One ID Privacy Policy

Last modified: 04.09.2025

**This privacy policy addresses the processing of personal data under applicable Data Protection Laws. For information on how Honda processes your Product Data and Related Services Data under the EU Data Act, please refer to the Annex below.**

  1. INTRODUCTION

    1.1Honda Motor Europe Limited (“Honda”, “we”, “us” or “our”) respects the privacy of users of its One ID Service (as defined below) (“you” or “your”) and is committed to protecting it through our compliance with this policy.

    1.2This policy describes:

    1.2.1The types of information we may collect or that you may provide when you create, register with, access, or use the One ID account and One ID services, including any individual products, services, application software, platforms and other user interfaces made available through a One ID account (collectively, the “One ID Service”).

    1.2.2Our practices for collecting, using, maintaining, protecting and disclosing that information.

    1.3This policy applies only to information we collect from your devices when using the One ID Service. This policy also applies when you use the Honda mobile and other software applications in connection with the One ID Service such as RoadSync Duo.

    1.4Our websites and other apps and services may have their own privacy policies, which we encourage you to read before providing information on or through them.

    1.5Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not wish for us to process your information in the way described in our policies and practices, do not use the One ID Service. This policy may change from time to time, so please check the policy periodically for updates.

  2. CONTACT INFORMATION

    2.1We are the controller of your personal data. This means that Honda Motor Europe Limited decides why and how your personal data is processed.

    2.2We sometimes work with our parent company and manufacturer, Honda Motor Co., Ltd and in relation to some of the processing activities described in this policy. Where this is the case, we may process your personal data for a common purpose or purposes, and make decisions together so that we are 'joint controllers' with Honda Motor Co., Ltd. As joint controllers, both companies are involved in making these decisions and will be jointly responsible to you under data protection laws for this processing.

    2.3To ask questions or comment about this privacy policy and our privacy practices, contact us at:

    2.3.1Our office address:Honda Motor Europe Limited, Cain Road, Bracknell, Berkshire, England, RG12 1HL

    2.3.2Our email address:DPO@honda-eu.com

  3. INFORMATION WE COLLECT AND HOW WE COLLECT IT

    3.1We collect information from and about users of the One ID Service:

    3.1.1Directly from you when you provide it to us.

    3.1.2Automatically when you use the One ID Service.

    3.2Information You Provide to Us

    3.2.1When you create a One ID account or any other account associated with the One ID Service, or use the One ID Service, we may ask you to provide:

    3.2.2Information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and country of residence.

    3.2.3Information that is about you but individually does not identify you offline, such as information about your mobile operating system and your device, such as device usage and history.

    3.2.4Information that you provide by filling in forms in connection with the One ID Service.

    3.2.5Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us.

    3.3The personal data you give to us is provided on a voluntary basis. However, if you do not provide us with your personal data, we may be unable to provide you with the One ID Service or any associated services, and we may be unable to communicate with you effectively, or at all.

    3.4Automatic Information Collection

    When you use the One ID Service, the various connected apps and services may use technology to automatically collect:

    3.4.1Usage Details. When you access and use the One ID Service, we may automatically collect certain details of your access to and use of the One ID Service, including traffic data, location data, logs, search histories, usage status (such as whether you are calling, being navigated, playing music, or in message mode or call mode) and other communication data and the resources that you access and use on or through the One ID Service.

    3.4.2Vehicle and Device Information. We may collect information about your vehicle, mobile device (including smartphones, headsets and other devices connected to your vehicle) and internet connection. This includes the vehicle’s and device’s unique identifiers, model numbers, manufacturers’ information, carriers’ information, battery data, operating system, browser type, mobile network information, screen height, width, dpi and orientation, the device’s telephone number, purchase and maintenance data of vehicles, warranty information, settings and other detailed information about your vehicle and device. We may also collect online identifiers from you, namely your IMEI, IP address, and Bluetooth Meter ID.

    3.4.3Travel Records. We may collect movement records such as total distance, average speed, starting point and stopping point of a movement, trip ID, app session ID, time, latitude, longitude, accuracy, speed, speed accuracy, distance, bearing, bearing accuracy, altitude, vertical accuracy, location provider, Geohash, device time, and other related information.

    3.4.4Stored Information and Files. The One ID Service also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

  4. HOW WE USE YOUR INFORMATION

    4.1We use information that we collect about you or that you provide to us, including any personal data, to:

    4.1.1Provide you with the One ID Service and its connected application software, services and contents, and any other information, products or services that you request from us.

    4.1.2Fulfill any other purpose for which you provide it.

    4.1.3Improve the quality of the One ID Service.

    4.1.4Conduct usage analysis, and develop new services and products.

    4.1.5Communicate with you, including to deal with your questions, messages or requests, and to manage your complaints.

    4.1.6Comply with laws and regulations applicable to us.

    4.1.7Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

    4.1.8Notify you when updates are available, and of changes to any products or services we offer or provide through it.

    4.2The legal basis for the processing of your personal data is:

    4.2.1Performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract. This includes processing to provide our services and to communicate with you including to handle your queries and complaints and to manage the service we provide to you.

    4.2.2Where the processing of your personal data is necessary for the pursuance of our legitimate interests (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child). Such legitimate interests are:

    1. To operate the administrative and technical aspects of our business efficiently and effectively where we process your personal data for account management purposes (e.g. account closures); and
    2. To maintain our responsiveness to the needs of our customers where we process your personal data for the purposes of providing certain optional service features and to improve and develop our products and services.

    4.2.3Where the processing of your personal data is necessary to comply with our legal obligations.

    4.2.4Consent. This is where you have given consent for us to process your personal data. We will request your consent before we process any personal data that we obtain from your vehicle or device (including any travel records), in each case, where the purpose of use of that data is not strictly necessary to provide you with our services.

  5. DISCLOSURE OF YOUR INFORMATION

    5.1We may disclose aggregated information about our users, and information that does not identify any individual or device.

    5.2In addition, we may disclose personal data that we collect or you provide:

    5.2.1To our directors, officers, employees, subsidiaries and affiliates, including Honda Motor Co., Ltd, who are authorized and need to access such data.

    5.2.2To vendors, contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. We use the following third parties in this regard:

    1. Customer support providers such as Zendesk
    2. Cloud, mapping and voice instruction translation service providers such as Google and Apple
    3. Analytics services providers such as Firebase
    4. Data hosting providers such as Amazon Web Services
    5. IT services providers such as IBM Japan
    6. Development and app delivery service providers such as Drivemode

    5.2.3To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business or assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data about One ID Service users is among the business or assets transferred.

    5.2.4To fulfil the purpose for which you provide it.

    5.2.5For any other purpose disclosed by us when you provide the information.

    5.2.6With your consent.

    5.2.7To comply or cooperate with any court order, law or legal process, including to respond to any government, police, public authority or regulatory request.

    5.2.8To enforce our rights arising from any contracts entered into between you and us and for billing and collection.

    5.2.9If we believe disclosure is necessary or appropriate to protect the rights, property or safety of Honda or its group companies, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

  6. TRANSFERS OF PERSONAL DATA OUTSIDE EUROPE

    6.1The personal data that we collect from you may be transferred to, and stored at, a destination outside Europe; this especially applies to transfers from us to Honda Motor Co., Ltd.’s headquarters in Japan.

    6.2Under European data protection laws, Japan is considered a country which provides adequate protection to your personal data and your data protection rights. However, we may transfer your personal data to other non-European countries that may not have similar data protection laws to those applicable in Europe and so may not protect the use of your personal information to the same standard.

    6.3Where we transfer your information outside of Europe, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include:

    6.3.1relying on decisions issued by the relevant government authorities (or other relevant persons) declaring that a country or a company certifying to an international framework is adequately protective of personal information to a degree that allows us to safely transfer your personal information to that country or company;

    6.3.2imposing contractual obligations on the recipient of your personal information using standard clauses issued by the relevant data protection regulator (or other relevant body); or

    6.3.3relying on 'binding corporate rules' put in place by recipients of your personal information that have been approved by relevant data protection regulators.

    6.4If you use our services whilst you are outside Europe, your information may be transferred outside Europe in order to receive those services.

    6.5You can obtain more details about the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the information about us above.

  7. DATA RETENTION

    7.1We will retain the personal data that we collect about you while we provide you with our services only for as long as the relevant purpose requires it, except where we are required by law to retain it for a longer period, in which case, we will retain it for that period. Specifically, in relation to the personal data described in this policy, we will normally retain it for 10 years if you are located in the European Economic Area and 7 years if you are located in the UK, in each case, from the date we stop using the data for purposes other than to establish, bring or defend legal claim and for audit and analytics purposes.

    7.2The only exceptions to the period mentioned above are where:

    7.2.1The law requires us to hold your personal information for a longer period, or delete it sooner;

    7.2.2Where we are involved in legal claims, proceedings of investigations, in which case we will retain your information for until no further appeals are possible; or

    7.2.3You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;

    7.3If the personal data is processed for multiple purposes, the data will be automatically deleted or stored in a form that cannot directly be traced back to you, as soon as the last specified purpose has been fulfilled. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  8. YOUR RIGHTS

    8.1You have certain legal rights in relation to the personal data that we hold about you. These rights may vary depending on where you are located and which data protection laws will apply to the relationship between you and us but would typically include:

    8.1.1the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you

    8.1.2the right to request that we rectify your personal data if it is inaccurate or incomplete

    8.1.3the right to request that we erase your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:

    1. it is no longer necessary for us to retain your personal data for the purposes for which we collected it;
    2. you object to our processing of your personal data for our legitimate interests, and our legitimate interests do not override your own interests, rights and freedoms; or
    3. we are only entitled to process your personal data with your consent, and you withdraw your consent.

    8.1.4the right to request that we restrict our processing of your personal data in certain circumstances. This may include (but is not limited to) circumstances in which:

    1. you dispute the accuracy of your personal data (but only for the period of time necessary for us to verify its accuracy);
    2. we no longer need to use the personal data except for the establishment, exercise or defense of legal claims; or
    3. you object to our processing your personal data for our legitimate interests (but only for the period of time necessary for us to assess whether our legitimate interests override your own interests, rights and freedoms).

    8.2the right to object to us about our processing of your personal data

    8.3the right to receive any personal data which we process about you on the basis of your consent or on a contract (as opposed to any other legal ground) and where the processing is carried out by automated means in a structured, commonly used and machine-readable format and/or request that we transmit that data to a recipient where this is technically feasible (please note that this right only applies to personal data which you have provided to us)

    8.4the right to withdraw your consent to our processing of your personal data at any time (please note, however, that we may still be entitled to process your personal data if we can rely on another legal ground for doing so)

    8.5We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.

    8.6You can exercise your rights by contacting us using our contact information included herein. You can also lodge a complaint with the applicable data protection regulator if you think that any of your rights have been infringed by us. The information of the data protection regulator in the UK is as follows:

    Information Commissioner’s Office

    Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, UK

    Phone: 0303 123 1113

    E-mail: casework@ico.org.uk

    Website: https://ico.org.uk

  9. DATA SECURITY

    We introduce and maintain appropriate and reasonable physical, technical and organizational measures to safeguard personal data against unauthorized access, use or disclosure, or unauthorized or accidental loss, destruction or alteration. In particular, we implement appropriate internal information security policies and regulations, access controls, training and audits. Our employees that have access to personal data are obliged to keep personal data confidential and safe.

  10. CHANGES TO OUR PRIVACY POLICY

    10.1We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal data, we will post the new privacy policy on this page.

    10.2The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active email address for you and for periodically visiting this privacy policy to check for any changes.

ANNEX: PROCESSING OF PERSONAL DATA UNDER THE EU DATA ACT

This Annex outlines how Honda processes Product Data and Related Services Data generated by your use of Honda motorcycles (“Motorcycle”) and/or the RoadSync Duo (“App”). For a detailed overview on which data we have currently identified as Product Data and Related Services Data please see the information provided on the data types collected and processed, as outlined in the EU Data Act Information Sheet for the Motorcycle and RoadSync Duo service available via the App or Motorcycle Information Sheet , Roadsync Service Information Sheet (link).

Honda treats all Product Data and Related Services Data as personal data, as they are inextricably linked to you through your user account and/or vehicle identification number. Accordingly, their processing must generally comply with applicable data protection laws, including the GDPR.

  1. SCOPE AND DEFINITIONS

    1.1This Annex governs the processing of personal data that qualifies as Product Data and Related Services Data which can be lawfully requested under

    1. Chapter II of the EU Data Act (by you either directly or via third parties), or
    2. Chapter V of the EU Data Act (by Public Sector Bodies).

    1.2For the purposes of this Annex, the following definitions apply:

    1. Primary User: A natural or legal person who is registered with Honda as the owner of a Motorcycle and/or is the primary account holder of the App.
    2. Other User: A natural or legal person who is contractually authorised to temporarily use the Motorcycle and/or is contractually authorised to temporarily use the App (may include Invited Users).
    3. User: A Primary User and/or Other User.
    4. Product Data: Data generated through the use of the Motorcycle, designed by the manufacturer to be retrievable via electronic communication, physical connection, or on-device access.
    5. Related Services Data: Data representing the digitisation of user actions or events related to the Motorcycle, either recorded intentionally by you or generated as a by-product during the provision of a related service through the App.
  2. LAWFUL PROCESSING

    Honda processes Product Data and Related Services Data generally in accordance with the legal bases identified in the Privacy Policy above. Where Honda is required to make available Product Data and Related Services Data that qualifies as personal data we need to differentiate between three main scenarios:

    2.1Data subject is the requesting User: Making available Product Data and Related Services Data that qualifies as personal data to a user under Art. 4 (1) and Art. 5 (1) EU Data Act. In such circumstance the legal basis is Art. 6 (1) (a) GDPR as we are only complying with data subjects instructions which we deem as consent in the sense of this Article.

    2.2Data subject is not the requesting User: where Users make requests under Art. 4 (1) EU Data Act or where third parties make requests based on Art. 5 (1) EU Data Act (on request or on behalf of the User) without the requesting User being the data subject with respect to the data that is subject to such request, the following applies:

    2.2.1Where we know that the requesting User is not the data subject, we will require the requesting User or third party requesting according to Art. 5 (1) EU Data Act to provide evidence that the data subject has declared consent (Art. 6 (1) (a) GDPR. Where consent cannot be obtained, Honda might make the data available based on legitimate interest pursuant to Art. 6 (1) (f) GDPR (which will need to be assessed in each individual case of a request).

    2.2.2Where we have no indication or reason to believe that the requesting User is not the data subject, we have to rely on the requesting User or the requesting third party in Art. 5 (1) EU Data Act scenarios to have assessed that their access to the requested data available is in compliance with the GDPR. Before making Product Data and Related Services Data that qualifies as personal data available, we generally require requestors to confirm their commitment to comply with the GDPR by accepting EU Data Act terms of use as provided by Honda.

    2.3Requests by governmental institutions, bodies, offices and agencies: Providing access to public sector bodies, the Commission, the European Central Bank, or a Union body that demonstrates an exceptional need for specific data, as outlined in Article 15 Data Act, the Article 14 (1) Data Act scenario: in such cases the legal basis is Art. 6 (1) (e) GDPR because making available Product Data and Related Services Data that qualifies as personal data is necessary as a means of last resort to respond to a public emergency, where emergency response and resolution lie in the public interest.

    Clarification: The legal bases for processing outlined in Honda’s privacy policy remain fully applicable. The same holds true for provisions regarding the form of consent and the possibility of its withdrawal.

  3. REQUEST PROCEDURE

    3.1Requests under the EU Data Act must clearly indicate whether they are made under:

    1. GDPR (e.g. access, rectification), or
    2. Data Act (e.g. access to Product Data or Related Service Data).

    3.2The Primary User is responsible for ensuring that Other Users (e.g. alternate users, other users of shared accounts) are aware of this policy and consent to the sharing of data generated during their use of the connected product / provision of related services. Honda assumes that any data processed relates to the Primary User unless otherwise indicated.

    3.3Requests under the Data Act submitted by any Other User require verification whether that natural or legal person qualifies as a user. To the extent necessary verification may include the following:

    1. Valid personal identification (e.g. passport, national ID card etc);
    2. Documentation evidencing a contractual right to temporarily use the Motorcycle and/or App, linked to the Primary User;
    3. Indication of the specific usage periods of the Motorcycle and/or App by the Other User;
    4. Written declaration (text form being sufficient) that the request pertains exclusively to data generated during the Other User’s own use of the Motorcycle or App or in multiple user scenarios a written declaration (text form being sufficient) of consent of other data subjects affected in the request period, potentially also including the Primary User.