INTRODUCTION
Mitsubishi Motors Europe B.V. (“MME” or “we”) offers those who purchase certain models of Mitsubishi
vehicles the ability to receive Connected Vehicle Services (“Services”). This Privacy Statement explains
how Personal Information about you is collected, used, and disclosed by MME with respect to the Services,
including by the telematics device on your vehicle (the “Device”), through the online MME Connected
Vehicle Services website for customers (the “Owner Portal”), through the My Mitsubishi Connect mobile
application (the “Mobile App”), through the MME Connected Vehicle Services customer care agent at 01285
647774 (“Customer Care”), and through dealership records provided to MME in connection with the Services.
"Personal Information" means any information relating to an identified or identifiable individual. This
Privacy Statement does not apply to vehicles, products and services that are unrelated to the Services,
that are not offered by MME or that do not otherwise link to or incorporate this Privacy Statement.
MME is the "controller" in respect of the above Personal Information for the purposes of the EU General
Data Protection Regulation 2016/679 ("GDPR"). This means that we are responsible for determining what
Personal Information will be collected as well as the purpose for which and the means by which the
Personal Information is processed.
For more information about the types of Services or Subscription Packages that are offered in connection
with the Connected Vehicle Services, please review the MME Connected Vehicle Services website at https://www.mitsubishi-connect.eu.
Terms that are used but not defined in this Privacy Statement are defined in the MME Connected Vehicle
Services Terms and Conditions, available at http://mitsubishi-connect.com/en/SafeguardRemote/Europe/cvsterms.
MME will collect certain Personal Information from you at the time you buy or lease your vehicle, which
we will use for the purpose of managing our contractual relationship with you, including service of your
vehicle, notifying you of warranty issues and the like.
You should be aware that MME collects certain data from your vehicle. Depending on the
circumstances, including whether or not you have activated the Services or purchased or renewed a
Subscription, this data may include your odometer value, vehicle error codes and other vehicle-related
data, and at times will include Vehicle Geolocation Information (as defined below). This data will be
collected, used, disclosed and shared by MME in accordance with the Connected Vehicle Services Terms
and Conditions (the "Terms"), this Privacy Statement, the Connected Vehicle Services Consent Form (the
"Consent Form") and laws, rules and regulations in effect in the country where you purchased your
vehicle. MME may also use this data for marketing purposes to offer products and other services to you.
MME will only start collecting this data upon your agreement to the Terms and the Consent Form.
If you agree to the Terms and the Consent Form and subsequently decide at any time that you do
not want us to collect or use any of this data, please contact Customer Care and request that we stop
collecting this data. Customer Care will deactivate your vehicle’s telematics-enabling Device (as
defined below). Upon deactivation of the Device, you will no longer be able to receive any Services,
including any Safety Services, you will not be able to activate any new Services, and any Subscription
Service Package you had subscribed to, whether as a trial or a paid subscription, will immediately
terminate.
If you sell, lease, transfer or surrender your vehicle, we will continue to collect Collected
Data (as defined below), and attribute such Personal Information to you, until we are notified of such
sale, lease, transfer or surrender.
General Types of Information Collected
We may collect the following types of Personal Information from you, your vehicle, and/or your devices
(collectively, “Collected Data”) when you use the Services, as described in this Section:
- Customer Information
: Customer Information includes your name, address, telephone number, date of birth, email address,
personal preferences (e.g., opt-in preferences, language preferences), and other Personal Information
about you including, in certain cases, information about the acquisition and financing of your vehicle
and billing information (e.g., credit card number). Depending on the service collecting the
information, such as Automatic Collision Notification, Customer Information could also include
information about the health of vehicle occupants collected by Customer Care.
- Vehicle
Information
: Vehicle Information includes your vehicle’s vehicle identification number (“VIN”), license plate
number, mileage (odometer information), diagnostic trouble codes, Device errors, oil status, vehicle
CAN signals (i.e., signals transmitted to, from and across the various software modules contained in
your vehicle) and other information regarding your vehicle.
- Vehicle
Use
Information
: Vehicle Use Information may include your latitude and longitude at a particular point in time
(“Vehicle Geolocation Information”), vehicle speed at a particular point in time, air bag deployments,
information about the status of certain vehicle systems (e.g., status of powered doors), vehicle
settings, vehicle direction, anti-lock events, information from your vehicle’s event data recorder
(“EDR Data”), infotainment system usage, and other information relating to your use of the vehicle. The
exact data collected depends on the Services selected and other factors, including the occurrence of
certain events (deployment of air bags, or use of certain remote features such as Door Lock or Unlock).
- Mobile
Device
Information
: Mobile Device information includes information regarding your mobile device that you use to access
the Mobile App, such as the location of your mobile device (mobile geolocation information), mobile
device type, mobile device operating system, Internet Protocol (IP) address, unique mobile device
identifier, type of browser, Internet service provider, and mobile phone number; and information about
your use of the Mobile App, including 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.
- Access
Information
: Access Information is information that may be collected automatically in connection with your use of
the Owner Portal or Mobile App, and includes IP addresses, browser types, internet service providers
(ISP), MAC address, device or session ID, referring/exit pages, operating systems, date/time stamps,
your usage and activity on our Owner Portal (e.g., clickstream data), device type, log files, campaign
engagement (e.g., clicking through campaign emails), and other access-related 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 may automatically collect some of this information,
please see Section VII (Tracking and Analytics) below.
For purposes of this Privacy Statement, irreversibly anonymized information, which includes data that is
related to you but does not identify you specifically, is not considered to be Personal Information.
Information Collected by the Device/Vehicle
Depending on the type of Service or Subscription Package you are using, the following information may be
collected:
| Service / Subscription Package |
Information Collected as Part of Service |
| GENERAL |
| Vehicle Data Collection |
- Vehicle Information (including VIN, odometer
information, vehicle CAN signals and Device errors)
- Vehicle Use Information (including Vehicle
Geolocation Information and vehicle settings)
- Customer Information
|
| SAFETY SERVICES |
| ACN (Automatic Collision Notification), (SOS Emergency Assistance), bCall (Roadside Assistance) |
- Date and time stamp of action
- Vehicle Geolocation Information
- Vehicle Use Information
- Customer Information
|
| iCall (Information Assistance) |
- Date and time stamp of action
- Vehicle Geolocation Information
|
| SUBSCRIPTION SERVICES |
| Remote Services (Remote Door Lock/Unlock, Remote Horn, Remote Lights, Vehicle Settings) |
- Date and time stamp of action
- Mobile Device Informatio
- Vehicle Use Information
- Vehicle Information
|
| Security Services (Stolen Vehicle Location) and Alarm Notification |
- Date and time stamp of action
- Vehicle Use Information
- Vehicle Geolocation Information
- Customer Information
|
| Parental Controls (Geofence, Curfew Alert, Speed Alert) |
- Date and time stamp of action
- Mobile Device Information
- Vehicle Use Information
- Vehicle Information
- Vehicle Geolocation Information
|
| Car Finder |
- Date and time stamp of action
- Mobile Device Information
- Vehicle Use Information
- Vehicle Information
- Vehicle Geolocation Information
|
| Report Services (Vehicle Health Report (VHR), Mileage Tracker) |
- Vehicle Information
- Vehicle Use Information
- Vehicle Geolocation Information
|
Information Collected by the Owner Portal
We may collect the following types of information from you when you use the Owner Portal:
- Customer Information (e.g., your name, address, telephone
number, email address, communication and language preferences, other user preferences, billing
information)
- Vehicle Information (e.g., VIN)
- Access Information (e.g., IP address, browser type, usage
transaction logs)
Information Collected by the Mobile App
We may collect the following types of information from you when you use the Mobile App:
- Customer Information (e.g., your name, address, telephone
number, email address, communication and language preferences, other user preferences, billing
information, credit card information)
- Vehicle Information (e.g., VIN, Vehicle Geolocation
Information)
- Access Information (e.g., mobile operating system, usage
transaction logs, remote service transactions)
- Mobile Device Information (e.g., mobile geolocation
information)
Information Collected by Customer Care
We may collect the following types of information from you when you contact Customer Care or sign up for
an account:
- Customer Information (e.g., your name, address, telephone
number, email address, communication and language preferences, other user preferences, credit card
information)
- Vehicle Information (e.g., VIN, Vehicle Geolocation
Information)
- Mobile Device Information (e.g., mobile geolocation
information)
- Voice recordings of interactions with Customer Care and
emergency personnel
Information Collected by Other Means
We may also collect Personal Information from you through other sources, including Mitsubishi Motors
Corporation, dealers, and distributors. We collect Vehicle Information from Mitsubishi Motors Corporation
and information such as dealership records, service repair order information and registration date from our
dealers and distributors. For a list of our current distributors and dealers who provide us with Personal
Information please contact us using the contact details below.
We may combine Personal Information collected from third parties with the information we collect directly
from you. If we receive Personal Information from a third party source and/or if we combine the information
we receive from these third party sources with your Personal Information, we will treat that information as
Personal Information. We are not responsible for the accuracy of the information provided by third parties
or how such third parties collect, use and share such information.
Special categories of Personal Information
We generally do not collect or process any special categories of Personal Information about you, such as
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, or trade union membership, or information about your genetic and biometric data. We
also do not collect or process any information about criminal convictions and offences from you. If you
provide your prior consent in the Consent Form, we or our service providers may collect limited information
about your health in connection with providing Safety Services to you and may share that information with
emergency services personnel.
Consequences of not providing Personal Information requested by us
Where we need to collect Personal Information, whether by law, where we have a legitimate interest, or
under the terms of a contract we have with you, and you do not provide that data when requested or have
asked that we discontinue collecting any information from you, we may not be able to perform the contract
we have or are trying to enter into with you or provide you with any Services. Where this is the case, we
will use reasonable attempts to tell you at the time what will be the effect of your decision.
General Use
We have set out below, in a table format, a description of all the ways we plan to use your Personal
Information and which of the legal bases we rely upon to do so.
Where our or a third party's legitimate interest is stated as being the legal basis for how we use your
Personal Information, we make sure we consider and balance any potential impact on you (both positive and
negative) and your rights before we process your Personal Information for our legitimate interests. We do
not use your Personal Information for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential impact on you in respect of
specific activities by contacting us at the contact address below.
| Purpose/Activity |
Lawful basis for processing including basis of legitimate interest |
| Send you related information, including confirmations, technical notices, updates, security alerts
and support and administrative messages. |
Necessary for our legitimate interest in ensuring that customers are aware of confirmations,
technical notices, updates, security alerts and support and administrative messages. |
| Notify you of the closest Mitsubishi dealer. |
Necessary for our legitimate interest in ensuring that customers are aware of their closest
Mitsubishi dealer. |
| Process and deliver sweepstakes, contests and promotions. |
Your prior consent. |
| Respond to comments, questions, or requests for information and provide customer service. |
Necessary for our legitimate interest in satisfying customer needs. |
| Communicate with you about our vehicles, products, services, contests, promotions, rewards, special
offers, upcoming events and other news about MME that we think will be of interest to you. |
Necessary for our legitimate interest in marketing and advertising goods and services that may be of
interest to our customers. |
| Communicate with you about goods and services from our selected partners. |
Your prior consent. |
| To monitor and analyze trends, usage and activities. |
Necessary for our legitimate interest in improving our goods and services. |
| To develop new products and services, including autonomous vehicle and car-sharing products and
services. |
Necessary for our legitimate interest in producing new products and services. |
| Administer your account(s) and process your payments for products and services. |
Necessary for the performance of a contract between us. |
| Provide customer and vehicle support and service (for example, recall information, servicing and
maintenance or warranty service). |
Necessary for the performance of a contract between us. |
| Verify eligibility for vehicle purchase or incentive programs. |
Necessary for our legitimate interest in making sure that a customer is eligible for vehicle purchase
or incentive programs. |
| Comply with our legal or regulatory requirements, to respond to a legal process or requests for
information issued by government authorities. |
Necessary to comply with a legal obligation |
| Link or combine with Personal Information we get from third parties to help understand your needs and
provide you with better service. |
Necessary for our legitimate interest in improving our goods and services. |
| Conduct research and analysis, including focus groups and surveys, on the Owner Portal and other MME
websites, applications, products and services. |
Your prior consent. |
| To prevent crime and fraud. |
Necessary for our legitimate interest in preventing fraud and ensuring the security of the Owner
Portal, other MME websites, applications, products and services. |
| To establish, exercise or defend against legal claims |
Necessary for our legitimate interest in protecting and enforcing our legal rights. |
| To facilitate, manage and personalize your online experience using Essential Cookies as described
here. |
Necessary for our legitimate interest in facilitating, managing and personalizing your online
experience. |
| To operate and improve our Owner Portal and other MME websites, applications, marketing efforts,
products and services using the technology described here. |
Necessary for our legitimate interest in improving our goods and services. |
Use of Personal Information Collected by the Device/Vehicle
Specifically, with respect to the information collected in connection with the Device, we may use the
Collected Data in the following ways, depending on the type of Service or Subscription Package you are
using:
| Purpose / Activity |
Lawful basis for processing including basis of legitimate interest |
| To provide the Safety Services to you, including using Vehicle Geolocation Information. |
Your prior consent. |
| Communicate with you about our vehicles, products, services, contests, promotions, rewards, special
offers, upcoming events and other news about MME that we think will be of interest to you. |
Necessary for our legitimate interest in marketing and advertising goods and services that may be of
interest to our customers. |
| To provide the Subscription Services and support to you. |
Necessary for the performance of a contract between us. |
| Use of Vehicle Geolocation Information to provide Subscription Services to you. |
Your prior consent. |
| To monitor, measure and report on vehicle and user engagement and usage. |
Necessary for our legitimate interest in improving our vehicles and services. |
| To communicate relevant message based on pattern and usage of Services. |
Your prior consent. |
| To inform you of various features and Services, including to encourage use of certain features. |
Your prior consent. |
| To solicit your feedback on the vehicle and the Services. |
Your prior consent. |
| To monitor and record your interactions with Customer Care and emergency personnel over voice
channels to your vehicle. |
Necessary for our legitimate interest in maintaining and improving the quality of our Services and to
protect our legal rights and those of others. |
Use of Anonymized Information
We may irreversibly anonymize the Collected Data so that it does not identify you or your vehicle
specifically. We may use such irreversibly anonymized data or share it with third parties for any
legitimate business purpose.
Automated decision-making
We do not envisage that any decisions will be taken about you using automated means (other than complying
with your requests, such as a request not to receive further marketing communications or automatically
dialing the vehicle upon receiving an Automatic Collision Notification). In the event that this position
changes, we will notify you in writing.
We may share the Collected Data with:
- MME’s affiliates, parents and subsidiaries;
- Dealers from whom you purchase the vehicle, for vehicle
servicing and for their own marketing purposes.
- MME's Distributors.
- if you are financing your vehicle, with third parties who
require the Collected Data to provide financing;
- emergency service providers, such as law enforcement,
roadside assistance providers, and ambulance providers, in order to deliver related services (for
example, Stolen Vehicle Assistance Services) or in emergency situations to protect vehicle occupants, MME
and the safety of our customers, employees or any third parties;
- certain unaffiliated third parties to provide select
products and services to you such as insurance companies to provide usage-based insurance;
- companies or organizations where you have asked us to or
agreed that we may share your Personal Information with them;
- vendors, contractors, consultants and other service
providers who are working on our behalf and need access to your information to carry out their work for
us, such as providers of connected vehicle services, call centres, data aggregators, tax processors,
credit card payment processors or providers of wireless cellular services;
- to the maximum extent permitted by applicable law, with
our legal advisors, with courts or regulators, or with law enforcement authorities, to (i) comply with
laws or to respond to lawful subpoenas, 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) to
conduct screening to ensure you are not on any government list of restricted parties;
- with our legal advisors if we believe your actions are
inconsistent with our user agreements or policies, including our Terms and Conditions;
- to the maximum extent permitted by applicable law, we may
also use 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 to assist with investigations of legal violations
or fraud. Such disclosures may be carried out without notice to you; and with the counterparty 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 acquisition of all or a portion of our assets or
business to another company.
Sharing of Anonymized Information
We may irreversibly anonymize the Collected Data so that it does not identify you or your vehicle
specifically. We may use such irreversibly anonymized data or share it with third parties for any
legitimate business purpose.
We will retain Collected Data only for as long as it is needed for the purposes listed here. This includes
for the purpose of satisfying any applicable legal or regulatory requirements. We may retain your Collected
Data for a longer period if we reasonably believe that the information may be relevant to any possible
legal action, whether initiated by you or any other party.
Where information is used for more than one purpose, we will retain it until the purpose with the latest
period expires.
If we keep any Collected Data after the Collected Data is no longer needed for these purposes, we will
store it in anonymized form. Otherwise we will delete it.
For more information about our retention policies, please contact us using the contact details below.
Personal Information provided during registration process
You may review and update any Personal Information that you provided to MME during your registration
process by logging into the Owner Portal or the Mobile App. On removal of any such Personal Information
from your registration details, we will delete the corresponding Personal Information from our systems. For
further information on how to manage your registration details please contact us at the contact details
below.
Transmission of Vehicle Data
Except as enabled by “Privacy Mode” as described immediately below, the Connected Vehicle Services do not
permit users to share some types of Vehicle or Access Data but not other types. If you wish to disable all
collection of Connected Data, please contact Customer Care at 01285 647774 and request that your Device be
inactivated and your Services discontinued. Please note that we will not be able to provide any services to
you, including any emergency services, once this has taken place unless you call to reactivate your Device,
and any applicable Subscription Service Package, including any Trial Subscriptions, pursuant to which you
were receiving Services will immediately terminate.
You can put your vehicle into "Privacy Mode" using the Mobile App. The vehicle will remain in Privacy Mode
until you take it out of Privacy Mode. While the vehicle is in Privacy Mode, the Device will not send the
location of the vehicle to us other than to facilitate emergency services, i.e., Automatic Collision
Notification. Whilst in "Privacy Mode" you will not be able to use the "Car Finder" or "Stolen Vehicle
Assistance" service to locate the vehicle. However, if your vehicle is in an event that triggers an
Automatic Collision Notification, or if you push the SOS or Information Assistance Buttons, your latest
known location will be provided to Customer Care. In addition, you may still use the Geofence function as
described in the Owner's Manual while your vehicle is in Privacy Mode.
Marketing Communications
By purchasing a product or a service from us [or any of our affiliates] you agree that we may from time to
time, send you mail, emails, text messages and telephone communications, including communications regarding
product information, marketing or promotions, research, and/or other topics about goods and services that
we may be able to provide to you, which may be the same or similar to those that you already receive from
us. We will process your Personal Information to contact you in this way and the legal basis for this
processing will be our legitimate interest in marketing and advertising services that may be of interest to
you. To contact you, we may use the information you provide to us, including email, direct (postal) mail,
mobile number or other telephone number.
You may, at any time, inform us that you do not want MME to contact you with marketing communications or
withdraw your consent to marketing communications from third parties using certain or all methods by (1)
contacting Customer Care, (2) indicating your preference through the Owner Portal, or (3) managing your
email and text alert notification preferences from within the Mobile App.
We will obtain your express opt-in consent before we share your Personal Information with any third party
for marketing purposes.
In addition, you may also opt-out of promotional email communications from MME and third parties by
clicking on a link provided in the promotional email message. You may also opt-out of promotional text
message communications from MME and third parties by texting STOP from the mobile device that you have
registered with MME. After opting-out, you will no longer receive marketing or promotional communications
through the applicable method, but will continue to receive other messages, such as Remote Services
notifications and specific information related to your use of the Services or vehicle (e.g., warranties,
service reminders).
Note that deactivating your Device will not automatically opt-you out of receiving such marketing or
promotional communications.
Service and Other Safety Notifications
Regardless of what may be said above, at the point of information collection, or your stated privacy
preferences, MME 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.
We value your privacy and will take all reasonable measures to help protect your Personal Information
against misuse and unauthorized access, disclosure and alteration. You should understand that transmission
via the Internet or over wireless cellular channels is not completely secure, and MME cannot guarantee the
security of your information collected from your vehicle or through the use by you of the Services.
When you visit the Owner Portal, we may conduct the following activities that will involve use of your
Personal Information for tracking or analytics purposes.
Log Files
We collect certain information automatically and store it in log files. This information may include,
without limitation, internet protocol (IP) addresses, browser types, internet service providers (ISP),
referring/exit pages, operating systems, date/time stamps and clickstream data.
Cookies
When you visit the Owner Portal, you may be issued one or more “cookies,” small data files stored on your
hard drive, to help make your website visit more relevant and personalized for you. We use session cookies,
which expire when you close your browser, to make it easier for you to navigate the Owner Portal. We use
persistent cookies, which remain on your hard drive, to help remember you in subsequent visits. You can
delete persistent cookies using the tools in your web browser.
We use cookies to track what users do when they visit the website and see which areas and features are
popular. We also count visits to the Owner Portal. Most browsers are initially set to accept cookies. If
you would prefer, you may set your browser to refuse cookies or alert you when cookies are being sent;
The table below sets out the type of cookies that may be used on the Owner Portal and provide details
about what they may be used for. When you visit the Owner Portal for the first time, cookies which are
essential to make our Owner Portal operate (see those identified as "essential cookies" below) may be set
but other cookies will not have been set unless you agreed to those cookies being set at that time. To the
extent the information we collect from you using essential cookies is Personal Information, the legal basis
for processing such information is our legitimate interest in enabling you to use the Owner Portal
securely. Any Personal Information that is collected using any other types of cookies is processed only to
the extent that you have provided your prior consent. If you have agreed to accept cookies then the Owner
Portal will remember this and continue to set cookies each time you visit. If you do not want cookies to be
stored, then you may turn off certain cookies listed below, or you can select the appropriate options on
your web browser. However, it is possible that some parts of the Owner Portal will not function properly if
you do so and we may not be able to provide you with the most convenient or tailored experience.
| Cookie type |
Purpose |
| Essential Cookies |
These are required for the operation of the Owner Portal. They include, for example, cookies that
enable you to log into secure areas of our website and to customize your account and news profile and
cookies that allow us to recognize that you have agreed to conditions you must accept to view certain
pages or documents or registered for alerts. |
| Analytical/Performance Cookies |
These allow us to capture traffic and usage patterns, for example, to recognise and count the number,
types and locations of visitors to the Owner Portal and to see how visitors move around the Owner
Portal when they are using it. This helps us to improve the way our websites work, for example, by
ensuring that users are finding what they are looking for easily, and to otherwise improve our users’
experience and understand the types and locations of visitors to the Owner Portal. |
| Functionality Cookies |
These cookies are used to recognize you when you return to our Website. This enables us to
personalize our content for you, greet you by name and remember your preferences (for example, your
choice of language or region). |
| Marketing or Targeting Cookies |
These cookies record your visit to the Owner Portal, the pages you have visited and the links you
have followed. We will use this information to make the Owner Portal and the advertising displayed on
it more relevant to your interests. We may also share this information with third parties for this
purpose and to inform our marketing partners that you have visited the Owner Portal, so they can serve
our brand messages to other sites you visit. |
Web Beacons
The Owner Portal and any communications sent by MME may contain electronic images (generally, single pixel
“.gif’ images) called “web beacons.” These web beacons allow MME and third parties to monitor and collect
certain information about the viewer of a web page, email message or other communication, such as the type
of browser requesting the web beacon, the device identifier of the device the web beacon is sent to and the
time the web beacon was viewed. Web beacons may be used to count unique users, visits and page views;
monitor traffic and conversion patterns; personalize your experience when you visit the Owner Portal,
including content you see; and determine whether or not messages were opened, links were clicked and/or
notifications/offers were acted upon.
Embedded Scripts
An embedded script is programming code that is designed to collect information about your interactions
with the Owner Portal. It may be temporarily downloaded onto your computer from our web server or a third
party with whom we work. If we use embedded scripts, they will be active only while you are connected to
the Owner Portal, and will be deleted or deactivated thereafter.
Information we automatically collect about you, such as how you interact with the Owner Portal, may be
combined with your Personal Information. If we associate any such automatically-collected information with
Personal Information about you, we will treat the combined information as Personal Information.
Do Not Track
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to
websites and online services you visit. There is no consensus among industry participants as to what “Do
Not Track” means in this context. Like many websites and online services, MME currently does not alter its
practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not
Track,” you may wish to visit https://allaboutdnt.com/.
Analytics Services
We may use Google Analytics and tools from other service providers to help us understand how visitors use
the Owner Portal and our other websites. Such third parties may be able to collect limited information
about you, including through the use of cookies. These tools provide information about the types of users
that visit the Owner Portal and help us improve the Owner Portal. For example, Google Analytics provides us
with certain data regarding the demographics of the users that visit the Owner Portal. You can learn more
about Google Analytics and how it collects and processes data (including how to control the information
sent to Google) by visiting: http://www.google.com/policies/privacy/partners/.
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout/
or downloading the Google Analytics Opt-out Browser Add-on.
It is your sole responsibility to tell your vehicle occupants and users about the Services and how they
work, what data may be collected (e.g., collection of Vehicle Geolocation Information) and how that data
may be shared, and what the limitations of the Services are (e.g., they may not work in remote areas). If
you choose to activate features such as Curfew, Geofence 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.
If you sell, lease or otherwise transfer your vehicle directly to another person, it is your
responsibility to notify such subsequent owner of the Services (including the Vehicle Data Collection and
any other collection of data) and 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. Cancelling the Account deletes
all Personal Information and resets the Device to initial settings, although some collection of Vehicle
Data may continue, including information required to provide Safety Services. If you do not 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.
Where necessary or desirable to carry out the data processing described in this Privacy Statement, we may
transfer your Personal Information internationally, including to third party companies (designated
Processors). We will require these recipients to protect your Personal Information to the same extent as
ourselves, and will take appropriate measures to oversee their activities with regard to protecting the
Personal Information entrusted to them.
If required to provide Services to you, we may use the services of third parties located in countries
outside the European Economic Area ("EEA"), such as to provide support or technical services. While we will
use reasonable efforts to minimize the international transfer of your Personal Information, these third
parties may require access to some of your Personal Information. If the country in which they are located
has not yet been deemed by the European Commission to offer adequate data protection, then we will take the
following steps to ensure an adequate level of data protection in the country of the recipient as required
under the Regulation, including imposing contractual terms approved by the European Commission that enable
the transfer of personal data in countries outside the EEA, requiring that specific technical and
organizational processes be followed, that we be permitted to audit their systems, processes and actions,
and that they report to us about any threats to Personal Information. If you wish to obtain a copy of these
safeguards, please contact us at the contact address above.
Personal Information may be transferred to the following countries outside the EEA:
- United States of America
- India
If you are a resident of the European Economic Area, then you have certain rights, under certain
circumstances, with respect to the Personal Information that we collect about you. These rights may include
the right:
- to request access to the Personal Information we hold
about you;
- to receive a copy of the Personal Information that you
have provided to us in a structured, commonly used and machine-readable format so that you can share it
with others;
- to review your Personal Information to see if it is
inaccurate or incomplete, and in such case to ask for the Personal Information to be rectified or
completed;
- to ask that your Personal Information no longer be
retained;
- to object to us processing your Personal Information by
asking for the processing of that Personal Information to be restricted or stopped;
- to ask us not to process your Personal Information for
marketing purposes; and
- where you had previously given consent to processing your
Personal Information for specific purposes, then to withdraw your consent for some or all purposes. Once
we have received notification that you have withdrawn your consent, we will no longer process your
information for the purpose or purposes you originally agreed to, unless we have another legitimate basis
for doing so in law. Please note that the withdrawal of your consent will not affect the lawfulness of
any processing of Personal Information based on your consent before its withdrawal.
In addition to using the Owner Portal or Mobile App to view your Personal Information, you can also
exercise these rights at any time in writing by contacting us at our contact details below. We reserve the
right to exchange correspondence with you in this regard. Please note that we may be required to retain
some or all of your Personal Information even after a request for erasure where there is a lawful reason or
obligation to do so.
You always have the right to make a complaint concerning processing of your Personal Information by
contacting the relevant supervisory authority. You can do this with the data protection authorities at your
place of residence, at your place of work or at the place of the alleged data breach. You can find contact
details for all the EU data protection authorities at https://edpb.europa.eu/about-edpb/board/members.
Children
The Services, including the Owner Portal and the Mobile App, are not intended for and are not targeted to
children under the age of 13. Children under the age of 13, are not permitted to use the Services and
should not send any information about themselves to us through the use of the 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 13 and, if we learn
that we have received information from a user under the age of 13, we will delete this information. If you
are a parent or guardian and you believe that your child under the age of 13 has provided us with Personal
Information, please contact us at 01285 647774 .
Third Party Links
The Owner Portal and Mobile App may contain links to third party websites and services, including but not
limited to social media sites and applications. This Privacy Statement does not apply to the linked sites,
and we do not control, nor are we responsible for, the content or privacy and security practices of those
sites. Any Personal Information you provide to a linked site or service is provided directly to a third
party and is subject to such third party’s privacy policy. We encourage you to learn more about such third
party’s privacy and security practices and policies before providing any of your Personal Information.
If you have any questions or concerns about this Privacy Statement, please contact MME by calling Customer
Care at 01285 647774, or emailing us at customer.services@mitsubishi-cars.co.uk, or sending us a request at
the address below:
- The Colt Car Company
- Product Planning and Incentives Department
- Watermoor
- Cirencester
- Gloucestershire
- GL7 1LF
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 we significantly change our
practices described in the Privacy Statement in a way that could reasonably be seen to decrease your
privacy (such as collection more Personal Information, using it in certain new ways or sharing it with new
types of third parties, or reducing our data security), we will provide you with additional notice of the
specific changes using the contact preferences you have given us. If the changes are not material, we may
not specifically ask for your consent, although you may contact us to update your privacy preferences as
described above. Otherwise, we will understand your continued use of the Services, including access to the
Owner Portal, after any such updates or notices your agreement to these changes.
