Privacy Policy regarding Honda RoadSync
1. About This Policy
We will process your personal data in compliance with every applicable law and any laws that replace them in the future, including but not limited to PERSONAL DATA PROTECTION ACT 2012 (“PDPA”)
In this privacy policy (this “Policy”), we provide information based on such laws related to processing your personal data. This Policy sets out the basis on which any personal data that you provide to us, or that we obtain about you from other sources, will be processed by us for our service of Honda RoadsSync (the “Service”). Please take the time to read and understand this Policy.
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/SG/privacy.html]. Please review it regularly. This Policy was last updated on 1st September 2022.
2. Information about us
For the purpose of data protection law, we, Boon Siew Singapore Private Limited (“we”, “us” and “our”) are data controller with respect to your personal data, and we are committed to respecting your privacy.
(a) Our office address:
【370 Ubi Road 3, Singapore 408651】
(b) Our email address:
【enquiry@boonsiewhonda.com.sg】
3. Definitions
In this Policy:
(a) your “personal data” means any data which relates to you and from which you can be identified. It may include contact details, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you;
(b) “processing” means any activity or operation that is carried out in respect of your personal data, such as collecting, storing, using, transferring or deleting it.
4. How we collect your personal data and what personal data we collect
We will process the following personal data about you. In connection with the Service, we collect information about you from your online device that you use to receive the Service. In addition, we also collect information about you that you give us in writing, by e-mails, or by other means. The information you give us is:
- 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 Service such as accelerometers, gyros, magnetometers, light, proximity (“Information from Sensors”);
- your user ID, application store install ID, e-mail address (“User IDs”);
- movement 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 devices, such as properties (including model number, brand name, manufacturer name, OS 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”);
- usage history such as time stamp, uu ID, installation properties, advertising ID (“Usage History”).
5. Purpose and legal basis of processing personal data
We use the personal data that we hold about you for the following purposes:
ü To provide or improve the quality of the Service;
ü To conduct usage analysis, to develop new services and products;
ü To communicate with you, including to deal with your questions, messages or requests, and to manage your complaints; and
ü To comply with laws and regulations applicable to us.
The legal basis for the processing of your personal data is:
ü Performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract
ü Where the processing of your personal data is necessary for the pursuance of our legitimate interests
ü Where the processing of your personal data is necessary to comply with our legal obligations
ü Where you give consent for us to process your personal data.
We will only use your personal data to the extent that it is necessary to do so to fulfil the purposes described above.
6. Disclosure of personal data to recipients
We may share your personal data with recipients in the situations described below:
ü Employees of ours who are authorized and need to access this data; and
ü Our external vendors or contractors, including developers of online tools, service providers for the operation of the Service, cloud service providers.
7. Transfers of personal data outside Singapore
The personal data that we collect from you may be transferred to, and stored at, a destination outside Singapore; this especially applies to transfers to Honda Motor Co., Ltd.’s headquarters in Japan and its subcontractors involved for the purposes prescribed in Section 5.
Where we transfer your personal data outside Singapore, we will ensure that:
(a) in accordance with requirements prescribed under PDPA, we, as an organisations under PDPA, enter into the contract, between the recipients under which the recipients bear a standard protection obligation to your personal data so transferred that is comparable to the protection under PDPA.
More information is available on
https://www.pdpc.gov.sg/Overview-of-PDPA/The-Legislation/Personal-Data-Protection-Act
(b) a compliant data transfer with each other and to keep the shared data secured and protected according to the official data protection regulations.
You can obtain more details about the protection given to your personal data when it is transferred outside Singapore (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.
8. Storage limit of personal data
We will retain the personal data that we collect about you while we provide you with our 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 apply the retention period stated below for each of the specific categories of personal data we collect for the Service:
Location Data: 5 years after Your last use of the Services
Information from Sensors: 5 years since the controller collects
User IDs: 5 years after Your last use of the Services
Travel Records: 5 years after Your last use of the Services
Information about Usage Environment: 5 years after Your last use of the Services
Information about Usage Status: 5 years since the controller collects
Usage History: 5 years since the controller collects
"Your last use" means the last time you launch the application on your devices used for the Service. Attention, 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 Service and then use an e-mail address that you did not use for such uninstalled application for the Services, the personal data collected from such uninstalled application for the Service may not be inherited and will be deleted after 5 years from Your last use of such uninstalled application.
9. 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; or
(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;
(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.
10. Obligation to provide personal data
Providing your personal data is not mandatory under law, but if you do not provide your personal data essential for providing the Service to us, you may not be able to use the Service.
11. Consent for transfers of personal data outside Singapore and related processing
We collect, use and analyze your personal data described above in Section 4 to provide and to improve the quality of the Service and develop new services and products (the “Purpose”), as provided for in Section 5. To achieve the Purpose, we must transfer your personal data to Japan, given that the processing activities for the Purpose is conducted only in Japan by Honda Motor Co., Ltd. and our recipients, as provided for in Section 6. Accordingly, we obtain your consent for the transfer of your personal data to Japan and related processing comprehensively on the application of your devices used for the Service. Please note that Japan may not ensure adequate data protection standards in light of the data protection rules of your country of residence. 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
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.