HONDA The Power of Dreams

1. About This Policy

Honda Australia Motorcycle and Power Equipment Pty Ltd (“we”, “us” and “our”) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information.  This document is our privacy policy (“Policy”) in respect of personal information that we may collect as part of the Honda RoadSync service and associated application software (“Services”), and it tells you how we collect and manage such personal information.  This Policy does not apply to personal information collected by us in any other context.  Please refer to our general privacy policy available on https://motorcycles.honda.com.au/privacypolicy.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) in respect of the collection, management and disclosure of your personal information.

This Policy may be changed from time to time.  Any updated versions of this Policy will be posted on our website at [https://global.honda/en/voice-control-system/legal/AU/privacy.html].  Please review it regularly.

This Policy was last updated on 1st February 2023.

2. Information about us

(a) Our office address:

Honda Australia Motorcycle and Power Equipment Pty Ltd

Level 4, 6 Gladstone Street,

Moonee Ponds VIC 3039

(b) Our email address:

MPE.Compliance@honda.com.au

3. Definitions

In this Policy:

(a) your “personal information” has the meaning given to it in the Privacy Act.  In general terms, it is any information that can be used to personally identify you.  This may include your email address.  If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information;

(b) our “affiliates” includes our subsidiaries, our parent companies, and any subsidiaries of our parent companies; and

(c) “processing” means any activity or operation that is carried out in respect of your personal information, such as collecting, storing, using, disclosing, transferring or deleting it.

4. How we collect your personal information and what personal information we collect

In connection with the Services, we collect your personal information when you use the Services and from the mobile device and vehicle that you use to receive the Services. In addition, we also collect information about you by other means, such as personal information that you give us in writing or by e-mail.

We may collect and process the following types of personal information, depending on your interaction with us and the Services:

• location data obtained from IP addresses, such as region, country, city (including latitudes and longitudes) (“Location Data”);
• information collected through sensors of your devices used for the Services such as accelerometers, gyros, magnetometers, light, proximity (“Information from Sensors”);
• your user ID, application store install ID, e-mail address (“User IDs”);
• movement and location records such as total distance, average speed, starting point and stopping point of a movement, universally unique identifiers (uu ID), trip ID, app session ID, time, latitude, longitude, accuracy, speed, speed accuracy, distance, bearing, bearing accuracy, altitude, vertical accuracy, location provider, Geohash, device time, etc. (“Travel Records”);
• usage environment of your mobile devices used to receive the Service, such as properties (including model number, brand name, manufacturer name, operating system version, carrier name, screen height and width, screen dpi, screen orientation, etc.), settings, online connection status, and other detailed information about your devices used for the Service (e.g. vehicle, headset, smart phone and other devices connected via Bluetooth or Wifi, network) (“Information about Usage Environment”);
• usage status such as whether you are calling, being navigated, playing music, or message mode, call mode, event uu ID, time (“Information about Usage Status”); and
• usage history such as time stamp of previous use of the Service, uu ID, installation properties, advertising ID (“Usage History”).

5. Consequences for not providing personal information

Providing your personal information is not mandatory under law, but if you do not provide all or part your personal information, you may not be able to use the Service or you may not be able to obtain the full functionality of the Services.

6. For what purposes do we collect and process your personal information

We collect and process your personal information that we hold about you for the following purposes:

(a) To provide, support, maintain or improve the quality of the Service;

(b) To conduct usage analysis, to develop new services and products;

(c) To communicate with you, including to deal with your questions, messages or requests, and to manage your complaints;

(d) To comply with laws and regulations applicable to us; and

(e) For any other purpose which we disclose to you at the relevant time.

7. Disclosure of personal information to recipients

We may share and disclose your personal information to the following recipients in connection with the purposes above:

• our affiliates, including Honda Motor Co., Ltd;
• employees of ours and our affiliates who are authorized and have a need to access the personal information; and
• external vendors or contractors of us or our affiliates, including developers of online tools, service providers for the operation of the Service, and cloud service providers.

8. Disclosure of personal information outside Australia

The personal information that we collect from you may be disclosed or transferred to, and stored at, a destination outside Australia, including the following:

• our related bodies corporate, including Honda Motor Co., Ltd., located in Japan; and
• data hosting and other IT service providers, located in Japan.

We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

9. Storage limit of personal information

We will retain the personal information that we collect about you while we provide you with the Service 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, we will generally apply the retention period stated below for each of the specific categories of personal information we collect for the Service:

Location Data, User IDs, Travel Records and Information about Usage Environment: 5 years after your last use of the Services

Information from Sensors, Information about Usage Status and Usage History: 5 years after collection of the data

In this Section, "your last use of the Services" means the last time you launch the application on any device used for the Services. This means that, if you stop using the Services for 5 years, all your personal data will be deleted automatically.

If you have uninstalled and reinstall the application for the Services and then use an e-mail address that you did not use for such uninstalled application for the Services, the personal information collected from such uninstalled application for the Services may not be inherited and will be deleted after 5 years from your last use of such uninstalled application.

Notwithstanding the above general retention periods, personal information is destroyed or de-identified when no longer needed in accordance with applicable laws.

10. Your rights

You have a number of 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:

(a) the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;

(b) the right to request that we rectify your personal data if it is inaccurate or incomplete;

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

  (i) it is no longer necessary for us to retain your personal data for the purposes for which we collected it;

  (ii) 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

  (iii) we are only entitled to process your personal data with your consent, and you withdraw your consent;

(d) the 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:

  (i) you dispute the accuracy of your personal data (but only for the period of time necessary for us to verify its accuracy);

  (ii) we no longer need to use the personal data except for the establishment, exercise or defence of legal claims; or

  (iii) 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);

(e) the right to object to us about our processing of your personal data;

(f) the 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;

(g) the 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.

You can exercise your rights by contacting us using the information about us indicated below in Section 12. You can also lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by us.

11. Information relating to processing in Japan

As noted in Section 8, we may transfer your personal data to Japan, as the processing activities for the purpose set out in Section 6 is conducted only in Japan by Honda Motor Co., Ltd. and other recipients, referred to in Section 7. The overview of data protection standards in Japan is as follows:

(1) Applicable data protection law

Act on the Protection of Personal Information

(2) Data protection authority

Personal Information Protection Commission

(3) Rights of data subjects

Under the Act on the Protection of Personal Information, data subjects have the rights (under certain requirements) set forth below:

• To receive personal data
• To request corrections of or additions to personal data
• To request that personal data be deleted
• To require that personal data processing or the disclosure of personal data to a third party be ceased

(4) Other safeguards

The Act on the Protection of Personal Information includes provisions that provide the following requirements to protect personal data:

• Lawful and fair collection
• Purpose limitation
• Data accuracy
• Implementation of appropriate security measures
• Restrictions on transfers to third parties
• Restrictions on transfers to third parties in foreign countries

12. Contacts and the process for complaining about breach of privacy

If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint.  Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below.  We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome.  We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint.  If we receive a response from you, we will assess it and advise if we have changed our view.

If you are not satisfied with the way your privacy-related complaint is handled by us, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to lodge a complaint with the OAIC may be found at www.oaic.gov.au or by calling 1300 363 992.

If you have any questions about this Policy, your rights, or any other issues regarding the protection of your personal information, you can reach us using the information about us above in Section 2 or contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially.  Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.  We will aim to ensure that your complaint is resolved in timely and appropriate manner.

Please contact our Privacy Officer at:

Honda MPE Privacy Officer

Ph: 03 9270 1148

Email: privacyofficer@honda.com.au