is not the legal owner of the vehicle, the request for Data should be submitted via the owner of the Vehicle.
  • Prior to granting access to data, Data Holder may request that technical and organizational security measures are applied to secure the Data.
  • In relation to personal data, when the scope of requested Data includes personal data, the GDPR applies. The User may be requested to demonstrate the legal basis for processing of personal data, unless the User is the data subject in the meaning of GDPR and only requests the personal data pertaining to him- or herself.
  • Data Holder may refuse the access to the Relevant data, where disclosure of data (or any further processing of data) could undermine security requirements of the Product, as laid down by national or EU law, resulting in a serious adverse effect on the health, safety or security of natural persons.
  • Additionally in exceptional circumstances, where the User is not able to assure sufficient security of Relevant data classified as trade secret, or in case where the disclosure of such Relevant data could cause, with high likelihood, a serious economic damage to the Data Holder, the Data Holder may refuse granting the access to Relevant data.
  • In case where the access to data or sharing of data with a third party is refused, the Data Holder is obliged to notify the User and the competent authority accordingly.

DATA ERASURE

  • The Data is automatically deleted or anonymized after the lapse of retention time as per annex 1 and, in relation to personal data, in applicable Privacy policy.
  • This section is without prejudice to the User’s right to request of personal data erasure under the GDPR, where the User is the data subject to whom such personal data pertains.

SHARING OF DATA WITH A THIRD PARTY

 

  • Chapter 6 applies accordingly to sharing of Data with 3rd party.
  • The User may at any time withdraw their instruction to share the Data with a 3rd party. Withdrawal of such instruction shall be communicated via Privacy center of the mobile app of the Data Holder (if provided) or by means indicated in section 9.
  • In case where the access to data or sharing of data with a third party is refused, the Data Holder is obliged to notify the User and the competent authority accordingly.

COMMUNICATION

  •  The User may request from the Data Holder that the Data is shared with 3rd party indicated by the User.
  • The User may also instruct a 3rd party to request the Data on User’s behalf. In such case, the Data Holder shall conclude a separate data sharing agreement with such 3rd party and will be entitled to verify the validity and completeness of the request provided by the 3rd party. Data Holder can decline the request coming from a 3rd party in case where:
    • There is no data sharing agreement concluded between Data Holder and the 3rd party;
    • The validity and/or completeness of the User’s request could not be reliably confirmed;
    • 3rd party does not provide sufficient guarantees for data security when the Data to be shared constitutes a trade secret of Data Holder or another party;
    • in case and to the extent where processing of requested data could undermine security requirements of the Product, as laid down by national or EU law, resulting in a serious adverse effect on the health, safety or security of natural persons;
  • Chapter 6 applies accordingly to sharing of Data with 3rd party.
  • The User may at any time withdraw their instruction to share the Data with a 3rd party. Withdrawal of such instruction shall be communicated via Privacy center of the mobile app of the Data Holder (if provided) or by means indicated in section 9.
  • In case where the access to data or sharing of data with a third party is refused, the Data Holder is obliged to notify the User and the competent authority accordingly.

RIGHT TO LODGE A COMPLAINT

  • The User is entitled to lodge a complaint alleging an infringement of the Data Act, chapter II, to the competent authority. The list of Data Act competent authorities is included in annex 3.

MODIFICATIONS OF INFORMATION NOTICE

  • Data Holder may modify this Information Notice, including its Annexes, if this is objectively justified by the normal conduct of business of the Data Holder, including i.a. technical modification, organizational changes, business process changes, security reasons and similar.
  • The Data Holder will notify the User of such changes as specified in the Agreement on Data Access and Use.

Annex no 1:

Type of data Format Access Estimated volume   Is data generated continuously and in real time? Collection frequency   Storage Retention period Trade secret
Get Powertrain Data CSV readily avaliable (access per request) 30 KB per trip Continuous and in real time Every hour during driving, end of driving remote server 1 week no
Get Speed Data CSV readily avaliable (access per request) 30 KB per trip Continuous and in real time Every hour during driving, end of driving remote server 1 week no
Get Vehicle Data CSV readily avaliable (access per request) 150 KB per trip Continuous and in real time Every hour during driving, end of driving remote server 1 week no
Get Vehicle Operation Data CSV readily avaliable (access per request) 200 KB per trip Continuous and in real time Every hour during driving, end of driving remote server 1 week no
Get Vehicle Battery Data CSV readily avaliable (access per request) 300 KB per trip Continuous and in real time Every hour during driving, end of driving remote server 1 week no
Get Location info CSV readily avaliable (access per request) 10 KB per trip Not continuous and not in real time End of driving remote server 1 week no

Further details regarding the specific data points processed under the EU Data Act are available upon request. To submit such a request, please contact us via email at EU_DataAct@hyundaihm.com or through our contact form. In accordance with the Data Act, the request must include the relevant Vehicle Identification Number (VIN) and be accompanied by appropriate documentation demonstrating your right to access the data. Such documentation may consist of proof of ownership of the vehicle, proof of lease or other title for temporary use of the vehicle, or proof of other rights to use the related service. If you are not the legal owner of the vehicle, your request must be submitted through the vehicle owner. Prior to granting access, Hyundai Hydrogen Mobility may require the implementation of technical and organizational security measures to ensure the protection of the data.

More Information about Hyundai Connected services: https://connected-mobility.hyundai.com/data-rights