HONDA PRIVACY NOTICE (UK)
April 2024
Honda Motor Europe Limited, trading as Honda UK, (“Honda”, “we”, “us”) is committed to protecting and respecting your privacy.
This Privacy Notice sets out how we, as data controller, collect and use your personal data in all cases when you interact with Honda e.g., when you visit a Honda retailer or dealership, visit our Honda websites, use our products, download and use our apps, or contact Honda in relation to your Honda product (“Services”).
This Privacy Notice is supplemented by additional notices we may provide you, for example, in relation to specific products or Services, including our websites, or if we use specific data for additional purposes.
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.
If you have any questions or need any further clarity, please get in touch with our data protection manager, using the contact details at the end of this Privacy Notice.
What Personal Data We Collect
We process the types of personal data set out below.
Type of personal data processed by Honda:
- Contact information
Examples: Names, addresses, phone numbers, email addresses, and other similar information.
How we collect this: You may provide this information to us directly or through dealers, retailers and distributors. In some circumstances, for example when we need to obtain or update contact information to carry out recall campaigns, we may obtain this information from providers of Deceased Screening services (currently we use the Bereavement Register and Mortascreen) and Goneaway and Forwarding services (currently GAS Reactive, NCOA Update and Absolute Contracts). - Login details
Examples: Usernames, passwords, PIN numbers.
How we collect this: You provide some of this information to us directly. We may generate some of this information ourselves. - Account details
Examples: Customer ID numbers, your preferences, applicable terms and conditions, product/s purchased, name and location of preferred Honda dealer or retailer, active and inactive subscriptions. Where you have configured a vehicle or product on our website, we will process this.
How we collect this: You may provide some of this information to us directly. We generate some of this information ourselves or through dealers, retailers and distributors. - Interests and preferences information
Examples: Inferred demographics, lifestyles and behaviours, such as the type of vehicle you might use / be interested in buying.
How we collect this: We obtain this information from Experian and similar service providers, with whom we share your address and contact details for this purpose. We also infer your interests based on your browsing of our website when you are signed into the website. - Product information
Examples: Product ID (e.g., your Vehicle Identification Number (VIN), if the product is a vehicle), version or model number, and date and location of purchase.
How we collect this: You may provide some of this information to us directly or through dealers, retailers and distributors. We generate some of this information ourselves when you acquire or use our products. - Vehicle valuation details
Examples: Information relating to the value of your vehicle, such as the make, model, fuel type, registration number, vehicle mileage and overall condition of your current vehicle. This may also include information relating to the number of previous owners, outstanding finance arrangements, equity held in this vehicle and any previous valuations you have obtained in the last 30 days.
How we collect this: You may provide some of this information to us directly or through dealers, retailers and distributors. We will obtain a valuation for your vehicle through a third party valuation provider. - Transaction information
Examples: Prices of a product/s or service/s purchased, transaction and payment history, payments due.
How we collect this: We generate this information ourselves when you transact with us. - Financial information
Examples: Your means of payment, your bank account number, sort code and billing address.
How we collect this: You provide this information to us directly. - Device and connection details
Examples: Information regarding the device that you use to connect to, and your connection to, Honda Services, such as your operating system and its version, details of the device you are using (e.g., your device serial number, unique identification number and MAC address), system settings of your device (e.g., screen information, device capabilities, network connections, language or default apps) and your approximate geographic location of connection (to the nearest city).
How we collect this: We generate this information ourselves when you connect to our Services. - Usage data
Examples: Details of your use of Honda Services, such as your time of visit, your connection length and your use of such Services (e.g., items that you select and requests that you make), or any data obtained your smartphone or other device on which you use the relevant Honda Service, which comprises of data relating to approximate location, acceleration, velocity, magnetic fields, light and proximity.
How we collect this: We generate this information ourselves when you use our Services. - Communications
Examples: Information you include in any feedback you provide or queries and complaints you submit to us. These often include details of your experience with Honda, your interest in and use of our Services, and your opinions, but may also include other information you choose to provide.
How we collect this: You provide this information to us directly or through dealers, retailers, and distributors. - Any other information you submit to us in connection with Honda apps
Examples: Signatures, photographs, opinions, and your location.
How we collect this: You provide this information to us directly or through dealers, retailers, and distributors.
Why We Collect, Use and Store this Personal Data
We collect, use and store your personal data for the reasons set out in the text below.
The text below also sets out the lawful bases we rely on to process the personal data. Where we rely on legitimate interests, further information in relation to Honda’s legitimate business interest and how we balance our interest against the rights and interests of our customers, can be provided upon request.
Honda will anonymise personal data wherever possible. Anonymised data does not qualify as personal data.
Purpose/Activity:
- To provide you with the Services you request, purchase, or subscribe for.
Main types of information: Contact Information
Lawful basis for processing: Performance of a contract with you. Necessary for our legitimate interests to provide and maintain our services. - To provide you with an enhanced experience of our Services, including by remembering where you left off when you start but do not complete an order.
Main types of information: Account Details, Transaction Information, Vehicle valuation details & Usage information
Lawful basis for processing: Necessary for our legitimate interests to provide a good service to our customers. - To set up and administer your Honda Account.
Main types of information: Contact Information, Security Information
Lawful basis for processing: Performance of a contract with you. - To collect payments due to us.
Main types of information: Contact Information, Payment Information
Lawful basis for processing: Performance of a contract with you. - To assist and facilitate you in obtaining finance for the purchase of any cars where we act as an introducer.
Main types of information: Contact Information, Account details, Transaction Information, Financial Information
Lawful basis for processing: Necessary for our legitimate interests to assist you in obtaining financial assistance to purchase our products or services. - To provide you with an estimate and valuation of your vehicle.
Main types of information: Contact Information, Account details, Vehicle valuation details
Lawful basis for processing: Performance of a contract with you. - To ensure the safety and security of your Honda products such as those covered by the Honda Marine App which offers security tracking.
Main types of information: Location Information, Device Information, Usage Information
Lawful basis for processing: Performance of a contract with you. - To reserve products which you request.
Main types of information: Contact Information, Payment Information
Lawful basis for processing: Performance of a contract with you. - To administer Honda apps resources.
Main types of information: Contact Information, Usage Information
Lawful basis for processing: Necessary for our legitimate interests to ensure Honda apps are able to run smoothly and in order to provide an effective service to users. - To improve the Honda Services and develop new ones.
Main types of information: Usage Data, Device Information, Approximate Location Information
Lawful basis for processing: Necessary for our legitimate interests to improve and develop new Services. - To understand your interests and preferences so that Honda Services can be tailored to you.
Main types of information: Usage Data, Interest and Preferences Information
Lawful basis for processing: Necessary for our legitimate interests unless tracking technologies are used, in which case we would rely on your consent. - To record and communicate consents you give third parties with whom we share personal data.
Main types of information: Consent Information
Lawful basis for processing: Necessary for our legitimate interests to ensure compliance with applicable laws, including customers’ rights. - To respond to your complaints, online and offline requests, or enquiries, for example by sending you a brochure, locating your nearest Honda retailer or dealership, booking you a test drive, or arranging a service for your Honda vehicle or product.
Main types of information: Contact Information, Request Information, Complaint Information
Lawful basis for processing: Necessary for our legitimate interests to provide a good service to our customers. - To arrange for Services to be provided to you by our dealers, Honda retailers and Honda branches, including upcoming vehicle services, test drives or other appointments in relation to you or your Honda vehicle or Honda product.
Main types of information: Contact Information, Request Information, Product Information
Lawful basis for processing: Necessary for our legitimate interests to provide you with value added services. - To send you Service communications
Main types of information: Contact Information
Lawful basis for processing: Necessary for our legitimate interests to communicate with you in relation to your use of our Services. - To carry out market research and analysis in order to understand how our Services are used with a view to improving them or developing new Services, including by asking you to provide your opinion or participate in surveys about our vehicles, products Services, retailers and dealerships.
Main types of information: Contact Information
Lawful basis for processing: Consent where required by national laws or guidance. Necessary for our legitimate interests to improve and develop new Services. - For internal record keeping.
Main types of information: Contact Information, Product Information, Usage Information, Transaction Information
Lawful basis for processing: Necessary for our legitimate interests to ensure we operate our business in an efficient and suitable manner. - For statistical analysis, research, and reporting.
Main types of information: Location Information, Product Information, Sensor Information, Usage Data, Interaction Information
Lawful basis for processing: Necessary for our legitimate interests to carry out statistical analysis, research, and reporting. - For quality and staff training purposes.
Main types of information: Communication Information, Transaction Information, Complaint Information
Lawful basis for processing: Necessary for our legitimate interests to provide a good service to our customers. - To contribute to government or industry initiatives (e.g., EU CO2 emissions reporting requirements, severe/sudden braking data and EU investigatory data in relation to new legislation).
Main types of information: Location Information, Product Information, Usage Information
Lawful basis for processing: Necessary for our legitimate interests to contribute to efforts and initiatives which are in the public interest. - To protect our legitimate business interests and legal rights, including, but 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
Main types of information: Location Information, Product Information, Usage Data, Sensor Information, Communication Information, Payment Information
Lawful basis for processing: Necessary for our legitimate interests to protect our business. - To keep a record of the information which you have been provided.
Main types of information: Communication Information, Request Information
Lawful basis for processing: Necessary for our legitimate interests to ensure we operate our business in an efficient and suitable manner. - To send you direct marketing relating to Honda Services by electronic means (email, SMS, instant messaging).
Main types of information: Contact Information, Consent Information
Lawful basis for processing: We may send you such direct marketing on the basis of our legitimate interest to do so (without your consent) where:
(i) the marketing relates to Services that are similar to those you have previously purchased from us and you have not objected to us sending you this type of marketing;
(ii) we do not send the marketing by electronic means (i.e. not by email, SMS, instant messaging); or
(iii) we send the marketing to a company address.
Otherwise, we will only send you direct marketing by electronic means if you give us consent. We will always offer you the opportunity to unsubscribe from direct marketing. - Data analysis techniques are used to understand your online journey and ownership history to provide a more seamless experience online and offline in your interactions with Honda
Main types of information: Browsing and interaction information, Product Information
Lawful basis for processing: Consent. - To comply with laws and regulations that apply to us or our Services, including those relating to product safety or the environment (e.g. carbon emissions)
Main types of information: Contact Information, Product Information, Safety Information, Emissions Information
Lawful basis for processing: Necessary to comply with a legal obligation. - To send you notifications which are required by law, including about products recalls and security incidents
Main types of information: Contact Information, Product Information, Safety Information
Lawful basis for processing: Necessary to comply with a legal obligation. - To respond to requests from public authorities including law enforcement bodies which we may receive
Main types of information: Location Information, Ownership Information, Supplier Information, Product Information, Sensor Information
Lawful basis for processing: Necessary to comply with a legal obligation. - To comply with court orders which we may receive
Main types of information: Contact Information, Payment Information, Product Information, Usage Data, Communication Information, Supplier Information
Lawful basis for processing: Necessary to comply with a legal obligation.
How We Share Your Personal Data
(a) Transfers within the Honda Group of Companies
We share your personal data with members of the Honda Group.
(b) Transfers to Honda authorised retailers, dealers and repairers
We share your personal data with Honda authorised retailers, dealers and repairers in the UK. For example, where you have made an online request for a test drive or a product service, we will ask your local Honda retailer or dealer to contact you to arrange the test drive or service at a convenient time.
A full list of Honda retailers and dealers may be accessed below:
Cars: https://www.honda.co.uk/cars/retailer-list.html
Motorcycles: https://www.honda.co.uk/motorcycles/dealer-list.html
Lawn & Garden: https://www.honda.co.uk/lawn-and-garden/dealer-list.html
Marine: https://www.honda.co.uk/marine/dealer-list.html
Industrial: https://www.honda.co.uk/industrial/dealer-list.html
ATVs: https://www.honda.co.uk/atv/dealer-list.html
Snowthrowers: https://www.honda.co.uk/snowthrowers/dealer-list.html
You can also search for your nearest Honda retailer using the following web links:
Cars: https://www.honda.co.uk/cars/retailer-search.html
Motorcycles: https://www.honda.co.uk/motorcycles/dealer-search.html
Lawn & Garden: https://www.honda.co.uk/lawn-and-garden/find-a-dealer.html
Marine: https://www.honda.co.uk/marine/dealer-search.html
Industrial: https://www.honda.co.uk/industrial/dealer-search.html
Snowthrowers: https://www.honda.co.uk/snowthrowers/dealer-search.html
ATVs: https://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. A list of categories of service providers is set out below.
- Honda website, apps and digital services developers, providers, hosting and analytics
- Honda New & Used Motorcycle websites, Motorcycle Experience Centres
- Agencies for the delivery of marketing, product, service and contract materials
- Agency for event management such as product trial events
- Fleet & B2B sales and servicing service providers
- IT hosting, IT development, IT maintenance & help desk providers, including web developers and hosting platforms for sales, web forms and/or social media forms
- Data Management & Data Analysis providers
- Ownership services providers, such as providers of guarantee services, service plan providers, roadside assistance providers and third parties necessary to manage and carry out recalls
- Market research service providers
- Customer Relations call services
- Customer services providers including online chat, telephone and email
- Publicity services and agencies
- Retailer, dealers and distributors
- Fleet Managers
- Recall campaign service providers
- Roadside assistance providers
- Vehicle garages
- Agencies capturing the voice of the customers through means such as new car buyer surveys, online reviews, buyer behaviour research.
- Payment processing providers
- Vehicle valuation service providers
- Retailer or dealer training providers
- Document management systems
- HME employees and contractors
(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 which includes where sharing information is mandated by law, where required by these authorities to carry out their functions or if required for the protection of our legitimate interests in compliance with applicable laws.
- Transfers to prospective or actual buyers or investors in the event that Honda, or any part of the Honda Group, sells any of its business or assets which includes personal data.
Transfers outside the UK and EEA
Honda is a subsidiary of Honda Motor Ltd., which is based in Japan. Therefore, your personal data will be processed in, or accessed from, Japan. When we transfer your data to Honda Motor Ltd in Japan, we rely on the assessment of the European Commission and Information Commissioner’s Office as to the adequacy of Japanese data protection laws.
When personal data is transferred internationally, we will rely on acceptable and defined legal mechanisms to ensure that we always protect data. The relevant transfers are described in the supplementary privacy notices set out above. In doing so, we may use standard contractual data protection clauses, which have been approved by the European Commission and the International Data Transfer Agreement approved by the UK government. We may also transfer your data to organisations which have corporate rules in place to protect your data, which have been approved by EU and UK data protection authorities. Alternatively, certain countries, like Japan, are also deemed to be adequate countries for the purposes of transferring your personal data and Honda may make use of such ‘adequacy’ designation.
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.
Your Choices and Rights
(a) Your general Choices and Rights
- 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.
(b) Your Choices and Rights regarding Direct Marketing
You may opt out of receiving any form of direct marketing at any time, regardless of whether we rely on consent to send you direct marketing. We will provide you with an opportunity to do so in every marketing communication that we send you. You may also ask us to stop personalising direct marketing.
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 country 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 the purposes set out in this notice or a supplementary notice, except in circumstances where we need to retain it for longer in order to comply with legal obligations or to progress legal claims. 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.
Generally, unless we set out an additional or different retention period in a supplementary notice that we provide you, we will retain your data for the periods set out in the list below. The list describes specific retention periods for each type of personal data described above.
Type of personal data processed by Honda
- Contact information
Retention period: 7 years from the end of your subscription unless you have not subscribed for Honda Services in which case we will retain it for 2.5 years from the date of your enquiry. - Login and Account details
Retention period: 7 years from the end of your account subscription unless you have not accessed Honda services in which case we will retain it for 2 years. - Interest and preferences information
Retention period: 7 years from the end of your last interaction with Honda - Product information
Retention period: 4 years from the end of ownership. - Transaction information
Retention period: 7 years from the end of interaction with Honda - Financial information
Retention period: 7 years from end of application or ownership of a product or service with Honda - Device and Connection Details
Retention period: 7 years from last interaction - Usage Data
Retention period: 7 years from last use - Communications
Retention period: 7 years from last communication - Any other data provided
Retention period: 7 years from last provision
Please see our supplementary notices for further information on our retention periods regarding your personal data related to specific services.
Links to third party sites or apps
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 or downloading a third party app, it is your responsibility to ensure that you read the privacy notice and legal terms & conditions that apply to that site or app.
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 website or app. 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
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.
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).