HONDA MII-MONITOR 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, use, or contact Honda in relation to the Honda Miimo mobile application software known as Mii-monitor (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 up keep 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
We process the following types of personal data:
• Location Data: information from the GPS Global Positioning System in the product defining the location of the Honda Miimo;
• Information to create a user profile: such as the serial number of your Honda Miimo, your email address and password, age range, City and Country;
• When you use the App: Technical details of your use of the App such as your IP address and operating system, 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);
• Where you contact us directly about the App: your name and contact details (such as your address, postal code, country, telephone numbers and/or e-mail address) and the reason for your contact;
• Where you contact the authorised Honda dealer (who sold you your Honda Miimo (“Dealer”)) via the App about your Honda Miimo: your name and contact details (such as your address, postal code, country, telephone numbers and/or e-mail address), the reason for your contact and information about your Honda Miimo or Device to help diagnose any issues you may be experiencing;
• When you contact us: we may collect information about services that interest you;
• Any other information you submit to us: such as signatures, photographs, opinions, your location and any other information you provide.
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, including to send you alerts and service notifications;
o to administer the App;
o to enable you to download updates to the App and any replacements;
o to respond to user questions and complaints;
o to create a profile of you to decide what products and services to offer to you for direct marketing purposes;
o for internal record keeping;
o for management and audit of our business operations including management analysis, auditing, forecasting, business planning;
o to ask you to provide your opinion or participate in surveys about our products and services (by push notifications) and to undertake and analyse those surveys and research, this is to allow us to benchmark and improve our products and services; and
o where necessary as part of any restructuring or sale of Honda or a relevant Honda Group company’s business or assets.
· Where you have given consent.
o To provide you with direct marketing including information about goods and services which may be of interest to you by messages in the App (to which you will be alerted by push notifications). We will always offer a chance to unsubscribe from direct marketing at any time.
o To track and analyse usage of the App, in order to improve and optimise the functionality of the App and Honda products and services (particularly our Miimo range). These analytics are normally done on an aggregated statistical basis).
· Where necessary to perform any contract Honda has with you or to take steps to enter into it.
o Responding and/or dealing with your requests or enquiries sent through the App or otherwise, providing you with technical support in relation to your Honda Miimo, providing the service offered by us via the App (which includes sharing your information with third parties, on which see below) and for any other purposes related to the management of your legal relationship with Honda.
· Where necessary to comply with a legal obligation.
o 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.
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.
· In the event of any product recall or litigation, personal data may be shared with our parent company, Honda Motor Co. Ltd., (HM) in Japan, for the purpose of investigating any potential technical issues and coordinating group insurance.
· HM also arranges technical support for the App.
(b) Transfers to Honda authorised dealers and repairers
We share your personal data with your Dealer to enable them, with our assistance, to provide you with technical support relating to your Honda Miimo. Your Dealer is a controller of your personal data, separately from Honda, therefore, they will process your personal data in accordance with their own privacy notice. We therefore encourage you to review your Dealer’s privacy notice.
(c) Amazon Alexa
You have the option of controlling your Honda Miimo mower via Amazon Alexa voice commands. To do so, you have to connect your Honda Miimo to Amazon Alexa. If you control your Honda Miimo via Alexa, you may have to transmit personal data via Amazon to Honda Miimo and vice-versa. If you give voice commands to Amazon Alexa in order to control Honda Miimo or retrieve information from your Honda Miimo, voice data are transmitted to Amazon and used by Amazon to perform the service. These data may be personal data. By connecting your Amazon Alexa and Honda accounts and by activating skills, you make it plain that the Honda Miimo installed on your system is to be controlled via Amazon Alexa and that information is to be output via Amazon Alexa. We exchange data with Amazon Alexa in this context. Amazon may process your personal data for its own purposes in accordance with any applicable privacy notices of Amazon and we have no influence over such processing. Please refer to Amazon's privacy notices with regard to Alexa for more information on data processing by Amazon.
(d) Transfers to companies providing services under contract
Your personal data will be shared with companies providing services under contract to the Honda group of companies, such as the companies set out below:
· App developers (current providers: Bella Dati)
· IT hosting (current provider: Amazon Web Services)
· Cloud server operator (current provider: Bella Dati)
· IT maintenance provider (current provider: Bella Dati)
· Professional advisors, such as law firms
(e) 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.
Transfers outside the UK and EEA
In providing you with the App, we may transfer the personal data described in this policy to Honda Motor Limited in Japan. Japan is deemed by the European Commission and the UK Secretary of State as providing an adequate level of protection of personal data.
When you use Amazon Alexa, we also transfer personal data to Amazon so that Alexa may respond to your commands. We transfer personal data to Amazon on the basis that the transfer is necessary for us to provide you with the service you requested, therefore, the transfer is necessary for the performance of our contract with you. Once personal data is transferred to Amazon, Amazon may transfer your personal data to other jurisdictions outside the European Economic Area and the UK.
We do not currently transfer your personal data outside of the UK or the European Economic Area except as set out above. We may engage in other international transfers of your personal data in the future, in which case we will update this privacy notice beforehand. In doing so, we may:
· rely on determinations of adequacy of the level of data protection provided by other countries, which are issued by the European Commission and/or the UK Secretary of State
· use standard contractual data protection clauses, which have been approved by the European Commission and/or by the UK Government (as appropriate);or
· rely on corporate rules in place to protect your data, which have been approved by the EU data protection authorities or the UK Information Commissioner (as appropriate).
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.
Your Choices and Rights
(a) Your general Rights and Choices
· 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 Rights and Choices regarding Direct Marketing
Honda may give you the opportunity to opt-in (consent) to receiving direct marketing communications in the App.
If you would then decide you do not want us to send you direct marketing in the App, we would then provide you with the facility to opt out of receiving direct marketing communications.
(c) 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.
We will retain your personal data only for as long as we need it for the purposes set out in this Privacy Notice. Unless the data needs to be retained to satisfy a legal obligation or because it may be relevant to a dispute, within 2 years after the end of your relationship with Honda for providing the HRM3000 Live service, we will take steps to delete your personal data or hold it in a form that no longer identifies you.
Links to third party sites
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 provided 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.