HONDA PRIVACY NOTICE (UK)

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, Honda websites and apps that refer to this Privacy Notice (all "Honda Online Content"). 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

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

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, validating a test drive incentive (requires your email and full address), 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
o    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.

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.

Data analysis techniques are used to understand your online journey and ownership history to provide a more seamless experience online and offline with your interactions with Honda. If you wish to object to this processing please refer to ‘Your Rights and Choices’ section.
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.
o For example, Honda e Reservation Account creation and payments, to ensure we keep you up to date via email and your online portal about all news relating to the Honda e.
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

On occasions Honda will also convert personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the Honda Online Content, analyse trends and, tailor products. Aggregated personal information does not personally identify you or any other use of the Honda Online Content.

How We Share Your Personal Data

Transfers within the Honda Group of Companies

We share your personal data with members of the Honda Group (for more details see http://world.honda.com/profile/overview/).

Honda Finance Europe PLC (HFE): HFE provides financing options for UK customers.

Honda Motor Ltd (HM): HM, our parent company, receives information on product recalls, and information on our NSX sales (Transfer of Customer Name and NSX Specification in order for factory build. N.B. HME send this information directly.)

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 European Economic Area ("EEA") that do not have equivalent data protection laws to those in the 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.

(a) 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, or service enquiries.

A full list of Honda dealers may be accessed below:

Cars: http://www.honda.co.uk/cars/retailer-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

There is also a Dealer Search Engine online:

Cars: http://www.honda.co.uk/cars/retailer-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

(b) 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:

Website provider & hosting (current provider: Digitas LBi Limited)
e-Commerce Power Equipment Website provider (current provider: The Hut.com Limited )
Live Chat Power Equipment Website provider (current provider: The Hut.com Limited )
Google analytics provided for website improvement and optimisation (Google LLC)
Used Car locator (current provider: Manheim Limited)
Motorcycle Dealer Websites (participating Dealers only)
(current provider: One Black Bear Limited)
Motorcycle Experiences (current providers: Honda School of Motorcycling,
Dave Thorpe (Dthorc Limited), The Ron Haslem Race School, Inch Perfect Trials Limited)
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)
My Honda App/Dongle (current provider: Bright Box Europe SA)
The App is administered on behalf of Honda by Bright Box Europe SA (registered number CH-550.1.167.893-8) and its affiliate Bright Box Hungary Kft (together “Bright Box”).
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)
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: Insights Engineers Ltd, InMoment Inc, GFK)
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)
Professional advisors (current provider: Deloitte LLP, Gartner Inc)
Dealer Awards Program (current provider: River Agency, Amp)

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).

Third party apps

Where you download a third party app from the Honda Online Content, your personal data will be transferred to that third party app provider directly as a separate data controller. Honda is not responsible for the processing of your personal data by such app providers. As such, you should take time to read and understand how your personal data will be used by app providers before you download their apps.

(c) 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 to third parties, 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)

Your Choices and Rights

(a) Your general Rights and Choices

You have the right to ask Honda for a copy of your personal data; to correct, delete 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.

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

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. (The retention period for any personal data shall not in any event exceed a period of 5 years from the point that the data is first collected by us, and after the ownership of any vehicle or product). 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.

Fake emails using Honda's name

Honda is aware of fake emails, popularly called "phishing" emails which can contain notices such as job advertisements, job offers and competition award notifications. These emails use Honda’s name to pretend they are genuine and exist solely for the purpose of obtaining private information about consumers (e.g. credit card numbers or passwords). These emails have no connection with Honda and Honda does not use these methods for job advertising or for communicating with competition winners.

Unfortunately these fake emails are a growing fraud on the internet. This practice is carried out either by the sending of a bogus email directly to a victim, or by directing them to a website where personal information is requested.

Fake job offers tend to target overseas individuals, as they ask for money to be sent to them for UK visa purposes. Honda never requests payments details in association with any job applications or any communication related to them. If in any doubt about the validity of a recruitment offer, please contact Human Resources, Honda (UK), Cain Road, Bracknell, RG12 1HL, United Kingdom.

Recent email award notifications have purported to be from Honda. Honda never requests payment details in association with competition winners or any communication related to them.

Honda advises that if you receive an email using Honda’s name that asks for personal information or financial information and you have concerns about its authenticity, then please treat such emails with extreme caution.

Links to third party sites

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 policy and legal terms & conditions that apply to that site

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 Honda Online Content. 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

The Honda Online Content is controlled by Honda Motor Europe Limited (company number 857969) which is the data controller for personal data collected via Honda Online Content and whose registered address is Cain Road, Bracknell, Berkshire, England, RG12 1HL.

If you have any questions about this Privacy Notice, please contact us at DPO@honda-eu.com.
Our data protection officer can also be contacted at DPO@honda-eu.com.