HONDA ACCESS EUROPE N.V.

HONDA CUSTOMER ONLINE CONTENT PRIVACY NOTICE (HONDA ACCESS EUROPE N.V.)

Honda is committed to protecting and respecting your privacy. This Privacy Notice tells you how Honda Access Europe N.V. (“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.
• Technical details of your visit to the Honda Online 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. 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.
• 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, as listed below, and where our interests are not overridden by your data protection rights.
• to deliver the Honda Online Content and related services to you;
• to administer Honda Online Content resources;
• to allow us to improve and optimise the Honda Online Content and Honda products and services;
• to respond to user questions and complaints; and
• for internal record keeping.
• Where you have given consent.
• For example, to provide you with direct marketing including information about goods and services which may be of interest to you by post, telephone, email and online. We will always offer a chance to unsubscribe from direct marketing.
• Where necessary to comply with a legal obligation.
• Where necessary to protect Honda’s legitimate interests and legal rights, and where our interests and not overridden by your data protection rights.

[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 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

Your personal data can be shared with members of the Honda Group (for more details see https://global.honda/about/group.html).

For the purposes mentioned above, your personal data can 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.

• Transfers to Honda authorised dealers and repairers

Your personal data can be shared with Honda authorised dealers and repairers in the EEA.

• Transfers to companies providing services under contract

If this is necessary for the realization of the intended purposes, the customer’s personal data will be shared with other companies of the Honda Group or suppliers within the European Economic Area that are directly or indirectly connected to Honda Access Europe; Honda Access Europe guarantees that these recipients will take the necessary technical and organizational measures to protect the personal data.

Transfers outside the EEA

Further to the above purposes, we can 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).

• 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

• Your general Rights and Choices
• You have the right 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.

• 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

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.

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 Access Europe website is controlled by Honda Access Europe NV (company number 0454807165) which is the data controller for personal data collected via the Honda Access Europe website and whose registered address is Wijngaardveld 1, 9300 Aalst, Belgium.

If you have any questions about this Privacy Notice, please contact us at hace.gdpr@honda-eu.com