PRIVACY POLICY

Honda Malaysia Sdn. Bhd. (""Honda"", ""we,"" ""us"" or ""our""), a company incorporated under Malaysian Companies Act  is committed to protecting the privacy and earning your trust. We will use the information that we collect about you in connection with innovative functions, telematics and connected car services (the ""Services"") and to enable you to use the Honda Connect Application (the ""Application""). This Privacy Policy provides information about Honda's data collection, use, disclosure and international transfer activities with respect to individually identifiable information (""Personal Data"") as the service provider of the Services and the Application about the users who have registered an account for the Application (""you"", ""your"", or ""yours""). We do not intend to collect or use Personal Data of minors.

By clicking the "Accept" button, you acknowledge that you have read, fully understand and acknowledge this Privacy Policy.

This Privacy Policy does not cover information that you submit on interactive features and digital services which are provided by third parties. For example, if you post something on Facebook or Twitter, or if you provide your information on other apps in which we certified that they can be used along with the Application, that information is governed by the privacy policies on those websites, and is not governed by this Privacy Policy. 

1. Information We Collected

We collect Personal Data from you when you provide your information to register the Application or when you update your information in the Application. We may also collect your Personal Data from other sources, including the authorized dealers who have sold you the Honda vehicle or offer services to you, your insurance broker or insurance companies whom you have contracted, the mobile network operators who offer you with network connection services, our service providers like Honda call centers whom you have contacted. Such Personal Data include

• Personal data and contact information, including your name and family name, date of birth, gender, email, phone number, physical address, contact in case of emergency, your account details including username and password. We may collect certain special categories of Personal Data about you i.e., biometric data for authentication of a person.
• Data pertaining to your purchases and services you choose, including but not limited to payment information, credit card details and other payment details (in accordance with other laws and regulations), billing and shipping address, products and services ordered and purchased, information and queries and complaints relating to products and services, or respective contracts entered into such as warranty claims, after sales services, repairs, customer care and services, rescissions and disputes, dealer appointments, and information that you provide for other services such as car insurance you have chosen.
• Data in connection with product and services marketing, including but not limited to information relating to newsletter and other communication channels, opt-ins and opt-outs, invitations to and participations at events and special activities, privileges offered and/or received, personal preferences and interests, survey questionnaire responses and customer segmentation information;
• Information about your use of the Services, including history and details of services usage, information which you searched for on the Application, marketing and communication details (e.g. your satisfaction with the receipt of marketing information from us and your satisfaction with services relating to communication), and your Personal Data which we will notify you if we collect such information.
• Data in connection with communication including but not limited to preferred means of communication, correspondence and communication with Honda (including records of the communication with HMSB Helpdesk and Call Centre).
• Information about your Honda vehicle (the ""Vehicle""), including its performance, condition and location information about your driving behavior, car status, trip logs, mileages, and remote vehicle control.
• Other data from your device and other technologies. We and our third-party service providers, may use a variety of technologies that collect and provide information about how the Application is used. We may also automatically collect your IP address or other unique identifier for the mobile device, technology or other device (collectively, ""Device"") you use to access the Application, login details, connectivity, types of browser, operating system, other technologies on the equipment that you use to access the Application, features or information of the Application that you have visited, time spent on each page of the Application. Usage Information and device identifier generally cannot be linked to you individually, but if we can link them or any other information to you, we treat it as your Personal Data in accordance with this Privacy Policy.

In case we use certain types of information described above in the way that would enable us to identify you, we will treat such information in the same manners as it would treat it as Personal Data.

2. How we process your Personal Data

2.1 Purposes

We process your Personal Data for the purposes set out below:

• To administrate the Application to provide you with our Services and to enable your access to, and use of, the Application and the Services;
• To communicate with you and provide our Services and those of our affiliates. The term ‘affiliates’ throughout this Privacy Policy shall mean Honda Malaysia Sdn. Bhd.’s subsidiary Honda Assembly (Malaysia) Sdn. Bhd., Asian Honda Motor Co. Ltd, Honda Motor Co. Ltd., and Honda R&D Co. Ltd.
• To evaluate and improve our services, such as developing new products or services and improve and manage working system;
• To perform internal accounting, auditing, administration, and processing of information relating to your transactions and other internal functions of Honda and its affiliates;
• To process and manage your payment and/or any other transactions related to of Honda and its affiliates;
• To conduct market research, surveys and direct marketing purposes;
• To tailor ads of Honda and its affiliates on the Application and elsewhere to your possible interests;
• To comply with industry standards and our policies;
• To conduct data analytics and customer relations management programs of Honda and its affiliates;
• To offer, transmit, communicate and/or to carry out any marketing, public relations and promotional activities relating to goods, services, promotions, activities and special offers of Honda and its affiliates, general information of Honda and its affiliates including other forms of customer relationship management via communication channels;
• To provide you and our authorized dealers with necessary support;
• To attend to or assist in the servicing, maintenance or repair of your vehicle, including the provision of roadside assistance services;
• To carry out our legal compliance obligations, such as to conduct a product safety recall where necessary;
• To provide you with notifications and information about your Vehicle;
• To inform you of a field service action affecting your Vehicle;
• To send you service reminders;
• To be in compliance with relevant laws, or rules and regulations, requests from government agencies and policies of Honda, and for enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities;
• To prevent and investigate frauds, illegal activities, omission of duties or misconduct which may or may not cause by or be relating to the Services provision of Honda;
• To protect customers, employees and other individuals and protection of data, secrets and assets of and entrusted to Honda and our affiliates, and protect the safety of systems and premises of Honda and our affiliates;
• For sale or acquisitions of business divisions, companies or parts of companies and other corporate transactions and the transfer of customer data associated therewith; and
• For other lawful purposes where such processing was evident from the circumstances or indicated at the time of the collection.

2.2 Legal bases

In general, you are required to provide your Personal Data to obtain full Services from us, except in limited instances when we indicate that certain information is voluntary and their processing is based on your consent (e.g. in connection with user satisfaction surveys). However, we may not be able to provide you with the full Services or you may not be able to use the Application properly if you do not provide us with certain Personal Data.

Furthermore, we rely on the following legal justifications for the processing of your Personal Data. 

• it is necessary for the performance of contract of which you are a party or in order to take steps at your request prior to entering into a contract (e.g. to provide you with the Services);
• it is necessary for legitimate interests of Honda or any other third parties where such interests are not overridden your fundamental rights of Personal Data (e.g. where it is necessary to disclose your Personal Data to third parties to provide you with the Services on our behalf);
• it is necessary for legal compliance;
• it is for preventing or suppressing a danger to a person’s life, body or health;
• it is necessary for our performance of duties in carrying out mission for public interest or in exercising the assigned power of the state; or
• it is necessary for the purpose of establishing legal claims, complying with or exercise of legal claims or defense of legal claims.

• It is necessary to enable you to avail the services and use the application in an effective, functional and in a manner beneficial to you.

3. Who we share your Personal Data with

We may disclose the Personal Data to the following categories of recipients for the purposes as specified in this Privacy Policy:

• Our affiliates: We may disclose your Personal Data to our affiliates for the purposes as specified in this Privacy Policy and to assure you that use of the Application is secured, smooth and efficient, and help us improve the Services to be suitable, to be in compliance with laws, to provide supports and promotions for Services offered on the Application, and for the achievement of administrative purposes and legitimate interests of Honda and our affiliates, and to develop the business operation.
• Service providers: We may disclose and/or transfer your Personal Data to third-party service providers, including our call centers, as part of our normal course of business for several purposes including facilitating your use of services.
• Third parties: For the purpose of offering additional services, promotions, offers, or privileges to you and for the purposes as specified in this Privacy Policy, we may disclose your Personal Data to our third parties acting as controllers as follows:
• your insurance companies;
• financial institution;
• our authorized dealers who have sold you the Honda vehicle or offer services to you;
• our suppliers and other business partners within the lawful purposes specified herein;
• local, national and foreign authorities in accordance with applicable law;
• acquirers or parties interested in acquiring business units, companies or other parts of Honda or our affiliates; and
• other parties in potential or actual legal proceedings in accordance with applicable law.

Other third parties: We may disclose your Personal Data to governmental agencies, regulatory authorities or courts in accordance with legal requirements and to external consultants such as lawyers, accountants, auditors.

A list of data recipients containing the identity, short description of the collection, use, or disclosure activity and location of the relevant data recipients can be requested from us under the contact details provided at Item 9 below.

4. Cross-border data transfer

We may transfer your Personal Data outside Malaysia in accordance with applicable Malaysian and the destination’s laws on personal data protection. The transfer of your Personal Data may only be done by obtaining your written consent or there are any other compelling legitimate grounds (e.g. to perform the contract terms) as permitted by applicable laws.

If Honda is required to obtain your consent and your Personal Data may be transferred to destination countries where the standard of protection available for your Personal Data may not be sufficient under the applicable laws on data protection in Malaysia, we will take steps necessary for the protection of Personal Data that is transferred to other persons internationally is in the same level of protection as we provide with respect to your Personal Data, and in compliance with the applicable laws on data protection which is in effect at that time.

5. Security

We use reasonable organizational, technical and administrative measures to protect Personal Data from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure under our control. Unfortunately, no data transmission over the Internet or data storage system can be fully secured.

6. How long we retain your Personal Data

We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy and for the period required pursuant to applicable legal requirements. When we are no longer permitted by the applicable laws to store your Personal Data, we will remove it from our systems and records, and/or take necessary steps to anonymize your Personal Data so that you can no longer be identified. In the event a judicial or disciplinary action is initiated, your Personal Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by the applicable laws.

7. Updates to the Privacy Policy

If we make any material change to this Privacy Policy, we will notify you adequately of such change via the Application,

8. Your legal rights

If and when the applicable personal data protection law becomes in effect and enforced in Malaysia, you have the following rights under the conditions set out under applicable law pursuant to the conditions and requirements set forth thereunder:

• Right of Access: You have the right to request access to and obtain copy of the Personal Data related to you, which is under the responsibility of Honda, or to request the disclosure of the acquisition of the Personal Data obtained without your consent.
• Right of correction: You have the right to request Honda to take any steps to ensure that your Personal Data is accurate, up-to-date, complete and is not misleading.
• Right to request for deletion: You have the right to request that Honda delete or to render your Personal Data to be unidentifiable to the extend applicable under the laws, except for the case that Honda may need to collect your Personal Data as applicable under the laws, such as the collection is for establishing claims, performing with or exercising legal claims, defensing legal claims or complying with the laws.
• Right of objection: You have the right to object to the collection, use or disclosure of your Personal Data on grounds relating to your particular situation. Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
• Right to restriction of processing: You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
• Right of withdrawal: You have the right to withdraw your consent given to any collection, use, disclosure, transmission and/or transfer of your Personal Data at any time by notifying Honda of such withdrawal via channels described under Clause 9 except in case of restrictions on consent withdrawal under the law or agreements which is beneficial to you.
• Right of complaints: You have the right to complain to competent government agencies against Honda in case of breach or non-compliance with the provisions under the law on the protection of personal data in which is in effect in Malaysia including relevant regulations of Honda.

In addition, you may request not to be contacted via email and/or not to receive marketing communications from us any time. You may inform us via email, telephone and/or in written form by using our below contact information in ""How to Contact Us"". The changes may not be effective immediately. We will proceed with your request as soon as we can, and in any case, not more than a period of time prescribed by the applicable laws. If you would like to stop receiving marketing communications from us, we will continue to send other information related to important services management to you and you may not cease to receive such information.

9. How to contact us

We may retain and use your Personal Data for as long as necessary to fulfill the purposes set out above. If you have further questions regarding the processing of Personal Data by this Application or would like to request to exercise your statutory rights, if and when the applicable personal data protection law becomes in effect and enforced in Malaysia, to access, rectification, erasure, portability, object collection, restriction, use or disclosure, of your Personal Data, withdraw your consent, or to make any complaints, please send us an email at https://www.honda.com.my/contact-us or telephone at HMSB Helpdesk (1800-88-2020). Our staff who can be contacted at the aforementioned channels will assist you when the applicable personal data protection law becomes in effect and enforced in Malaysia.