1.         About This Notice

 

Honda Motor Europe Ltd. (“HME”) and Honda Motor Co., Ltd. (“HM”) (“we”, “us” and “our”) are committed to ensuring that we process your personal data in compliance with applicable data protection laws, including the General Data Protection Regulation, the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (the "Data Protection Laws").

In this privacy notice (this “Notice”), we explain how we use the personal data of users of our Honda RoadsSync service (the “Service”), including the associated mobile application (the "App"). The Notice describes what data we collect, the purposes for which we use it, for how long we may keep it, and the third parties to whom we may disclose it. It also explains what rights you have in relation to your personal data. Please take the time to read and understand this Notice.

This Notice supplements any other fair processing or privacy notice that may be provided to you from time to time (including HME’s general UK notice https://www.honda.co.uk/privacy.html).

Note that the Notice does not apply to providers of third party services, including those which may connect or interact with the Service or which are linked to within the Service, and we recommend that you read their privacy policy to understand how they might use your personal data. We are not responsible for the use of your personal data by such third parties.

This Notice explains how we use, store and share the information we collect about you, how you can exercise your rights in respect of that information and the procedures that we have in place to safeguard your privacy. Please contact us by email at DPM-UK@honda-eu.com if you have any questions, comments or concerns about this Notice or how we handle your personal information, or if such information changes at any time.

2.         Information about us

 

For the purpose of the Data Protection Laws, Honda Motor Europe Ltd. (00857969) (Cain Road, Bracknell, Berkshire RG12 1HL, United Kingdom) and Honda Motor Co. Ltd. (2-1-1, Minami-Aoyama, Minato-ku, Tokyo 107-8556, Japan) are joint data controllers with respect to your personal data. This means that we are jointly responsible to you for processing your personal data. We have put in place an arrangement clarifying our respective tasks, duties, and responsibilities in order to comply with Data Protection Laws. If you wish to know more about this arrangement, please contact us using the contact information indicated below in Section 11.

3.         Changes to this Notice

 

This Notice may be changed from time to time. Any changes to this Notice in the future will be posted https://global.honda/en/voice-control-system/legal/GB/privacy.html and, where appropriate, notified to you by in-app pop-up. Please check back frequently to see any updates or changes to this Notice.

4.         Definitions

 

In this Notice, where we refer to:

(a)    your “personal data”, this means any data which relates to you and from which you can be identified. It may include contact details, information about how you use the Service and your location. We describe the personal data which we collect in connection with the Service in Section 5 of this Notice;

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

(c)    “processing”, this means any use of your personal data such as collecting, storing, using, transferring or deleting it.

5.         What personal data we use and how we collect it

 

This section describes the personal data which we use and collect in connection with the Service.

You provide us with some of this data directly, for example, when you subscribe for the Service, register in the App or when you communicate with us. This will only include your email address and the content of your communications, such as any feedback or complaints. You will need to have a Google account for Android devices or Apple ID for iOS devices in order to use the service and we will not have access to your account details.

We also collect or generate other data automatically when you use the Service. This is described in the table below:

Type of data	Description	Source
Location Data	This is obtained from your IP addresses and comprises region, country, city (including latitudes and longitudes).	The App
Sensor Data	This is obtained from the sensors of the smartphone or other device on which you use the App. It is comprised of data relating to acceleration, velocity, magnetic fields, light and proximity.	The App
User IDs	This is comprised of your user ID for the Service, your Google ID or Apple ID and your email address.	The App
Travel Records	This is comprised of movement records, namely total distance travelled, 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, and device time.	The App
Usage Environment	This is information which describes the environment in which the Service is used. It is comprised of information about: (i) your App, namely the app version; (ii) the mobile or other device on which you use the App, namely the device properties (model number, brand name, manufacturer name, OS version, carrier name, screen height and width, screen dpi, screen orientation), device capabilities (telephony, SMS, voice services, Google Play), device settings, language, default apps (music, navigation, telephony, SMS), network connections and connection status, accessories and devices connected over Bluetooth or WiFi (e.g. headset); (iii) the vehicle with which you use the Service, namely the type of your vehicle, the vehicle's interface, the vehicle's display and any switch your vehicle may have to operate the Service; and (iv) and the device which connects your vehicle to the Service (the "BT Unit"), namely its model, serial number, hardware, software and MacAddress.	The App The vehicle The BT Unit
Usage Status	This is comprised of information about whether you are calling, being navigated, playing music, in message mode, in call mode, event ID, and the time of the event.	The App
Usage History	This is comprised of the times when you used the Service, your device ID, installation properties, advertising ID, session ID and the vehicle destination ID.	The App The vehicle
Your Instructions	This includes all instructions you provide through the App. When you give voice instructions, your phone’s speech recognition service translates these to technical instructions which are provided to the App.	The App

 

In addition, we also obtain personal data from the following third parties:

·       For Android devices: Google, who provide us with your Google ID to provide you with the App;

·       For Apple devices: Apple, who provide us with your Apple ID to provide you with the App;

·       Your phone’s audio and speech recognition services providers that translate your voice requests into technical instructions on the App for the Service;

6.         Why we use your personal data

 

The following table sets out the purposes for which we use your personal data in connection with the Service. We only use your personal data to the extent that this is necessary to fulfil the relevant purposes.

Under the Data Protection Laws, we are also required to have a "lawful basis" to process your personal data. This is summarised in the table below.

Why we use your personal data	The personal data we use	Lawful basis
To provide you with the Service.	User ID Location Data Travel Records Usage Environment	To take steps at your request to enter a contract with you, and for the ongoing performance, management and facilitation of such contract.
To improve the Service, including the quality of the Service, the App and the user experience. This involves carrying out analytics to understand how the Service is used.	User ID Location Data Sensor Data Travel Records Usage Environment Usage Status Usage History	The processing is necessary for our legitimate interest to develop and improve our products and services.
To plan and develop new products and services. This also involves carrying out analytics to understand how the Service is used.	Location Data Sensor Data Travel Records	The processing is necessary for our legitimate interest to develop and improve our products and services.
To communicate with you in relation to the Service. This includes sending you service communications, dealing with questions, messages or requests you may have, and managing complaints.	Contact details Content of communications between us	In some cases, the processing is for necessary for the ongoing performance, management and facilitation of our contract with you.   Where the processing is not necessary for the contract, we process your data on the basis that it is necessary for our legitimate interest to provide you interest to provide you with a good customer experience.

 

 In addition, we may process the personal data described in this Notice:

·       To comply with laws and regulations applicable to us (on the basis that this processing would be necessary to comply with legal obligations)

·       To protect our business and the Service, including by enforcing our terms and conditions, obtaining legal advice and progressing legal claims (on the basis that this processing is necessary for our legitimate interest to protect our business)

·       To offer for sale or obtain funding for, our business including our assets and services (on the basis that this processing would be necessary for our legitimate interest to conduct our business in a profitable manner)

We have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interests as the lawful basis on which to process your personal information in certain circumstances (we have stated this above and set out our legitimate interests). We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest does not override your privacy rights as an individual. If you require further information regarding this balancing test, please contact us.

 

7.         Sharing your personal data

 

We will only share your personal data as described in this section.

For the purposes set out in the previous section, we will only share your personal data with:

·       Our employees and affiliates who are authorized and need to access the data;

·       Our external vendors or contractors, including developers of online tools, service providers for the operation of the Service, and cloud service providers. More specifically, your personal data will be shared with our:

·       App and platform provider namely, Drivemode

·       Analytics services providers namely, Google and Firebase

·       Customer support service provider currently, Zendesk

·       Cloud hosting provider namely, Google

·       App providers, in situations where you use the App to control other apps, such as Google Maps, HERE Maps or media providers

·       Diagnostics services providers

·       Providers of our central IT systems, such as our customer management platform

·       our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us)

·       insolvency practitioners

·       prospective buyers or funders of our business or assets

·       competent authorities and regulators, including law enforcement or fraud prevention agencies and the courts, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters

 

We may also disclose your personal data to third parties as may be required in the following situations:

·       in the event that we consider selling any business or assets, in which case we will disclose your personal information to any prospective buyers of such business or assets;

·       if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;

·       in the event we are the subject of any insolvency situation (e.g. the administration or liquidation);

·       in order to enforce or apply our terms and conditions, policies or any contract we have with you or have facilitated between you and a third party;

·       to protect our rights, property, or safety, or that of our people, or others. This includes exchanging information with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of safety, crime prevention and fraud protection; and

·       if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

 

Third party services

This Notice does not cover third party websites, apps or portals that we may link to from our Services and does not cover any services of other providers. We are not responsible for the privacy policies and practices (including use of cookies) of such third parties even if you accessed the third party website, app, portal or service using links from our Services.

We recommend that you check the policy of each provider and contact such third party if you have concerns or questions. Any provider of other services such as providers of data packages, mobile networks, Wi-Fi hotspot services, music or messaging services are separate controllers of your data and are responsible for their own processing.

8.         International transfers of personal data

 

Your personal data will be transferred to the EEA, the UK and Japan.

Both the EEA and the UK recognise Japan as providing an adequate level of protection of personal data. The EEA and the UK also recognise each other as providing such an adequate level of protection. As such, data can be transferred freely between these jurisdictions.

The use of Google Analytics may also involve transfers of data to the U.S. and where this is the case we shall ensure that appropriate contractual and security measures (including standard contractual clauses) are in place to protect your personal data.

9.         Retention of your personal data

We will only process your personal data for as long as necessary to achieve the purposes for which we process it. Once it is no longer needed, we will securely and irretrievably delete it or anonymise it so that it can no longer be linked to you.

The table below sets out the maximum period of time for which we retain your personal data. Specific types of data which are included in these categories may be deleted within a shorter period. However, please note that we may retain the data for longer periods if we are required to retain it by law or if it is needed for the establishment, exercise or defence of legal claims.

Type of data	Maximum retention period
Location Data	Up to 5 years from when you last use the Service
Sensor Data	Up to 5 years from when the data is collected
User IDs	Up to 5 years from when you last use the Service
Travel Records	Up to 5 years from when you last use the Service
Usage Environment	Up to 5 years from when you last use the Service
Usage Status	Up to 5 years from when the data is collected
Usage History	Up to 5 years from when the data is collected
E-mail address	Up to 5 years from when you last use the Service
Communications you send to us	Up to 5 years from the date of the communication

 

Your "last use" means the last time you launch the application on your devices used for the Service. If you stop using the Services for 5 years, all your personal data will be deleted automatically.

If you have uninstalled the application and then reinstall the application for the Service using an e-mail address that you did not use previously, the personal data collected from the application for the Service prior to this uninstallation may not be inherited and will be deleted after 5 years from your last use of the uninstalled application.

For more detailed information about these retention periods, please email our data protection manager at DPM-UK@honda-eu.com.

10.       Your rights

 

As a data subject, you have a number of legal rights in relation to the personal data that we process about you.

Right	Description
(1) To be informed	A right to be informed about the personal information we hold about you. This Notice (together with HME’s general UK notice https://www.honda.co.uk/privacy.html) sets out how we collect, hold and store your information, what we do with it and why. If you have any questions, please contact us so we can provide you with the further information you require.
(2) Of access	A right to access the personal information we hold about you.
(3) To rectification	A right to require us to rectify any inaccurate or incomplete personal information we hold about you.
(4) To erasure	A right to ask us to delete the personal information we hold about you. This right will only apply where (for example): ·       we no longer need to use the personal information to achieve the purpose we collected it for; ·       where you withdraw your consent if we are using your personal information based on your consent; or ·       where you object to the way we process your data (in line with Right 7 below). Note that you may trigger the deletion of your profile information and the anonymization of all vehicle data by deleting your account. You may also trigger the anonymization of all vehicle data by de-enrolling your vehicle (although this does not result in the deletion of information in the app).
(5) To restrict processing	In certain circumstances, a right to restrict our processing of the personal information we hold about you. This right will only apply where (for example): ·       you dispute the accuracy of the personal information held by us; ·       where you would have the right to ask us to delete the personal information but would prefer that our processing is restricted instead; or ·       where we no longer need to use the personal information to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claims.
(6) To data portability	In certain circumstances, a right to receive the personal information you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.
(7) To object	A right to object to our processing of the personal information we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims.
(8) In relation to automated decision making and profiling	A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. Note that the Service does not involve automated decision-making.
(9) To withdraw	A right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with marketing material). Please note that the withdrawal shall only be effective for the future. Processing that occurred before the withdrawal shall not be affected. Note that we do not rely on consent for any processing carried out in connection with the Service.
(10) To be provided with the essence of the arrangement between joint controllers	Honda Motor Europe Ltd. and Honda Motor Co. Ltd. act as joint controllers when processing personal data in connection with this Service. You have a right to request the essence of the arrangement which the parties have put in place between them to ensure compliance with Data Protection Laws.

 

You can exercise your rights by contacting our data protection manager at DPM-UK@honda-eu.com.

11.       Contact information

 

If you have any questions about this Notice, your rights, or any other issues regarding the protection of your personal information, please contact our data protection manager using the contact information below.

Address: Data Protection Manager, Honda (UK), Cain Road, Bracknell, Berkshire, England, RG12 1HL

E-mail Address: DPM-UK@honda-eu.com

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal information. However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to our supervisory authority, which is the UK's Information Commissioner's Office. Their address is: First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

If you would like this notice in another format (for example audio, large print, braille) please contact us using the details above.

 

Last updated: August 2022