1. What is this Privacy Policy about?

In this Privacy Policy (“Privacy Policy”), we inform you about the collection and processing of your personal data in connection with the provision of MOCEAN services (hereinafter “MOCEAN services” or “Services”).

Terms not defined in this Privacy Policy have the same meaning as set out in the General Terms and Conditions.

This Privacy Policy also applies to MOCEAN Services purchased under MOCEAN for Business Customers in accordance with the General Terms and Conditions for MOCEAN for Business Customers.

2. Who is responsible for processing my data and how can I contact the data controller?

Hyundai Connected Mobility GmbH (“Hyundai”), with its registered office at Kaiserleipromenade 5, 63067 Offenbach (hereinafter “HCM”, “we”, “us”), is responsible for processing personal data in connection with the registration and participation in the “MOCEAN subscription” we provide.

In this section we inform you how we use your personal data and what rights you have under the General Data Protection Regulation (“GDPR”).

If you have questions about the processing of your personal data, please contact us at: HCM.dataprotection@hyundai-europe.com
or write to the Data Protection Officer at:

Hyundai Connected Mobility GmbH
Attn: Data Protection Officer
Kaiserleipromenade 5
63067 Offenbach

3. What types of personal data are processed, for what purposes, and on what legal basis?

3.0. User Registration

We process your personal data to enable you to register a user account on the MOCEAN platform. You may use your Hyundai Account to register.

For the contractual relationship between HCM and you, we process your:

To complete registration, you must also complete the verification process (see Section 3.1).

3.1. Verification Process

3.1.1. Identity and Driving Licence Verification

We process your personal data such as your ID card and driving licence to verify your identity and confirm whether you meet our eligibility criteria. To this end, the documents you provide are checked by an external service provider to assess the risk of potential fraud.

For the contractual relationship between HCM and you, we process electronic copies of your driving licence and ID card, along with information contained in these documents (Art. 6 (1) b) GDPR).

In the case of MOCEAN for Business Customers: If you are authorised to sign the MOCEAN Services contract on behalf of a business entity, we process your personal data (name, surname, and supporting documents confirming your authority to act on behalf of the entity). In certain cases, we may also request your ID card to verify your identity and minimise fraud risk. This processing is based on our legitimate interest (Art. 6 (1) f) GDPR) in verifying the authorised signatory of our customer.

3.1.2. Credit Check and Fraud Prevention

We process your personal data to reduce the risk of payment defaults, non-returned vehicles, and fraud. Before concluding a MOCEAN subscription with you, we perform a credit check. Your credit rating is determined through a partially automated financial assessment process (profiling) conducted with our partners.

Credit information includes probability values (“scores”), calculated using scientifically recognised mathematical-statistical methods. Various data points are weighted in the score calculation. We use these analytical results from our partners as the basis for deciding whether, and under what financial conditions, we provide you with a vehicle.

We transmit personal data you provide (e.g. name, surname, address, country, date of birth) to our partner for credit assessment. Based on its databases, this partner analyses your creditworthiness and identifies possible fraud cases.

In accordance with Art. 22 (2) a) GDPR and based on our legitimate interest (Art. 6 (1) f) GDPR), we process your data to the extent necessary for concluding and delivering the MOCEAN subscription (Art. 6 (1) b) GDPR).

Given the value of the subscribed vehicle, a credit check is required prior to contract conclusion to reduce the risk of payment defaults, verify the accuracy of the information provided, and ensure you can meet the financial obligations of the chosen subscription. This also serves our legitimate interest in detecting, investigating, and preventing fraud (Art. 6 (1) f) GDPR), and allows us to inform the credit assessor about contractual breaches (see Section 3.6).

To ensure proper verification under Sections 3.1.1 and 3.1.2, we may request additional documents, including payslips, bank statements, tax assessments, and proof of address.

For the above procedures, we share your personal data with our local partner CRIF GmbH (CRIF). Data exchange with CRIF also fulfils statutory obligations to conduct credit checks (§§ 505a and 506 BGB).

CRIF may transmit your data to its contractual partners in the EEA, Switzerland, and, where applicable, other third countries for credit assessment purposes. CRIF processes your personal data as an independent data controller under its own privacy policy. You can find CRIF’s privacy policy here: www.crif.de/datenschutz.

For MOCEAN for Business Customers, CRIF performs credit checks on company data (e.g. annual reports or tax filings). This procedure is used to verify the company’s information and documents, and to identify authorised representatives.

3.2. Provision of MOCEAN services

We process your personal data to provide MOCEAN services, including vehicle inspection and handover, customer support and communication during the contract term, insurance, responding to inquiries, etc.

For this purpose, we process:

We also collect data about your activities on the MOCEAN platform (e.g. vehicle selection such as model, colour, subscription duration, your progress in the sign-up process, date/time of activities).

For MOCEAN for Business Customers, we also process:

Processing is based on fulfilling the contractual relationship between HCM and you (Art. 6 (1) b) GDPR).

In this context, we may also share your data with our partners as necessary to provide MOCEAN services (e.g. insurance, debt collection). A list of partners is provided in Section 4 of this Privacy Policy.

3.3. Vehicle Geolocation for Security Purposes

Hyundai vehicles are equipped with geolocation functions, enabling us to retrieve information about the location of the subscribed vehicle.

We process your location data for security purposes and to prevent theft or loss of vehicles (Art. 6 (1) f) GDPR).

We only access location information if:

3.4. Satisfaction Surveys on the MOCEAN Subscription Platform

We also process your data to conduct satisfaction surveys on the use of the MOCEAN Subscription platform in order to improve user experience.

Participation is voluntary.

If you choose to participate, we process:

Processing is based on our legitimate interest in improving the user experience and our services (Art. 6 (1) f) GDPR).

3.5. Communication with Interested Parties

We process your data to respond to inquiries submitted via the MOCEAN platform (contact form / live chat / contact centre).

For this purpose, we process:

Processing is based on our legitimate interest in ensuring proper communication with customers and interested parties (Art. 6 (1) f) GDPR).

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