HONDA PRIVACY NOTICE (UK)

December 2018

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 a dealership, visit our Honda websites, download and use our apps, or contact Honda in relation to your Honda product, (all "Honda Contact"). 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.

What Personal Data We Collect

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We process the following types of personal data:

  • Contact information: such as your name, address, phone, email, and other similar information.
  • Information to create a user profile: such as your username, password or PIN.
  • Vehicle information: such as your Vehicle Identification Number (VIN) and date of purchase.
  • Product information: such as your product id and date and location of purchase.
  • Financial information: such as your bank account number, sort code and billing address.
  • Details regarding your connection to the Honda Websites or Honda apps: such as your operating system; your browser type (for visits to our website); details of the device you are using (e.g. your device serial number, unique identification number and MAC address); and your approximate geographic location of connection (to the nearest city).
  • Details of your visit to the Honda Websites or Honda apps: such as your time of visit; your connection length and your use of Honda Websites or Honda apps (e.g. items that you click on and requests that you make).
  • Any other information you submit to us in connection with Honda Websites or Honda apps: such as signatures, photographs, opinions and your location.

Why We Collect, Use and Store this Personal Data

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We collect, use and store your personal data for the reasons set out below:

  • Where necessary for Honda’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights.
        o to deliver the Honda Websites or Honda Apps and related services to you;
        o to administer Honda Websites or Honda Apps  resources;
        o to allow us to improve and optimise the Honda Websites or Honda Apps and Honda products and services;
        o to allow us to understand your interests and preferences so that Honda Websites or Honda Apps  can be tailored to you;
        o to respond to your online requests or enquiries, for example by sending you a brochure, locating your nearest Honda dealership, booking you a test drive, or arranging a service for your Honda vehicle or product.
        o to notify dealers and Honda branches of any upcoming services, test drives or other appointments in relation to you or your Honda vehicle or Honda product;
        o to contact you for the above two purposes (directly or through a Honda group company, a Honda authorised dealer, a relevant partner or agent) by post, telephone, e-mail, SMS or push notification;
        o to ask you to provide your opinion or participate in surveys about our vehicles, products services, and dealerships;
        o to respond to user questions and complaints; and
        o for internal record keeping

    Further information in relation to Honda’s legitimate business interest, and how we balance our interest against the privacy rights of our customers, can be provided upon request.
  • Where you have given consent.
        o To access information stored on your device to understand your interests and to improve your customer experience e.g. by providing you with tailored content and offers which align with your personal interests.
        o To provide you with direct marketing including our “Engine Room Newsletter” and other information about, or offers relating to, Honda products and services which may be of interest to you by post, telephone, SMS, email and push notification.
        o Where you provide your consent to receive direct marketing, we will always offer you the opportunity to withdraw your consent and to unsubscribe from our Newsletters.
  • Where necessary to perform any contract Honda has with you.
        o For example, to facilitate online payments and to deliver products and services.
  • Where necessary to comply with a legal obligation.
  • Where necessary to protect Honda’s legitimate interests and legal rights, and where our interests are not overridden by your data protection rights.
        o Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulatory, auditing, legal claims (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements

Honda will also convert personal data into anonymous data and use it (normally on an aggregated statistical basis) for e.g. market research and analysis, to improve the Honda Websites or Honda Apps, to analyse trends and to assess the success of advertising campaigns. Aggregated personal information does not personally identify you or any other use of the Honda Websites or Honda Apps.

How We Share Your Personal Data

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(a)    Transfers within the Honda Group of Companies 
We share your personal data with members of the Honda Group as set out below:

  (i)  Honda Finance Europe PLC (HFE): HFE provides financing options for Honda customers in the UK. HFE is a company incorporated in England.
  (ii)  Honda Motor Co., Ltd. (HM): HM, our parent company, receives information on product recalls, product liability claims and information on orders for new NSX vehicles (including the customer name and order specifications). HM is a company incorporated in Japan.

For the purposes mentioned above, your personal data will be processed in, or accessed from, Japan. When transfer your data to HM in Japan, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

(b)    Transfers to Honda authorised dealers and repairers 

We share your personal data with Honda authorised dealers and repairers in the EEA. This data is shared so we can fulfil your test drive, service enquiries, and also share your ownership details with your sales or servicing dealers where you have requested assistance.

A full list of Honda dealers may be accessed below:

Cars: http://www.honda.co.uk/cars/dealer-list.html
Motorcycles: http://www.honda.co.uk/motorcycles/dealer-list.html
Lawn & Garden: http://www.honda.co.uk/lawn-and-garden/dealer-list.html
Marine: http://www.honda.co.uk/marine/dealer-list.html
Industrial: http://www.honda.co.uk/industrial/dealer-list.html
ATVs: http://www.honda.co.uk/atv/dealer-list.html
Snowthrowers: http://www.honda.co.uk/snowthrowers/dealer-list.html

You can also search for your nearest Honda dealer using the following web links:

Cars: http://www.honda.co.uk/cars/dealer-search.html
Motorcycles: http://www.honda.co.uk/motorcycles/dealer-search.html
Lawn & Garden: http://www.honda.co.uk/lawn-and-garden/find-a-dealer.html
Marine: http://www.honda.co.uk/marine/dealer-search.html
Industrial: http://www.honda.co.uk/industrial/dealer-search.html
Snowthrowers: http://www.honda.co.uk/snowthrowers/dealer-search.html
ATVs: http://www.honda.co.uk/atv/dealer-search.html

(c)   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 the companies set out below:

  • Honda Website providers & hosting/www.Honda.co.uk
        o Main platform (current provider: Digitas LBi Limited)
        o Honda Used Car locator (current provider: Cox Automotive Limited)
        o Honda e-Commerce Power Equipment website, including live chat provider (current provider: The Hut.com Limited )
  • Google analytics provided for website improvement and optimisation (Google LLC)
  • Honda Motorcycle Dealer Website templates (participating Dealers only) (current provider: One Black Bear Limited)
  • Motorcycle Experiences (current providers: Honda School of Motorcycling, Dave Thorpe (Dthorc Limited), The Ron Haslam Race School, Inch Perfect Trials Limited)
  • Honda Used Motorcycle Website (current provider: One Black Bear Limited)
  • Brochure fulfilment (current provider: RR Donnelley & Sons Company)
  • Email Broadcast (current provider: Celerity Ltd, & Adestra Limited)
  • Event Management (current provider: Noble Limited, KCS Limited)
  • Event tablet data collection (current provider: Brandwidth Limited)
  • Fleet & B2B Management: (current provider: ROI Limited)
  • IT help desk provider (current provider: ATOS IT services UK Limited)
  • IT hosting (current provider: IBM Belgium SPRL/BVBA)
  • IT maintenance provider (current provider: IBM United Kingdom Limited)
  • Data Management (current provider: Direct Select (192) Limited T/A UKChanges , Carweb Limited, ETL)
  • Data analysis (current providers: Urban Science International Limited, Karmarama, Dentsu Aegis Network Limited)
  • Extended Guarantees & Service Plan providers
    (current provider: The Warranty Group Europe HQ)
  • Warranty providers (current provider: The Warranty Group Europe HQ)
  • Roadside Assistance (current provider: The Automobile Association (AA plc))
  • Customer satisfaction surveys across our divisions
    (current providers: InMoment Inc, GFK)
  • Customer Relations call services (current provider: Concentrix Corporation, BPA Corporate Facilitation Ltd, Ctalk Limited)
  • Customer Relations call management (current provider: Ctalk Limited)
  • Registration Data for government use (Driving & Vehicle Licensing Agency (DVLA))
  • Registration/Security Tag process for Motorcycles (current provider: DataTag Limited)
  • Tracking system for Motorcycles (current provider: Scorpion Automotive Limited)
  • Vehicle Recalls (current provider: GrassRoots Group UK Limited)
  • Transfers to third parties that are joint Data Controllers, where you have given specific consent:
        o Insurance providers (current provider: Aviva Insurance Services UK Limited)
        o Independent Reviews across our divisions (current provider: Reevoo Limited)

 

Transfers outside the EEA
Further to the above purposes, we will transfer your personal data to organisations outside of the EEA. When doing do, we may use standard contractual data protection clauses, which have been approved by the European Commission. We may also transfer your data to organisations in the US who participate in the EU-US Privacy Shield or which have corporate rules in place to protect your data, which have been approved by EU data protection authorities. 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.

Google Analytics

Where you consent to the use of Google Analytics for performance optimisation of your Honda app, Google may store or process your data in the US or any other country in which Google or its sub-processors maintain facilities. Where this is the case, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice).

(d)    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.
        o 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

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(a)    Your general Rights and Choices 

  • You have the right to ask Honda for a copy of your personal data; to correctdelete or restrictprocessing 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 will give you the opportunity to opt-in (consent) to having your contact details used for direct marketing purposes at the time we ask you to submit your details.

If you do not want us to send you direct marketing, or to use your personal data for profiling related to direct marketing, or to pass your details on to third parties for marketing purposes, you can ask us not to do this, at any time, by:

  • Replying to a direct marketing email, by selecting the ‘unsubscribe’ button;
  • By changing privacy settings in an app (if applicable to the app);
  • By contacting us at consentUK@honda-eu.com or writing to:
    The Database Manager, Honda (UK), Cain Road, Bracknell, RG12 1HL, United Kingdom; or
  • By calling us on 0345 200 8000.

(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.

Data Retention

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We will retain your personal data only for as long as we need it for Honda's legitimate interest in accordance with applicable law, or perform a service at your request, or to meet a legal requirement.  At the end of the retention period, 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

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Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and Group companies. Honda is not responsible for the content of any websites that are linked to its site. When entering a third party site, it is your responsibility to ensure that you read the privacy notice and legal terms & conditions that apply to that site

Updates to this Privacy Notice

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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 Honda Websites or Honda Apps. 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.

Contact Us

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Honda Motor Europe Limited (company number 857969, Cain Road, Bracknell, Berkshire, England, RG12 1HL) is the data controller of Honda customer and prospect personal data, processed further to this Privacy Notice. Our data protection officer for Honda operations in Europe can be contacted at DPO@honda-eu.com (English only).
In the UK, Honda Motor Europe Limited trades as Honda (UK), whose address is Cain Road, Bracknell, Berkshire, England, RG12 1HL. Our data protection manager for Honda operations in the UK can be contacted at DPM-UK@honda-eu.com. If you have any questions about this Privacy Notice, please contact us at Honda (UK).