February 27, 2020
Honda is committed to protecting and respecting your privacy. This Privacy Notice tells you how Honda Motor Europe Limited, Sucursal en España (“Honda”, “we”, “us”) treats your personal data when you visit, download or contact Honda on Honda websites and applications that refer to this Privacy Notice (as a whole, “Honda online Content”). This Privacy Notice also details your personal data protection rights, including the right to object to some of Honda’s data processing. You can find more information about your rights and how to exercise them in the “Your Options and Rights” section.
We may also provide you with additional information when we collect personal data, if we believe it is useful to give relevant and timely information.
Which personal data we collect
We process the following types of personal data:
- Contact information: such as your name, address, telephone number, e-mail address and other similar information.
- Technical details of your visit to Honda digital content: such as your IP address and operating system, browser type (for visits to our website), details of the device you are using (e.g. serial number of your device, unique identification number, MAC address) and technical and event-based data regarding the use of your device (e.g. internet and Bluetooth connection, connectivity data and session duration).
- Information to create a user profile: such as your username, password or PIN.
- Vehicle information: such as your Vehicle Identification Number (VIN), registration number and date of purchase.
- Product information: such as the identification of your product and the date and location of the purchase.
- Any other information you send 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 following reasons:
- Where necessary for the legitimate interests of Honda, as detailed below, and when your data protection rights do not override our interests:
o to provide you with Honda’s digital content and related services;
o to manage Honda’s digital content resources;
o in order to improve and optimise Honda’s digital content and Honda’s products and services;
o to respond to your request or inquiry; for example, by sending information, locating the nearest Honda dealer, booking a test drive or arranging your registration for a Honda Safety Institute (HIS) driving course, or making an appointment for maintenance of your Honda vehicle.
o to notify official Honda dealers and branch offices of any upcoming service, test drives or other upcoming appointments regarding you or your vehicle.
o to contact you for either of the above purposes (directly or through a Honda group company, an authorized Honda dealer, or the appropriate partner or agent) by e-mail, text message, or automatic notification.
o to understand which parts of Honda’s digital content are the most popular/used, or those that need change/improvement; and
o to respond to users’ questions and complaints; and
o for internal record-keeping.
- If you have given your consent.
o For example, to provide you with direct advertising, including information about products and services that may be of interest to you by mail, telephone, e-mail and online. We will always offer you the opportunity to unsubscribe from the e-mail.
o To ask you to give us your opinion or participate in surveys about our vehicles, products and services
- When necessary to enforce any contract Honda has with you.
o For example, to deliver products and services.
- When necessary to meet a legal obligation.
- When necessary to protect Honda’s legitimate interests and legal rights and when your data protection rights do not override our interests. [Protect our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulation, auditing, legal claims (including disclosure of such information in connection with legal proceedings or litigation) and other ethics and compliance reporting requirements.]
Honda will also convert personal data into anonymous data and use it (typically on an aggregate statistical basis) for research and analysis aimed at improving Honda’s Online Content, analysing trends, and customising products. Aggregate personal information does not personally identify you or any other user of Honda’s Online Content.
How we share your personal data
- Transfers within the Honda Group of Companies
We share your personal information with members of the Honda Group. o Honda Motor Co., Ltd: HM, our head company, which receives information in the case of technical or safety campaigns.
For the above purposes, your personal data will be processed or accessed by members of the Honda Group of Companies located in jurisdictions outside the European Economic Area (“EEA”) that do not have data protection laws equivalent to those in the EEA. When we transfer your data within the Honda Group of Companies, we make use of standard contractual clauses for the transfer of personal data, which have been approved by the European Commission.
- Transfers to authorised Honda dealers and workshops
We share your personal information with authorised Honda dealers and garages in the EEA. You can access to a complete list of Honda dealers
- Transfers to companies providing services under contract
Your personal data will be shared with companies providing services under a contract with the Honda Group of Companies, such as those listed below:
o CRM provider, e-mailing management, lead database (current supplier: STD Database Marketing S.L., Leader B2b Sl. )
o Media and events agencies (current supplier: Dentsu Aegis Network Iberia S.L. Organization Sports Adventure Travel S.L )
o Google analytics (current supplier: Google LLC)
o Websites and hosting (current suppliers: Digitaslbi Ltd, Acens Technologies S.L, STD Database Marketing S.L.)
o IT hosting (current suppliers: Acens Technologies S.L., Cloudi NextGen S.L., STD Database Marketing S.L.)
o IT Maintenance (current suppliers: STD Database Marketing S.L., IBM Belgium SPRL/BVBA, Acens Technologies S.L.)
o Vehicle test request (current supplier: Digitaslbi Ltd)
o Customer Service (current suppliers: Concentrix Corporation, Leader B2b sl. )
o Vehicle registration (current suppliers: Ridel Vilaseca, S,L, gestorias locales)
o Transfers of ownership (current supplier: T-Systems ITC IBERIA SAU)
o Cloud-based Systems (current suppliers: Microsoft Corporation, Acens Technologies S.L., Cloudi NextGen S.L.)
o Roadside assistance (current supplier: Europe Assistance Servicios Integrales de Gestión S.A.)
o Satisfaction and opinion surveys (current suppliers: InMoment Inc., Tns Investigación De Mercados y Opinion Sl, Qualtrics ltd)
o Data management (current suppliers: STD Database Marketing, S.L., Snap ON Business Solutions LTD, Gassiot & Llobet,Viqtor Davis)
o Communication services (current suppliers: STD Database Marketing, S.L., Concentrix Corporation, Alfe Trameses S.L., Gregor Samsa SL)
o Application services (current suppliers: BrightBox Inc., Mapit IoT S.L., Sophus 3 limited)
o Complaint management (current suppliers: Baker & Mckenzie Barcelona S.L.P, Concentrix Corporation)
o Vehicle maintenance contract (current supplier: TWG Services Ltd)
Transfers outside the EEA
In addition to the above-mentioned, we will transfer your personal data to organisations outside the EEA. In doing so, we can use standard contractual clauses for the transfer of personal data, which have been approved by the European Commission. We may also transfer your data to US entities that are part of the EU-US Privacy Shield Framework or have Binding Corporate Rules to protect your data, which have been approved by the EU data protection authorities. For more information, including obtaining a copy of the documents used to protect your information, please contact us as described in the “Contacting Us” section below.
When you consent to the use of Google Analytics to optimise the performance of your Honda application, Google may store or process your data in the USA or any other country in which Google or its sub-processors have facilities. In this case, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
When you download a third-party application from Honda’s Online Content, your personal data will be transferred directly to that third-party application provider as a separate data manager. Honda is not responsible for the processing of your personal data by such application providers. In this regard, you should take the time to read and understand how application providers will use your personal data before downloading their applications.
- Transfers to other organisations
o Transfers to third parties if we have a duty to disclose your personal information in order to comply with a legal obligation or if we believe that disclosure is necessary to protect the rights, property, or safety of Honda, our customers, or other persons.
o Transfers to government authorities and/or law enforcement officials if required by law or if necessary for the protection of our legitimate interests in compliance with applicable laws
o Transfers to potential or actual buyers in the event that Honda, or any part of the Honda Group, sells any of its business or assets that include personal data.
Your options and rights
- Your general rights and options
o You have the right to request Honda for a copy of your personal data in order to correct, delete or limit the processing of your personal data, and to obtain the personal data provided in a structured and readable format.
o You may object to the processing of your personal data in certain circumstances (in particular, where we are not required to process the data in order to comply with a contractual or other legal requirement).
o Once we have requested your consent, you may withdraw it at any time. If you request to withdraw your consent for Honda to process your data, this will not affect any processing that has already taken place at that time.
These rights may be limited; for instance, if compliance with your request would reveal personal information about another person, or if you ask us to delete information that is required by law or that we must keep for mandatory legitimate interests.
- Your rights and options with respect to direct marketing actions
Honda will give you the opportunity to agree (consent) to the use of your contact information for direct marketing purposes at the time we ask you to send it to us.
If you do not want us to send you commercial information, use your personal data to create profiles related to direct marketing or disclose your data to third parties for marketing purposes, you can ask us not to do so at any time:
o Unsubscribe from our emails by clicking on “Unsubscribe”;
o Change privacy settings in the application (if available in the application)
o Send an e-mail to firstname.lastname@example.org attaching a copy of your ID card;
o attaching a copy of your ID card
c/Del Mar Del Nord
1 Polígono Industrial ” La Torre del Rector ”
08130 Santa Perpétua de Mogoda
o Call the toll-free number 900 204 205.
- Your right to lodge a complaint with the Supervisory Authority
You also have the right to lodge a complaint with the Data Protection Supervisory Authority. 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 store your personal data only for as long as we need it for Honda’s legitimate interest under applicable law, or for as long as we perform a service at your request or to comply with a legal requirement. At the end of the conservation period, we will take steps to delete your personal data or keep it in a format that no longer identifies you.
Fake e-mails with the name of Honda
Honda is aware of fake e-mails, popularly called “phishing” e-mails, which may contain advertisements such as job postings, job offers, and reward notifications. These e-mails 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 e-mails are not linked to Honda and Honda does not use these methods for recruiting or communicating with the winners of prizes.
Unfortunately, these fake e-mails are a growing fraud on the Internet. This practice is carried out by sending a fake e-mail directly to the victim or by directing the victim to a website where personal information is requested. False job offers tend to be directed at people living abroad, as they ask for money to obtain visas for the United Kingdom. Honda never requests payment information in connection with employment applications or associated communications. If you have any questions about the validity of a contract offer, please contact email@example.com.
Honda advises that if you receive an e-mail with Honda’s name requesting personal or financial information and are uncertain of its authenticity, treat such e-mails 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 website that is linked to its site. When entering a third-party site, it is your responsibility to ensure that you read the data protection policy and legal terms and conditions that apply to that site.
Updates to the present Privacy Notice
This Privacy Notice may be updated periodically. Therefore, we will update the date at the top of this Privacy Notice and kindly invite you to check the changes in this Privacy Notice, which will be available on Honda’s online content. On occasion, we may also actively advise you of specific data management activities or significant changes to this Data Protection Notice, as required by applicable law.
Responsible for the Online Content is Honda Motor Europe Limited (company number 857969, Cain Road, Bracknell, Berkshire, England, RG12 1HL). In Spain (peninsula and Balearic Islands), Honda Motor Europe Limited is marketed as Honda Motor Europe Limited, Sucursal en España, whose address is c/ Mar del Nord, 1, Pol.Ind. La Torre del Rector, 08130 Sta. Perpétua de Mogoda (Barcelona).
If you have any questions or concerns about this Privacy Notice, you may contact our Official Data Protection Officer for Honda’s operations in Europe by e-mail at DPO@honda-eu.com (only in English) or for Honda in Spain, you can contact us at DPMSpain@honda-eu.com