1. INTRODUCTION
1.1 This privacy notice (the “Privacy Notice”) of Kia Connect GmbH, registered under the registration number HRB 112541, ("Kia", "we" or "us") applies to the collection and processing of personal data in connection with the provision of the Kia Smart Charging services (the "Services") through the Kia Smart Charging Application ("App") and is addressed to our customers using these Services (“you”, “your”).
1.2 The App uses (personal) data from the Kia Connect app and/or Kia Connect services. The processing of personal data in connection with the provision of the Kia Connect services via the vehicle's infotainment system and the Kia Connect app, and the processing of personal data in connection with the registration of the underlying Kia account (including personal data such as your name, your email address, your date of birth, your mobile phone number) are subject to separate privacy notices. These can be found at https://connect.kia.com/eu/downloads-smartcharging/.
1.3 Kia takes the protection of your personal data and your privacy very seriously and will process your personal data only in accordance with the GDPR and other applicable data protection and privacy laws.
Please note that in addition to this Privacy Notice, where appropriate, we may inform you about the processing of your personal data separately, for example in consent forms or separate privacy notices.

2. CONTROLLER, CONTACT INFORMATION
2.1 Unless expressly stated otherwise, Kia Connect GmbH is the controller of the personal data collected and processed in connection with the provision of the Kia Smart Charging services.
2.2 If you have any questions about this Privacy Notice or our processing of your personal data, or if you wish to exercise any of your rights, you may contact us at:
Kia Connect GmbH
Theodor-Heuss-Allee 11
60486 Frankfurt am Main, Germany
Email: info@kia-connect.eu
You may also use our contact form, which is available here: https://connect.kia.com/eu/customer-support/contact-form/
Alternatively, you may also contact our data protection officer at the contact details provided in Section 3 below.

3. DATA PROTECTION OFFICER
We have appointed an external data protection officer (“DPO”). You may contact our DPO at:
Kia Connect GmbH
– Data Protection Officer –
Theodor-Heuss-Allee 11
60486 Frankfurt am Main, Germany
Email: dpo@kia-connect.eu

4. PURPOSES, LEGAL BASES AND CATEGORIES OF PERSONAL DATA
Details about the purposes of and the legal bases for our processing of your personal data, and the categories of personal data that we may process, are set out in Sections 5 and 6 below.
Please note that we will process personal data only to the extent permitted by law and to the extent necessary for the relevant purpose.
4.1 Purposes
We will mainly process your personal data for the provision of the Kia Smart Charging services, i.e., to calculate a charging plan which allows you to charge your vehicle at times when this is most cost effective. Further details about the Kia Smart Charging services can be found in the Kia Smart Charging Terms of Use.
Furthermore, we may also process your personal data for the purpose of complying with applicable laws or other legal obligations (e.g., disclosure of relevant personal data to courts or criminal prosecution authorities), or if we have separately informed you about such purposes.
4.2 Legal bases
Generally, in connection with the provision of the Kia Smart Charging services, we collect and process your personal data in order to take steps at your request prior to entering into a contract (“conclusion of contract”) or to the extent necessary for the performance of our contract with you (Art. 6 (1) b) GDPR, or to the extent to which the processing is necessary for the purposes of our or a third party’s legitimate interests (Art. 6 (1) f) GDPR).
With respect to certain processing activities, we may process your personal data to the extent necessary for compliance with a legal obligation to which we are subject (Art. 6 (1) c) GDPR), or where we have obtained your prior consent to the relevant processing of your personal data for a specific purpose (Art. 6 (1) a) GDPR).
4.3 Sources
Unless otherwise expressly stated in this Privacy Notice, the personal data listed in Sections 5 and 6 below are provided to us directly by you (e.g. by entering certain personal data in the App). If you are customer of a supported electricity supplier and give us your consent, we can obtain information on your electricity tariff (and in cases of dynamic tariffs, the price per kWh applicable from time to time) directly from your electricity supplier.
4.4 Your right to not provide your personal data
Generally, you have the right to not provide your personal data to us. However, in some cases (e.g., to consider your planned departure time when calculating a charging schedule), we may require certain personal data from you to be able to process your enquiry or to provide the relevant services. We will inform you about the required personal data accordingly.

5. PROCESSING IN CONNECTION WITH THE PROVISION OF THE KIA SMART CHARGING SERVICES
The Kia Smart Charging services offer you price-based charging as follows:
5.1 Price-based charging
The price-based charging functionality serves to calculate and implement an optimized charging schedule for the electric vehicle linked to your account and to display the amount of achieved savings. The charging schedule is calculated based on the data you enter in the Kia Smart Charging app, namely the times for high- and low tariffs of your energy supplier and the applicable prices per kWh (or, in cases of dynamic tariffs – if applicable to you –, the prices per kWh applicable from time to time), your desired trip start time and the desired state of charge at the start of the trip. The price-based charging service controls the start- and stop times of the charging session using the Kia Connect services when the vehicle is connected to your electric vehicle supply equipment (EVSE, also called "wallbox").
For this purpose, the following categories of personal data are processed:
• Electric vehicle data, namely electric vehicle model, VIN, state of charge, remaining range, charging state (charging in progress, charging stopped, charging complete), plug status (connected, disconnected), remaining charging time to reach target battery level, GPS-based location of the vehicle;
• Charging preferences and settings in the App, namely the desired departure time and desired (minimum and target) state of charge of the vehicle's battery at the desired departure time, use of solar energy produced (if available);
• Energy supply data, namely the details of the energy supplier used and the energy tariff details (e.g. whether the relevant tariff is a single, double, triple or dynamic tariff, the start- and end times of each tariff phase, price forecasts (in case of dynamic tariffs) and the applicable prices per kWh); availability of local solar energy production and, if applicable, number of panels, size, location of roof, available power;
• Address details, which are used to determine your smart charging location and to verify your energy contract with your energy supplier, namely your street address, postal code, city and country;
• Identity information, namely first name, surname, nickname, email address and an encrypted version of your self-chosen password;
• Kia Connect account data, which is used to establish a connection between the App and the electric vehicle using the Kia Connect back-end systems, namely the model of the vehicle and the VIN as well as a token used by the Smart Charging Service to authorize its access to the Kia Connect back-end.
Legal basis: The processing is necessary for the performance of the contract that you have entered into with us (Art. 6 (1) b) GDPR) on the provision of the Kia Smart Charging services.
5.2 Data exchange with your supported energy supplier
If you have an energy supply contract with an electricity supplier that is supported by the Services, you have the option to allow us to obtain the details regarding your tariff directly from your energy supplier or to verify the data you entered in the App regarding your tariff with your energy supplier. Furthermore, you have the option to allow us to provide proof of the delivered smart charging services to a supported energy supplier for settlement and revenue calculation. In order for us to exchange data with your energy supplier as described above, we will ask for your consent in the App before obtaining the data.
If you do not consent to us obtaining the data directly from your energy supplier (or if your energy supplier is not supported), you will have to enter the respective information manually in order to be able to benefit from the smart charging functionality of the Services.
For this purpose, the following categories of personal data are processed: Contact details of your energy supplier, contract number or energy meter ID, details of your energy tariff (peak and off-peak times, applicable rates), charging results/amount of electric energy used for charging.
Legal basis: The processing is based on your prior consent (Art. 6 (1) a) GDPR).
5.3 Assisting with stabilizing the electricity grid
We also strive to help stabilizing the electricity grid. This is done by offering to the operators of the electricity grid (and other entities responsible for ensuring the stability of the electricity grid, such as Balancing Service Providers ("BSPs")) to charge the electric vehicles subscribed to the Service at times when there is electric energy available on the grid that is not consumed otherwise (e.g. due to the availability of large amounts of electric energy from renewable sources).
For this purpose, the following categories of personal data are processed: Location of your charging point, information identifying your charge point's connection to the electric grid (meter ID or contract number, if you hold a contract with a supported energy supplier); start- and end time of the charging session to document our contribution to stabilizing the electricity grid.
Legal basis: The processing is necessary for the purpose of the legitimate interests pursued by us (Art. 6 (1) f) GDPR). Our legitimate interests are: assisting in stabilizing the electric energy grids by adapting charging sessions of electric vehicles to the availability of electric energy in the grid.

6. OTHER PROCESSING ACTIVITIES
In addition to the processing activities set out in Section 5 above, we may also process your personal data for the following purposes:
6.1 Communication
We may process your personal data to communicate with you in relation to the Kia Smart Charging services or the contract that you have entered into with us (e.g. to send you e-mails about the status of your registration with the Kia Smart Charging services, to provide customer support, to inform you about technical issues with the Kia Smart Charging services, to perform our contractual obligations, to inform you about changes to the Kia Smart Charging Terms of Use or this Privacy Notice) via several communication channels, including, email, telephone and notifications within the Kia Smart Charging App or the Kia Connect App (if you use this app).
When you contact us via available communication channels (e.g., via a contact form on our website or in the App (if available), by email or by telephone), we may process your personal data to handle your request and communicate with you accordingly in relation to your request. Certain fields in the contact form will be pre-filled to make using the contact form more convenient for you.
For this purpose, the following categories of personal data are processed: Contact details (e.g. email address, telephone number), data relevant for the sending of the notifications within the App (User ID, country, language, device ID, platform,), data relevant for pre-filling the contact form in the App (email address, , language), name, information provided by you in relation to the relevant request, contract data.
Legal basis: The processing is necessary for the performance of the contract that you have entered into with us (Art. 6 (1) b) GDPR), or for the purpose of the legitimate interests pursued by us (Art. 6 (1) f) GDPR). Our legitimate interests are: providing the best possible service for our customers and appropriately answering and processing our customers’ requests.
6.2 Technical Support
Where a technical issue has been detected in relation to your vehicle and the Services, we might be required to read out information from your vehicle for the purpose of analysing such information and to resolve the detected issue. Subject to your prior consent, we will collect and process what is known as a log file of the Head Unit from your vehicle, which contains certain categories of personal data. Your consent is voluntary and can be withdrawn at any time (e.g. by using our contact form available in the “Customer Support” section under “Contact Us” on our website (https://connect.kia.com/eu/customer-support/contact-form/)). The withdrawal of your consent will not affect the lawfulness of processing based on such consent before its withdrawal. However, please note that the refusal to grant or the withdrawal of your consent might prevent us from offering or completing an analysis of the detected issue of your vehicle and the Services.
For this purpose, the following categories of personal data are processed: User ID, , inquiry made to obtain technical support, time stamps; in addition, depending on the subject matter of the inquiry, further information may be processed as required to respond to the support request, such as model and location of the charge point used, the energy supplier used, the presence and technical details of photovoltaic systems used by you (if relevant) .
Legal basis: The processing is based on your prior consent (Art. 6 (1) a) GDPR).
6.3 Marketing
We may contact you via email and/or notifications within the Kia Smart Charging App or the Kia Connect App (if used by you) to provide you with promotional information regarding our products and/or services, to ask you to participate in surveys or to provide your feedback.
In relation to emails and notifications within the App, this is usually subject to your prior consent and to the scope of such consent. You may give your consent by activating the respective consent button in the consent list of the App or by other relevant means (if applicable). Your consent is voluntary and can be withdrawn at any time (e.g. by deactivating the respective consent button in the consent list of the App). You may also unsubscribe from our promotional email list at any time by clicking on the unsubscribe link included in each promotional email that we send. The withdrawal of your consent will not affect the lawfulness of processing based on such consent before its withdrawal. You also have the right to object to the processing of your personal data for direct marketing purposes (see Section 11.6 below for more details).
If you provide us with your email address as part of signing up to the Services and unless you have objected, we may send you information about similar Kia smart charging services or products to the relevant email address without asking you for your prior specific consent. This is because specific consent from you as an existing customer is not required in such cases. However, you have the right to opt out from receiving such electronic mail marketing at any time without incurring any costs (other than the transmission costs according to the basic rates). You may also unsubscribe from our promotional email list at any time by clicking on the unsubscribe link included in each promotional email that we send. You also have the right to object to the processing of your personal data for direct marketing purposes (see Section 11.6 below for more details).
For this purpose, the following categories of personal data are processed: Name, contact details (e.g. email), technical data (e.g. device information, IP address, User ID, UUID), information about your consent (e.g. date and time of opt-in).
Legal basis: The processing is based on your prior consent (Art. 6 (1) a) GDPR; Sec. 7 (2) No. 2 of the German Act against Unfair Competition (“UWG”)), or it is necessary for the purpose of the legitimate interests pursued by us (Art. 6 (1) f) GDPR; Sec. 7 (3) UWG). Our legitimate interests are: promoting our services and products.
6.4 Data Sharing
Details about our sharing of your personal data with third parties are provided in Section 7 below.
6.5 Product improvement and development
Kia collects telematics data relating to the performance, use, operation and condition of the vehicle from the vehicle and/or the App for the purpose of product improvement and development, and may transfer this data to its affiliated companies they can also process the data for these purposes and for the product improvement and development of the App and/or the Services.
Legal basis: The processing is necessary for the purpose of the legitimate interests pursued by us (Art. 6 (1) f) GDPR). Our legitimate interests are: improvement of the Services and the App, and the development of new products and services; e.g. to determine technical faults, analyse vehicle performance or provide improved products or customer services.
The data used for this purpose is limited to technical data on the basis of which the relevant team members cannot identify a natural person. The data used for the improvement/development of the App and Service includes (with regard to the vehicle) the battery level, charging start/stop times and error codes and (with regard to the App) type of mobile device and application version, time zone setting and location, browser types and versions, operating system and platform of the device(s) you use to access the Services.
Tracking data, which is used to improve our service and includes information we or others collect about you through cookies and similar tracking technologies, such as web beacons, pixels and mobile identifiers;
6.6 Operation of Business
We may process certain categories of the personal data referred to above for internal management and administration purposes, including record management or maintaining other internal protocols.
Legal basis: The processing is necessary for the purpose of the legitimate interests pursued by us (Art. 6 (1) f) GDPR). Our legitimate interests are: ensuring the appropriate and efficient operation of our business.
6.7 Legal Compliance
We may process certain categories of the personal data referred to above (e.g., records of any consents that you have given, together with the date and time, as well as content and means of consent) to comply with applicable laws, directives, recommendations, or requests from regulatory bodies (e.g., requests to disclose personal data to courts or regulatory bodies, including the police).
Legal basis: Such processing may be necessary: (i) for compliance with a legal obligation to which we are subject (Art. 6 (1) c) GDPR); or (ii) for the purpose of our legitimate interests (Art. 6 (1) f) GDPR). Our legitimate interests are: ensuring our compliance with applicable legal obligations.
6.8 Legal Proceedings and Investigations
We may process certain categories of the personal data referred to above to assess, enforce and defend our rights and interests.
Legal basis: The processing is necessary for the purpose of the legitimate interests pursued by us (Art. 6 (1) f) GDPR). Our legitimate interests are: protecting our interests and enforcing our rights.

7. RECIPIENTS AND CATEGORIES OF RECIPIENTS
Any access to your personal data at Kia is restricted to those individuals that have a need to know to fulfil their job responsibilities.
Kia may disclose your personal data for the respective purposes and in compliance with applicable data protection laws to the recipients and categories of recipients listed below:
• Kia group companies – We may disclose your personal data to other companies that are members of the Kia group, including our affiliated companies in Europe and Kia Corporation in the Republic of Korea.
To the extent that we disclose such data to other members of the Kia group for internal administrative purposes, such disclosure is necessary for our operational and business interests (Art. 6 (1) f) GDPR). We may also disclose such data because it is necessary for the performance of our contract with you (Art. 6 (1) b) GDPR).
Furthermore, in some cases, the disclosure may be based on your consent (Art. 6 (1) a) GDPR). Where you give such consent, your consent is voluntary and can be withdrawn at any time. The withdrawal of your consent will not affect the lawfulness of processing based on such consent before its withdrawal.
• Service providers – We may disclose your personal data to certain third parties, whether affiliated or unaffiliated, that process such data as our service providers on our behalf under appropriate instructions as processors and as necessary for the respective processing purposes (Art. 28 (3) GDPR). These processors are subject to contractual obligations, which require them to implement appropriate technical and organisational security measures, to safeguard the personal data and to process the personal data only in accordance with our instructions. Our service providers include:
◦ The service provider for the technical infrastructure and maintenance services relevant to the Kia Smart Charging services, which is Jedlix B.V., having its registered office at Stationsplein 45 Unit D, 3013 AK in Rotterdam, the Netherlands ("Jedlix").
Jedlix is responsible for the technical and organisational aspects of the provision of the App and the Services, as well as for keeping the App operational. Kia provides the Services and App in its own name and determines the specifications of the App.
◦ The service provider for customer support with regard to the smart charging services, which is Kia Nederland B.V., having its registered office at De Corridor 25, 3621 ZA in Breukelen, the Netherlands ("KNL"). Depending on the specific field for which support is required, Kia Nederland B.V. has commissioned further sub-processors which are also bound by a processing agreement. First-level customer support for Kia Smart Charging will be provided by Road B.V., Joan Muyskenweg 37, 1114 AN in Amsterdam, the Netherlands. If the first-level-support requires further assistance regarding technical questions concerning the Kia Smart Charging system, it may contact the technical service provider Jedlix (see previous bullet point) to obtain second-level-support; should the inquiry concern Kia Smart Charging-related hardware (such as Kia Smart Charging wall boxes, if applicable), the respective hardware manufacturer may be contacted.
◦ The service providers for our customer data management platforms and connected car data management platforms, which are salesforce.com Germany GmbH, Erika-Mann-Strasse 31-37, 80636 Munich, Germany, and Amazon Web Services EMEA SARL, 38 avenue, John. F. Kennedy, L-1855, Luxembourg, with their servers located within the EU/EEA.
◦ The service provider Momentive Europe UC, Second Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin 4, Ireland, which provides the online survey tool Surveymonkey and related services for the purpose of conducting and evaluating surveys.
◦ Our affiliated entities in the EU/EEA, which provide services relating to customer support, including call centre services.
• Independent third parties working towards stabilizing the electricity grid – We may disclose your personal data to third parties contributing to stabilizing the electricity grid. This involves in particular transmission of the location of your charge point the energy meter number and the charging results to Jedlix B.V., having its registered office at Stationsplein 45 Unit D, 3013 AK in Rotterdam, the Netherlands ("Jedlix"), in its role as an independent controller for providing individual EVs or groups of EVs as electric loads to help balancing the electricity grid. We (or Jedlix) may also transfer this data onward to other parties involved in ensuring the stability of the electricity grid (such as Balancing Service Providers or grid operators). This data transfer and subsequent processing is based on the overarching interest (and our interest to contribute in this regard) to ensure the stability of the electric grid in times of increasing (temporarily high) loads such as EVs or heat pumps and increasingly volatile availability of electric energy due to the use of solar or wind energy (Art. 6 (1) f) GDPR). The recipients will process the relevant personal data as independent controllers.
• Governmental authorities, courts and similar third parties that are public bodies – We may disclose your personal data to governmental authorities, courts and similar third parties that are public bodies where we have a legal obligation to do so (Art. 6 (1) c) GDPR) or for the purpose of protecting our interests or enforcing our rights (Art. 6 (1) f) GDPR). These recipients will process the relevant personal data as independent controllers.
• Outside professional advisors – We may disclose your personal data to our tax consultants, auditors, accountants, legal advisors, and other outside professional advisors for the purpose of operating our business (Art. 6 (1) f) GDPR). In some cases, we may also disclose the data for the purpose of protecting our interests or enforcing our rights (Art. 6 (1) f) GDPR). These recipients will usually process the relevant personal data as independent controllers.
• Third-party acquirers – In the event that we sell or transfer all or any relevant portion of our assets or business (including reorganisation or liquidation), we may disclose your personal data to third-party acquirers (Art. 6 (1) f) GDPR). These recipients will process the relevant personal data as independent controllers.

8. CROSS-BORDER DATA TRANSFER
We are a member of an international group of companies. Therefore, we may transfer personal data within the Kia group and to other third parties as noted in Section 7 above.
Some of these recipients may be located or have relevant operations outside of your country and the EU/EEA (e.g., in the Republic of Korea, the United Kingdom or the United States of America) (“Third Country”). For some Third Countries, the European Commission has determined that they provide an adequate level of protection for personal data (e.g., the Republic of Korea, the United Kingdom) (“Adequate Jurisdiction”).
Where we transfer personal data to a recipient that is located in a Third Country which has not been determined an Adequate Jurisdiction, we (or our processors in the EU/EEA that transfer personal data to sub-processors in such Third Countries, as applicable) provide appropriate safeguards by way of entering into data transfer agreements adopted by the European Commission ("standard contractual clauses") with the recipients or taking other effective measures to provide an adequate level of data protection.
A copy of the respective safeguards may be requested from us or our data protection officer (see Section 2 and Section 3 above).

9. DATA RETENTION
Your personal data is stored by Kia and/or our service providers for no longer than is necessary for the purposes for which the personal data is collected, and which are set out above.
When we no longer require your personal data for such purposes, we will erase it from our systems and/or records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we are required to retain the relevant personal data to comply with legal or regulatory obligations to which we are subject; e.g. personal data contained in contracts, communications and business letters may be subject to statutory retention requirements, which may require retention for up to 10 years).

10. DATA SECURITY
We have implemented appropriate technical and organisational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful forms of processing.
However, as the internet is an open system, the transmission of data via the internet is not completely secure. While we constantly improve our security measures in line with technical developments and to ensure an appropriate level of security for any of your personal data that we process, we cannot guarantee the security of your data transmitted to us using the internet.

11. YOUR RIGHTS
Where we process your personal data based on 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.
Furthermore, under applicable data protection law, you may have the right to: obtain access to your personal data (Art. 15 GDPR), have your personal data rectified (Art. 16 GDPR), have your personal data erased (Art. 17 GDPR), have the processing of your personal data restricted (Art. 18 GDPR), data portability (Art. 20 GDPR) and to object to the processing of your personal data (Art. 21 (1) and (2) GDPR).
You also have the right to lodge a complaint with the competent data protection authority (Art. 77 GDPR).
Please note that these rights could be subject to certain limitations under applicable local data protection laws.
11.1 Right of access
You may have the right to obtain from us confirmation as to whether personal data concerning you is processed, and, where that is the case, to request access to the personal data and certain additional information. Such information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data has been or will be disclosed. However, please note that the interests of other individuals may restrict your right of access.
You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
11.2 Right to rectification
You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Subject to the relevant purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
11.3 Right to erasure ("right to be forgotten")
Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may have the obligation to erase such personal data.
11.4 Right to restriction of processing
Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be flagged accordingly and may only be processed by us for certain purposes.
11.5 Right to data portability
Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and you may have the right to transmit this data to another controller without hindrance from us.
11.6 RIGHT TO OBJECT
UNDER CERTAIN CIRCUMSTANCES AND WHERE THE PROCESSING IS BASED ON LEGITIMATE INTERESTS (ART. 6 (1) F) GDPR), YOU MAY HAVE THE RIGHT TO OBJECT, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA BY US AND WE MAY BE REQUIRED TO NO LONGER PROCESS YOUR PERSONAL DATA.
FURTHERMORE, WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING, WHICH INCLUDES PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IN THIS CASE YOUR PERSONAL DATA WILL NO LONGER BE PROCESSED FOR SUCH PURPOSES BY US.

12. AUTOMATED DECISION MAKING, INCLUDING PROFILING
Kia does not make any decisions based on algorithms or other automated processing that have significant consequences for you.

13. UPDATES
This Privacy Notice may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law. We encourage you to read this Privacy Notice carefully, and to regularly review any changes we might make in accordance with the terms of this Privacy Notice.
We will publish the updated Privacy Notice on our websites, and in the Kia Smart Charging app. The date of the last update is mentioned at the top of this Privacy Notice.

14. DEFINITIONS
“controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“GDPR” means: (i) Regulation (EU) 2016/679 (General Data Protection Regulation); or (ii) regarding the United Kingdom, Regulation (EU) 2016/679 as it forms part of the law of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended from time to time (also known as the UK GDPR).
“personal data” means any information relating to an identified or identifiable natural person.
“process” / “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.