HONDA MY GENERATOR APP CUSTOMER PRIVACY NOTICE
Honda is committed to protecting and respecting your privacy. This Privacy Notice tells you how Honda Motor Europe Limited (“Honda”, “we”, “us”) processes your personal data when you visit, download, or contact Honda in relation to the Honda My Generator mobile application software known as My Generator (including any services which may be accessible via the application) (collectively the “App”). This Privacy Notice also describes your personal data protection rights, including a right to object to some of the processing that Honda carries out. More information about your rights, and how to exercise them, is set out in the “Your Choices and Rights” section.
We may also provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.
Depending on your relationship with Honda, we may also provide or may have already provided you with other notices about our use of your personal information, for example where you have already bought another Honda product, you may have agreed to our contacting you in relation to the maintenance and upkeep of that Honda product, or in relation to the receipt of other communications or marketing information from Honda. Those notices are not replaced by this Privacy Notice and are therefore, still in effect, as may be applicable.
What Personal Data We Collect
The Honda My Generator app uses identifier data unique to your device in order to communicate with the Honda generator and third-party software, devices, networks and services, as further set out in and in accordance with this Honda Privacy Notice. Honda does not, however, receive, store or otherwise process any data which enables the identification of an individual person as a result of them using the Honda My Generator app, nor does it provide such data to third-parties.
We process the following types of personal data:
• When you use the App: Technical details of your use of the App such as your IP address and operating system, IMEI number, browser type (for visits to our website), details of the device you are using to access the App (“Device”) (e.g. your Device serial number, unique identification number, MAC address) and technical and event based data in relation to your usage of your Device (e.g. internet and Bluetooth pairing and connectivity data and session duration);
• Why We Collect, Use and Store this Personal Data
We collect, use and store your personal data for the reasons set out below.
· Where necessary for Honda’s legitimate interests.
o to deliver the App and related services to you;
o to administer the App;
o to enable you to download updates to the App and any replacements;
o to allow us to improve and optimise the functionality of the App and Honda products and services (particularly our Honda Generator range);
o to understand which parts of the App are popular/most used, or those which need changing/upgrading;
o to respond to user questions and complaints;
o for internal record keeping;
o for management and audit of our business operations including management analysis, auditing, forecasting, business planning;
o where necessary as part of any restructuring or sale of Honda or a relevant Honda Group company’s business or assets; and
o to gather anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the performance of the App – please see ‘Aggregated Information’ below.
· Where necessary to perform any contract Honda has with you or to take steps to enter into it.
o For example, providing you with technical support in relation to your Honda Generator, providing the service offered by us via the App and for any other purposes related to the management of your legal relationship with Honda.
· Where necessary to comply with a legal obligation.
o For example, when you exercise your legal rights under data protection law, to verify your identity, for the establishment and defence of our legal rights, for activities relating to the prevention, detection and investigation of crime (which may involve sharing your information with law enforcement agencies, as explained below) and for compliance with legal and regulatory responsibilities that apply to us.
· Aggregated Information
o Honda will also gather anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the App, analyse trends and, tailor products. Aggregated personal information does not personally identify you or any other user of the App.
How We Share Your Personal Data
(a) Transfers within the Honda Group of Companies
We share your personal data with members of the Honda Group.
For the purposes mentioned above, your personal data will be processed in, or accessed from, members of the Honda Group of Companies situated in jurisdictions outside the UK and European Economic Area ("EEA") that do not have equivalent data protection laws to those in the UK and EEA. When we transfer your data within the Honda Group of Companies, we make use of standard contractual data protection clauses, which have been approved by the European Commission.
Transfers outside the UK and EEA
When personal data is transferred internationally, we will rely on acceptable and defined legal mechanisms to ensure that we always protect personal data. In doing so, we may use standard contractual data protection clauses, which have been approved by the European Commission and currently adopted by the UK Government. We may also transfer your data. We may also transfer your data to organisations which have corporate rules in place to protect your data, which have been approved by the EU data protection authorities. Alternatively, certain countries like Japan, are also deemed to be adequate countries for the purposes of transferring your personal data and Honda Motor Europe may make use of such ‘adequacy’ designations. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.
(b) Transfers to other organisations
· Transfers to third parties if we are under a duty to disclose your personal data in order to comply with a legal obligation or if we consider this is necessary for us to protect the rights, property or safety of Honda, our customers or others.
· Transfers to government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
· Transfers to prospective or actual buyers in the event that Honda, or any part of the Honda Group, sells any of its business or assets which includes personal data.
Your Choices and Rights
(a) Your general Choices and Rights
· You have the right to be informed about the processing of your information (this is what this notice sets out to do) to ask Honda for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format.
· You can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
· Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Honda processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
(b) Your Right to Complain to a Supervisory Authority
You also have the right to complain to a supervisory authority for data protection. The supervisory authority could be in the place where you live, or where you work, or where a breach of data protection obligations has occurred.
Updates to this Privacy Notice
This Privacy Notice may be updated periodically. We will update the date at the top of this Privacy Notice accordingly and encourage you to check for changes to this Privacy Notice, which will be available on the App. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Privacy Notice, as required by applicable law.
The App is controlled by Honda Motor Europe Limited (company number 857969) which is the data controller for personal data collected via the App and whose registered address is Cain Road, Bracknell, Berkshire, England, RG12 1HL.
If you have any questions about this Privacy Notice, please contact our data protection officer at DPO@honda-eu.com.