Vehicle Data Privacy Notice

last update: March 2024

GENERAL PRIVACY POLICY

Our Commitment to Protecting Your Information

Mitsubishi Motors Europe B.V. with its registered office at Mitsubishi Avenue 21, (6121 SH) Born, the Netherlands and our affiliated businesses (collectively, “MME“, “we” or “us“) are committed to being responsible custodians of the information you provide us and the information we collect in the course of providing our products and services to you.

This Privacy Notice explains how we will handle your personal data when providing our connected car services or other vehicle-related services (such as vehicle maintenance services) to you.

You can subscribe to our connected car services through your My Mitsubishi Motors account and you can access our connected car services through the My Mitsubishi Motors App and the Smartphone-link Display Audio (SDA) Infotainment system in your vehicle.

The MME connected car services are provided through a proprietary platform of Renault S.A. with its registered office at 122-122 bis avenue du Général Leclerc – 92 100 Boulogne-Billancourt, France (hereafter “RSA”) (with the exclusion of Google Automotive Services). MME and RSA act as data controller and processor respectively for the processing of personal data when providing the connected car services.

You should read this Privacy Notice together with the General Mitsubishi Motors Europe Privacy Policy (the “General Privacy Policy”) in which we describe in general terms how we collect your personal data and why we collect it, what we do with your personal data, with whom we share it, how we protect it, and the choices you can make about your personal data.

What personal data do we collect from you?

We will collect and use the following personal data:

Type of data

Type of dataDescription
Account information
  • Your name (e.g. title, first name, last name)
  • Language (e.g. mother tongue, preferred contact language)
  • Contact information (e.g. phone number, email address, mailing address)
  • Your My Mitsubishi Motors account details (e.g. preferred contact method, subscription information, authorized retailer/repairer preference)
  • App usage data (e.g. login statistics, error messages)
  • Your privacy preferences (e.g. date consent was given, what you consented to, date consent was withdrawn, how consent was given)
  • Emergency contact information (if provided on your My Mitsubishi Motors account)
  • Information relating to our invoices to you and your payments to us (e.g. payment transactions, such as the amount you paid, the date of payment, and the payment method used).
Vehicle usage data
  • Driving behavior data: driving logs (e.g. start and end times of trips, routes taken, distance traveled); speed (e.g. average speed, maximum speed); acceleration and braking data (e.g. average acceleration, average deceleration, time spent hard braking)
  • Technical vehicle data (e.g. mileage, fuel consumption; oil temperature; warnings (e.g. low fuel warning, oil change warning, tire pressure warning))
  • Diagnostic data (e.g. system failures, diagnostic trouble codes (DTCs))
Vehicle identification & service information
  • Vehicle identification data: vehicle registration plate, vehicle identification number (VIN), date of purchase of the vehicle, IP address of the SIM card in the vehicle’s data communication unit, vehicle accessories)
  • Contracts relating to your vehicle (e.g. insurance, leasing, additional warranty)
  • Service and maintenance history
Geo-positioning & location data
  • The geographic coordinates of your vehicle and/or your smartphone (e.g. latitude, longitude)
  • The planned route of your vehicle which can include your vehicle’s starting point, destination, and waypoints
  • The history of your vehicle’s journeys
  • The direction in which your vehicle is moving
Security data
  • In order to protect our systems and data, we keep certain information about the way our IT systems, applications and networks are being accessed and used. For example, during a limited period of time we keep logs of who has accessed your connected car data, and when, so as to be able to investigate any potential threat to the confidentiality, integrity and availability of your connected car data.
Why do we collect/use your personal data?

We collect and use your personal data for the following purposes:

PurposeLegal basisData
To manage our commercial relationship with you

We use your personal data to manage our commercial relationship with you:

  • To manage of your vehicle order (including tracking from production to delivery);
  • To handle your request to register your vehicle;
  • To handle your request for documents regarding your vehicle;
  • To activate and manage your contracts (maintenance, extra warranty, connected car services);
  • To manage your My Mitsubishi Motors account and means of authentication;
  • To handle your queries and complaints (including your privacy-related requests or complaints – see the section “What are my privacy rights?” below)
  • To conduct satisfaction surveys, managing and responding to your reviews, in order to improve customer satisfaction and to improve our products and services;
  • To run a vehicle recall campaigns in case of due to a quality or safety issue;
  • To raise invoices and to manage and collect payments.
  • We process your personal data to perform the contract that you have concluded with us
  • We process your personal data based on our legitimate business interest to manage our relationship with you
  • In some cases (e.g. in the case of a vehicle recall campaign) we process your personal data because we have a legal obligation (e.g. we must process your personal data to contact you if your vehicle is part of a recall campaign).
  • Account data
  • Vehicle identification & service information
To provide our products and services to you
We process your personal data to provide our connected car services and/or other vehicle-related services (such as vehicle maintenance services) to you. To secure our networks and systems In order to protect the confidentiality, integrity and available of the data that we hold about our customers, we must ensure our systems and networks are secure. For example, we keep logs of who has accessed which system when and we investigate these logs in case we have indications of actual or suspected security incidents on our networks and systems. These logs may contain personal data.We process your personal data to perform the contract that you have concluded with us
  • Account data
  • Vehicle usage data
  • Vehicle identification & service information
  • Geo-positioning & location data
  • Security data
To secure our networks and systems
In order to protect the confidentiality, integrity and available of the data that we hold about our customers, we must ensure our systems and networks are secure. For example, we keep logs of who has accessed which system when and we investigate these logs in case we have indications of actual or suspected security incidents on our networks and systems. These logs may contain personal data.
  • We process your personal data based on our legitimate business interest to keep our networks and systems secure.
  • To the extent that we are legally obliged to keep our networks and systems secure, we process your personal data based on a legal obligation.
  • Security data
Cooperation with law enforcement authorities, handling complaints and managing disputes

We process your personal data when:

  • Law enforcement authorities require us to disclose your personal data to them (e.g. as part of a criminal investigation)
  • That is reasonably necessary for us to handle a complaint
  • That is reasonably necessary for us to handle a dispute

Cooperation with law enforcement authorities, handling complaints and managing disputes

  • We process your personal data based on our legitimate interest.
  • We process your personal data based on a legal obligation.
  • Account data
  • Vehicle usage data
  • Vehicle identification & service information
  • Geo-positioning & location data
  • Security data
Improving our products and services and developing new products and services
We may use your personal data to conduct research and development activities such as data analytics. This will help us enhance and improve our products and services, develop new mobility products and services. For instance, if there is a technical problem with a particular vehicle model, we may use your personal data to try and solve that problem.
  • We process your personal data based on your consent.
  • Exceptionally we process your personal data based on our legitimate interest to continually improve our products and services and to innovate.
  • Vehicle usage data
  • Vehicle identification & service information
  • Geo-positioning & location data
  • Security data
To comply with laws and regulations

There are laws and regulations that require us to process personal data. For example:

  • In many countries we are required to keep invoice-related data (including personal data stated on the invoice) for tax reasons;
  • We are legally obliged to collect certain data relating to on-board fuel consumption.
  • We process your personal data based on a legal obligation.
  • Account data
  • Vehicle usage data
  • Vehicle identification & service information
  • Geo-positioning & location data
  • Security data

As part of our connected services, we provide and integrate with Google services, specifically Google Maps, Google Assistant, and Google Play. Read Google’s privacy policy (available at https://policies.google.com/privacy) to obtain more information about how Google processes your personal data.

What if you sell your vehicle or otherwise allow others to use your vehicle?

If you sell your vehicle or allow others to use it, you are responsible for ensuring that they are aware of this Privacy Notice.

Before selling your vehicle to another person or reseller, you should take these steps to protect your privacy:

  • Unpair your vehicle from your My Mitsubishi Motors account. This will prevent you from accessing the new owner’s personal data through your account; and
  • Delete all of your personal data from the vehicle by means of performing a factory reset and erasing all data and settings from the SDA infotainment system. This includes any data or content that you have stored on the vehicle, such as your navigation history, contact list, and music preferences.
How long will MME keep my personal data?

We keep your personal data for no longer than is necessary for the purposes for which they are processed.

We keep your personal data for different lengths of time, and this depends on a few things. First, it depends on why we’re using your data – we only keep it for as long as we need it for that reason. Second, there are some rules in the law that say we have to keep your data for a certain amount of time, and we have to follow those rules. So, basically, we hold onto your personal data as long as we have a good reason to, and sometimes the law tells us how long we have to keep it.

For the My Mitsubishi Motors app, if you don’t use your account for three years, we have a rule in place. We continually check for accounts that have been inactive for this amount of time. If we find any, we delete them, along with any personal data linked to those accounts, from our systems. This helps us keep our records tidy and ensures that we’re not holding onto information we don’t need any more while also protecting your privacy. We do this regularly to keep everything running smoothly and securely.

Who do we share your personal data with?

We will share your personal data with others for the following purposes:

  • With other entities of the Mitsubishi Motors group of companies. We are part of a multinational group of companies and sometimes we may share personal data with other Mitsubishi Motors entities for the purposes of efficient management of our business, compliance with legal and regulatory requirements and to provide our connected car services to you.
  • With our distributors, retailers and repairers for them to (i) provide services to you (e.g. maintenance and repair services) or (ii) to handle and respond to requests from law enforcement authorities;
  • To our third-party service providers that perform services on our behalf (e.g. external providers IT services, mailing services, market analysis services);
  • We may anonymise your personal data and share these anonymous data with third parties for legitimate purposes such as for developing new mobility services and solutions;
  • If we are under a duty to disclose your personal data in order to comply with any legal obligation (e.g. when law enforcement authorities require us to disclose vehicle-related data as part of a criminal investigation) or if we need to establish, exercise or defend our legal rights;
  • If reasonably necessary in connection with a dispute in which we are or may become involved, we may share your personal data with, for example, the other part(y)(ies) involved in the dispute or with a court of law;
  • If we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • If we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer.
Transfers of personal data outside the European Economic Area

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected in the EEA. This can be done in a number of ways, for instance:

  • The country that we send the data to might be approved by the European Commission as providing an adequate level of data protection;
  • We may have concluded a contract with the non-EEA recipient that contains privacy clauses that have been pre-approved by the European Commission; or
  • Where the recipient is located in the US, it might be a certified member of the EU-US Data Privacy Framework.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

What are my privacy rights?

You have the following rights regarding your personal data (depending on and subject to applicable laws):

RightsWhat does this mean?
1. Right to be informedYou have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this notice.
2. Right of accessYou have the right to access the personal data we keep about you – this is because we want you to be aware of the personal data we have about you and to enable you to verify whether we process your personal data in accordance with applicable data protection laws and regulations.
3. Right to rectificationIf your personal data is inaccurate or incomplete, you have the right to request the rectification of your personal data.
4. Right to erasureThis is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep it. This is not a general right to erasure, there are exceptions.
5. Right to restrict processingYou have rights to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. Right to data portabilityYou have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such personal data transferred directly to a third party.
7. Right to object to processingYou have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interests or on public interest grounds; the right to object to processing for direct marketing purposes (including profiling); the right to object to the use of your personal data for scientific or historical research purposes or statistical purposes in certain circumstances.
8. Right to withdraw consentIf our processing of your personal data is based specifically on your consent, you have the right to withdraw that consent at any time. This includes your right to withdraw consent to our use of your personal data in the context of voluntary employee surveys.
9. Right to object to automated decision makingYou have the right not to be subject to a decision based solely on automated Processing, including profiling, which produces legal effects for you or similarly significantly affects you. Automated decision making takes place when an electronic system uses personal data to make a decision without human intervention. This is not a general right to object, there are exceptions. For example, we are allowed to use automated decision making where it is necessary to perform a contract with you and appropriate measures are in place to safeguard your rights.
 
Contact us and complaints

We take your privacy seriously. That is why we want to make it easy for you to learn more about how we use your personal data and to exercise your privacy rights:

  • Visit your My Mitsubishi Motors account on the My Mitsubishi Motors app: This is the best place to find the account information that we hold about you. You can directly rectify your account-related personal data or choose to delete your account.
  • Contact your preferred Mitsubishi Motors Dealer or Mitsubishi Motors Distributor in your country. We will do our best to respond to your requests promptly and in accordance with the law. Please note that we may ask you to provide proof of identity to prevent unauthorized access to your personal data.

Otherwise, and in addition to the above, you may contact our Data Protection Officer at dpo@mitsubishi-motors-euro.com to exercise your privacy rights.

You also have the right to file a complaint with the data protection authority in your country. you can find the contact details of your country’s data protection authority here.

Changes to this Privacy Notice

MME may update this Privacy Notice from time to time. The effective date of the current version of the Privacy Notice is noted at the top of the notice. MME encourages you to periodically review this notice.

Differences or discrepancies between the General Privacy Policy and this Privacy Notice

In the event of any conflict or inconsistency between a clause in this Privacy Notice and a clause in the General Privacy Policy, this Privacy Notice shall take precedence.