Connected Vehicle Services
Last Updated: December 07, 2020
Mitsubishi Motor Sales of Canada ("MMSCAN" or "we") provides those who purchase certain models of Mitsubishi vehicles the ability to receive Connected Vehicle Services ("CV Services"), which involve collection of personal information via:
- The telematics device on your vehicle (the "Device"), which can record information about how you drive, vehicle maintenance data, your location via GPS, and other information as further described below;
- The My MITSUBISHI CONNECT mobile application (the "Mobile App");
- The MMSCAN Connected Vehicle Services customer care center at 1-888-576-4878 ("Customer Care"); and
- Dealership records provided to MMSCAN in connection with the CV Services.
This Privacy Statement explains how personal information about you is collected, used, and disclosed by MMSCAN with respect to the CV Services. This Privacy Statement does not apply to vehicles, products, mobile applications, or services that are unrelated to the CV Services as listed above. This Privacy Statement supplements our General Privacy Notice, which is available at https://www.mitsubishi-motors.ca/en/legal/#privacy .To obtain an accessible copy of this Privacy Statement please contact us via the methods identified in the "Contact Us" section below.
For more information about the types of Services or Subscription Packages that are offered in connection with the CV Services, please review the MMSCAN Connected Vehicle Services website. Terms that are used but not defined in this Privacy Statement are defined in the MMSCAN Connected Vehicle Services Terms and Conditions, available at https://www.mitsubishi-motors.ca/en/ccslegal/terms. Overview of services are outlined in the table below
|TYPE OF SERIVCE||PURPOSE OF SERVICE|
|Parental Control Services||
|Vehicle Data/Vehicle Data Collection||
The following information about your vehicle (the “Default Vehicle Data”) will be collected, used, disclosed and shared by MMSCAN as part of the Vehicle Data Collection:
DEFAULT VEHICLE DATA:
DEFAULT VEHICLE DATA (AS DEFINED IN THE TERMS AND CONDITIONS, WHICH INCLUDES YOUR GEOLOCATION INFORMATION, ODOMETER VALUE, VEHICLE ERRORS AND OTHER VEHICLE-RELATED DATA) WILL BE COLLECTED, USED, DISCLOSED AND SHARED BY MMSCAN IN ACCORDANCE WITH THIS PRIVACY STATEMENT, THE CONNECTED VEHICLE SERVICES TERMS AND CONDITIONS, AND CANADIAN LAWS, RULES AND REGULATIONS, INCLUDING FOR MARKETING PURPOSES TO OFFER PRODUCTS AND OTHER SERVICES TO YOU. THIS DATA MAY START BEING COLLECTED IMMEDIATELY UPON YOUR PURCHASE OR LEASE OF YOUR VEHICLE FROM THE DEALER. YOU WERE NOTIFIED OF AND CONSENTED TO THIS COLLECTION, USE, DISCLOSURE AND SHARING AT YOUR TIME OF VEHICLE PURCHASE OR LEASE. THIS DATA MAY BE COLLECTED FROM YOUR VEHICLE, EVEN IF YOU DO NOT ACTIVATE THE SERVICES OR PURCHASE A SUBSCRIPTION SERVICES PACKAGE OR IF YOUR SUBSCRIPTION, TRIAL OR RENEWAL PERIOD HAS EXPIRED. IF YOU DO NOT ACTIVATE TO CONNECTED VEHICLES SERVICES BY ACCEPTING THE TERMS AND CONDITIONS, THE FOLLOWING DATA WILL STILL BE SENT BY THE VEHICLE. THE INFORMATION IS NOT STORED IF YOU DO NOT ACTIVATE CONNECTED VEHICLE SERVICES. EMERGENCY CALLS OR AIRBAG COLLISION NOTIFICATION CALLS TO THE CALL CENTER MAYBE MONITORED OR RECORDED FOR AUDIT PURPORSES
- Mileage Tracker (Odometer value and scale)
- Vehicle Settings
- Device Errors
- Vehicle Geolocation (Latitude, Longitude) – Only in the case of emergency (emergency call or airbag collision notification is triggered) and breakdown services (when breakdown call is triggered from the vehicle).
- Vehicle operational data (i.e., signals transmitted to, from and across the various software modules contained in your vehicle)
IF YOU DO NOT WANT THIS DATA TO BE COLLECTED, CONTACT CUSTOMER CARE (1-888-576-4878) TO DEACTIVATE YOUR VEHICLE'S TELEMATICS-ENABLING DEVICE AND REQUEST THAT THIS VEHICLE DATA COLLECTION BE STOPPED. UPON DEACTIVATION OF THE DEVICE, YOU WILL NO LONGER BE ABLE TO RECEIVE ANY CONNECTED VEHICLE SERVICES , AND ANY APPLICABLE CONNECTED VEHICLE SERVICES SUBSCRIPTION SERVICE PACKAGE. ANY FREE "TRIAL" SUBSCRIPTION, PURSUANT TO WHICH YOU WERE RECEIVING THE CONNECTED VEHICLE SERVICES, WILL IMMEDIATELY TERMINATE.
I. INFORMATION COLLECTED BY MMSCAN
We currently collect the categories of personal information listed in the "Categories of Personal Information We Collect" section below, and we may use the data for the purposes identified in the "Purposes for which Categories Will Be Used" section below. For purposes of this Privacy Statement, aggregated, de-identified or anonymized information, which includes data that is related to you but does not identify you specifically, is not considered to be personal information.
Categories of Personal Information We Collect: Depending on how you use the CV Services, we collect the following personal information from you, your vehicle, and/or your devices (collectively, "Collected Data") when you use the CV Services.
|Identifiers||Your name, address, telephone number, and email address||
|Vehicle identification number (VIN) and license plate number||
|Internet Protocol (IP) address||
|Unique mobile device identifier and mobile phone number||
|MAC address and device ID number||
|Billing Information||Your name, address, telephone number, email address, billing information (e.g., credit card number)||
|Characteristics of protected classifications||Date of birth (age)||
|Commercial information||Date and time stamp of action recorded in vehicle||
|Information about the acquisition and financing of your vehicle||
|Internet or other electronic network activity information
(This information is gathered by certain tools and methods such as log files, cookies, web beacons, and embedded scripts. For more information about how we automatically collect some of this information, please see the Tracking and Analytics section below.)
|Mobile device type, mobile device operating system, type of browser, Internet service provider, screen view time, scrolling, specific actions to activate features and/or otherwise navigate the Mobile App, reactions to alerts, searches, and your interactions with in-application marketing offers||
|Browser type, usage transaction logs, internet service providers (ISP), referring/exit pages, operating systems, date/time stamps, device type, log files, campaign engagement (e.g., clicking through campaign emails)||
|Geolocation data||Vehicle geolocation information (latitude and longitude at a particular point in time)||
|Mobile device geolocation information||
|Audio, electronic, visual, thermal, olfactory, or similar information||Communication and other user preferences||
|Mileage (odometer information), diagnostic trouble codes, Device errors, oil status, vehicle CAN signals (signals transmitted to, from and across the various software modules contained in your vehicle)||
|Vehicle speed, air bag deployments, vehicle status information (e.g., status of powered doors), vehicle settings, anti-lock events, information from your vehicle's event data recorder, and infotainment system usage||
|Voice recordings of interactions with Customer Care and emergency personnel||
Purposes for which Categories Will Be Used:
We may use the Collected Data in order to
- provide the CV Services, the Services, and customer support to you;
- monitor, measure, and report on vehicle and user engagement and CV Services usage;
- communicate relevant messages based on pattern and usage of the CV Services;
- inform you of various features of the CV Services, including to encourage use of certain features;
- offer other goods and services to you;
- solicit your feedback on the vehicle and the Services;
- provide information about our products and send you related information, including confirmations, brochures, technical notices, updates, security alerts and support and administrative messages;
- notify you of the closest Mitsubishi dealer;
- respond to comments, questions, or requests for information and provide customer service;
- communicate with you about our vehicles, products, services, information, contests, promotions, rewards, special offers, upcoming events and other news about MMSCAN we think will be of interest to you;
- monitor and analyze Connected Vehicle trends, usage and activities;
- develop new products and services, including autonomous vehicle and car-sharing products and services;
- administer your account(s) and process your payments for products and services;
- provide customer and vehicle support and service (for example, recall information, servicing and maintenance or warranty service);
- verify eligibility for vehicle purchase or incentive programs;
- comply with legal, regulatory or contractual requirements;
- generate analytics to improve the CV Services and the user experience;
- send you surveys regarding your satisfaction with customer service agents and our services;
- prevent fraudulent transactions and monitor against threats.
Your information will be accessible to the employees within the Accounting, Marketing, Sales, Aftersales, Technical, Product Planning departments who have a “need to know” such information for the above purposes.
In addition, we may share the Collected Data:
- with emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers, in order to deliver the Services (including, for example, Stolen Vehicle Assistance services, as defined in the Connected Vehicle Services Terms and Conditions);
- with certain third parties (vendors, contractors, consultants, and other service providers) such as call center, telematics service provider, online appointment scheduler vendor, etc. to provide select products and services to you
- when you give us your consent to do so, including if we notify you on the Mobile App that the information you provide will be shared in a particular manner and you provide such information;
- to the maximum extent permitted by applicable law, to (i) comply with laws or to respond to lawful subpoenas, warrants, government inquiries, litigation, dispute resolution, requests and legal process, or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to protect our rights, security, safety and property and those of our agents, customers and others, including to enforce our agreements, policies and Terms and Conditions; (iv) to detect, investigate and prevent fraud; or (v) in an emergency to protect MMSCAN and the safety of our customers, employees or any third party;
- if we believe your actions are inconsistent with our user agreements or policies, including our Terms and Conditions;
- to the maximum extent required by applicable law, we may also disclose IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion;
- with MMSCAN's affiliates, parents and subsidiaries;
- with MMSCAN's dealer network, for vehicle servicing and for their own marketing purposes;
- in connection with, or during negotiations of, any merger, sale of company assets (including a liquidation, realization, foreclosure or repossession), restructuring, reorganization, financing, disposal, conveyance, transfer lease, or any other type of transaction involving all or a portion of our assets or business to or with another company; and
- for a purpose disclosed elsewhere in this Privacy Statement or at the time you provide your information.
As permitted by applicable law, we may use and disclose all of the personal information that we collect in order to:
- Comply with federal, provincial, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; and
- Exercise or defend legal claims.
We may also collect, use, retain, sell, or disclose consumer information that is deidentified or aggregated. As noted above, such information is not considered to be personal information for the purposes of this Privacy Statement if there is no serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.
Additional Data Collection and Uses: We will not collect categories of personal information other than those disclosed above without providing a new notice at collection. In addition, we will not use your personal information for any purpose other than those disclosed above. If we intend to use your personal information for a purpose that was not previously disclosed in the notice at collection, we will directly notify you of the new use and obtain consent from you to use it for the new purpose, except as otherwise required or permitted by law.
II. TRACKING AND ANALYTICS
1. Analytics Services
HOW LONG DO WE STORE AND USE YOUR PERSONAL INFORMATION?
We will retain Collected Data only as long as it is needed for the purposes that it was collected (as described in this Privacy Statement), or for legal and regulatory compliance, in accordance with our data retention policies. After the Collected Data is no longer needed for these purposes, we will store it in de-identified form and/or delete it.
SAFEGUARDING YOUR INFORMATION
We use reasonable measures to help protect your personal information in an effort to prevent misuse and unauthorized access, disclosure and alteration. Although MMSCAN uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and MMSCAN cannot guarantee the security of your information collected from your vehicle or through the use by you of the CV Services.
OTHER RISKS AND CONSEQUENCES
You should be aware that MMSCAN may be compelled pursuant to court order, regulatory demand or other legal obligation to produce or disclose the Collected Data by law enforcement or third parties (including individuals and insurance companies) in some circumstances, including geolocation information, vehicle speed, and other information regarding your operation of your vehicle. As noted above, MMSCAN may also, in its discretion, disclose any or all Collected Data in cooperation with copyright owners, Internet service providers, wireless service providers, governmental authorities or law enforcement agencies. Such information could be used against you in legal proceedings, including in the event of a collision and/or alleged negligent, improper or unlawful conduct by you.
1. Review and Correction of Personal Information
You may access, review, rectify, correct or update any personal information that you provided to MMSCAN during your registration process by logging into the Mobile App. You may also request to access, correct, rectify or update any other personal information by contacting us, as described below, subject to any permitted or required exceptions under applicable law. You will be required to provide proof of identity in order to access such information.
2. Transmission of Vehicle Data
If you would prefer to not have MMSCAN collect any Vehicle Data (defined in the Connected Vehicle Services Terms and Conditions at https://www.mitsubishi-motors.ca/en/ccslegal/terms from your vehicle, you will need to contact Customer Care and request that your vehicle's telematics-enabling Device be deactivated and that the Vehicle Data Collection be stopped. Upon deactivation of the Device, you will no longer be able to receive any Services, and any applicable Subscription Service Package, including any Trial Subscriptions, pursuant to which you were receiving the Services will immediately terminate.
3. Marketing Communications
From time to time, you may also receive mail, email, text message, and telephone communications from MMSCAN, including communications regarding product information, marketing or promotions, research, and/or other topics. To contact you, MMSCAN may use the information you provide to us, including email, direct (postal) mail, mobile number or other telephone phone. You may, at any time, inform us that you do not want MMSCAN to contact you with marketing communications using certain or all methods by (1) contacting Customer Care, or (2) managing your email notification preferences.
In addition, you may also opt-out of promotional email communications from MMSCAN by clicking on the designated link provided in the promotional email message.
4. Service and Other Safety Notifications
Regardless of what may be said above, at the point of information collection, or your stated privacy preferences, MMSCAN reserves the right to contact you in the event of a service notification for your Device or vehicle (e.g., a recall notice), or to issue other notices concerning the safety of your vehicle.
It is your sole responsibility to tell your vehicle occupants and users about the Services and the CV Services, how they work, what data may be collected (e.g., collection of geolocation data), how that data may be shared, and what the limitations of the Services and CV services are (e.g., they may not work in remote areas). If you choose to activate features such as curfew, boundary or speed alerts, you have the obligation to explain that remote monitoring of the vehicle will be conducted using parameters that you set. You agree to make all vehicle occupants and users aware of this Privacy Statement and the privacy choices you have made, and to obtain their consent to the collection, use and disclosure of their personal information in accordance with this Privacy Statement.
If you sell, lease or otherwise transfer your vehicle directly to another person, it is your responsibility to notify such subsequent owner of the CV Services, the Services (including the Vehicle Data Collection and any other collection of data), this Privacy Statement, and the Terms and Conditions. In addition, prior to such transfer, you should delete all information (such as contacts and saved map addresses stored in the vehicle) from the vehicle and contact Customer Care to cancel your account. Any information you do not delete may be accessible to future users of the vehicle. Please refer to your Owner's Manual for instructions on how to delete information from your vehicle's system.
OTHER IMPORTANT NOTICES
The CV Services, including the Mobile App, are not intended for and are not targeted to children under the age of 16. Children under the age of 16, are not permitted to use the CV Services and should not send any information about themselves to us through the use of the CV Services. It is your sole responsibility to tell your vehicle occupants and users that the Services are not to be used by children.
We do not knowingly collect any personal information from children under the age of 16 and, if we learn that we have received information from a user under the age of 16, we will delete this information unless we have valid consent from a parent or guardian. If you are a parent or guardian and you believe that your child under the age of 16 has provided us with personal information without your consent, please contact us at [email protected]
2. Third Party Links
The Mobile App may contain links to third party websites and services, including but not limited to social media sites and applications. Because of the dynamic media capabilities of these platforms, it may not be clear to you which links are to the Mobile App and which are to external, third-party websites. You can check the URL to confirm that you have left the platform.
3. International Transfers of Information
The CV Services are operated from within the United States. If you are located outside of the United States and are accessing the Mobile App or otherwise using the CV Services, please be aware that information we collect will be collected and stored in the United States (San Jose, California and Dallas, Texas). Information transferred to, and stored in, the United States may be accessible to courts, law enforcement and government authorities in the U.S. By using or accessing the Mobile App, using the CV Services or providing us with any information through the CV Services, you consent to this transfer, processing and storage of your information in United States.
See below under “Contact Us” for information regarding how you can obtain written information about our policies and practices with respect to foreign service providers and affiliates, or to ask questions about the collection, use, disclosure or storage of personal information by such service providers and affiliates.
UPDATES TO PRIVACY STATEMENT
From time to time, we may update this Privacy Statement. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. If the changes being made are material, we will provide you with additional notice wherever possible, and obtain your consent when required by applicable law. Your inaction or continued use of the Services after any such updates or notices may be interpreted as agreement to the changes, except where explicit consent is required by applicable laws.
You may contact us, as described below, for any of the following purposes:
- If you have any questions, concerns or a complaint about this Privacy Statement, or our collection, use, disclosure or other handling of your personal information,
- To access, correct, or update personal information that you cannot access and modify directly through the Mobile App,
- To withdraw consent to continued use and disclosure of personal information,
- To obtain written information about our policies and practices with respect to service providers and affiliates outside Canada, or to ask questions about the collection, use, disclosure or storage of personal information by such service providers and affiliates on MMSCAN’s behalf.
Attention: Privacy Officer
Mitsubishi Motor Sales Of Canada
P.O. Box 41009