Mitsubishi Connect Privacy Policy
Mitsubishi Motors Australia Limited Privacy Policy for Connected Car Services
1. Privacy and Security Policy
Mitsubishi Motors Australia Limited and our related entities (MMAL, we, us or our) are committed to protecting the privacy of your personal information in accordance with the Privacy Act 1988 (Cth) including the Australian Privacy Principles (APPs).
This policy is intended to provide a general overview of our approach in respect of the handling and management of your personal information in relation to the 'Connected Car' application software and related platforms, systems and services (including any in-vehicle functions) (Connected Services). This policy applies to the Connected Services only, and our general Privacy Policy will apply to interactions with us outside of the Connected Services.
Other policies may override, or apply in addition to, this policy in certain circumstances. For example, when we collect personal information from you, we may advise a specific purpose for collecting that personal information, in which case we will handle your personal information in accordance with that stated purpose.
This policy is intended to cover most personal information for Connected Services handled by us (and our authorised agents who collect personal information on our behalf), but is not exhaustive. If you have any queries about our management of your personal information, you are encouraged to contact our Privacy Officer for further information (see section 12 below).
By activating, accessing or using the Connected Services (including creating an account for the Connected Services), or by providing or allowing collection of your personal information through the Connected Services (Use), you consent to us handling your personal information in accordance with this policy.
If you do not agree to this policy, you should de-activate and cease Using the Connected Services. However, you agree that some features of the vehicle cannot be de-activated through the Connected Services application software. Please contact us or consult the Connected Services platform for further information about such features and whether they can be de-activated such as the deactivation of the Telematics enabling device.
In addition to the circumstances described in this policy, your personal information may be accessed or used as required or permitted by law.
2. Collection of your personal information
We will collect your personal information when you Use the Connected Services.
We aim to limit the personal information we collect to what is reasonably necessary to fulfil the Connected Services. In most cases, we or our agents and contracted service providers will collect your name, date of birth, address, contact details (including telephone number and email address), emergency contact, driver's licence number, geolocation information and payment details. We may also collect any other personal information that you volunteer to us. We may also collect information about your vehicle, such as make and model, VIN, registration number plate, distance travelled and other vehicle usage and diagnostic details, and your mobile device or phone.
Generally we collect your personal information directly from you or through the Connected Services unless it is impracticable or unreasonable to do so.
If you do not provide the personal information we request, or the information you provide is inaccurate or incomplete, you may be unable to access or use all or part of the Connected Services.
3. Purposes for which we collect, hold, use and disclose your personal information
We will generally only use and disclose your personal information to allow you to Use the Connected Services and for us to operate and maintain supporting or associated functions (for example, providing roadside assistance services, diagnostic services etc), for related purposes that you would reasonably expect, and as otherwise required or permitted by law.
We may use and disclose your personal information for purposes including:
- providing safety services, such as automatic collision notification and SOS emergency assistance;
- notifying you when your Mitsubishi vehicle is due to be serviced, or in the event of any maintenance issue that we identify;
- providing security services, such as notifying you when the vehicle alarm is activated and providing assistance to track the vehicle if stolen;
- if your Mitsubishi vehicle is a plug in hybrid electric, providing monitoring and other services for features such as the battery level of the vehicle and the status when charging your vehicle; and
- assisting you to remotely find and monitor your Mitsubishi vehicle.
The features of the Connected Services may change over time, and by continuing to Use the Connected Services you agree to the collection, use and disclosure of your personal information for the purposes of any additional features or functions of the Connected Services.
By Using the Connected Services, you consent to us using your personal information for the above purposes. You also agree that we may also use your personal information to directly contact you for marketing and promotional purposes. You may request not to receive these communications by contacting our Privacy Officer using the details set out below, or by using the opt out function provided for in those communications. If you do not opt out in either of these ways you will be taken to have consented to receiving such communications from us. There are no consequences for opting out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to rejoin our marketing list at a later time if you wish.
We may communicate your personal information within our corporate group, to authorised Mitsubishi dealers, and to our authorised agents and contracted service providers that provide administrative or promotional services (for example, providers of maintenance or support for the Connected Services, including Aeris Communications, Inc. which is a Connected Services provider).
4. Sensitive Information
We will only collect 'sensitive information' with your consent. 'Sensitive information' is a sub-category of personal information that includes any information or opinion about an individual's racial background, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, memberships or affiliations with professional trade associations or unions, sexual orientation or criminal record that is also personal information as well as information about an individual's health, genetic or biometric information). We will assume that you have consented to us collecting all information which is provided to us by you for use in accordance with this policy, including any 'sensitive information', unless you notify us otherwise at the time you provide it to us.
5. Information about third parties
If you provide us with personal information about a third party (for example, your emergency contact), in doing so you represent and warrant to us that you have that person's consent for us to collect and handle their personal information in accordance with this policy – and we will be collecting their personal information on that basis.
6. Storage and security of your personal information
We may hold your personal information in electronic formats or in hard copy.
We aim to store your personal information securely to ensure that your personal information is protected from unauthorised access, modification and disclosure, and from other types of misuse, interference and loss.
We will take reasonable steps to destroy or de-identify your personal information if we no longer require it for any purposes for which it can be lawfully used and/or disclosed. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes. Your personal information may also be retained in our IT platform back-up records.
The transfer of data over the internet or other public networks is inherently insecure. We cannot guarantee the security, during transmission, of any personal information provided to us via, or stored in, the Connected Services. Please bear this in mind when using the Connected Services.
7. Access to and correction of personal information
You agree to regularly update the personal information in your account for the Connected Services to ensure that it remains correct and up-to-date.
You may lodge a request to access personal information that we hold about you, or to correct your personal information if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading. The best way to access and update your personal information is to use that functionality in the Connected Services, however you may also contact our Privacy Officer via the contact details below to make a formal request.
If you make such an access request, we will generally provide you with access except in limited circumstances where the law permits us to deny access. Any such requests must be made in writing to our Privacy Officer via the details shown below. We will not charge you a fee for requesting access but if your request for access is accepted, we will inform you in advance of any fee that you will need to pay us for providing access.
8. Location tracking
The Connected Services may allow the location of your Mitsubishi vehicle to be identified, which supports a number of features of the Connected Services (for example, allowing you to remotely locate your vehicle). By Using these features of the Connected Services, you consent to us (or our agents or service providers) tracking the location of the vehicle. For the purposes of any applicable surveillance device laws, this includes consent to the installation, use and maintenance of a tracking device (or such other similar terminology used in relevant legislation).
You agree to notify any passenger in your Mitsubishi vehicle, or any other person that you allow to use your Mitsubishi vehicle, that the location of the vehicle may be tracked as part of the Connected Services.
We will only use the location tracking data for the purposes of fulfilment of the Connected Services, or as otherwise required or authorised by law.
9. Overseas disclosure of personal information
Generally, we do not disclose your personal information to overseas recipients other than to our related bodies corporate, except with your consent or where we are required or authorised to do so by law.
In some circumstances, we may disclose your personal information to our related bodies corporate in Japan, or our contracted service providers located in India, Singapore, Belgium and the USA, including contractors which are Connected Services providers. By providing us with your personal information and using the Connected Services, you consent to the overseas disclosure of your personal information and acknowledge that such information may not necessarily be handled in accordance with the APPs.
10. Changes to our privacy policy
We reserve the right to amend, modify or replace this policy at any time. You should review our privacy policy regularly. Our current privacy policy is published in the Connected Services.
11. Complaints
If you believe that a breach of your privacy has occurred or you otherwise have a complaint about our use of your personal information, please contact our Privacy Officer via the contact details below. We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response, which generally, will be within 14 days of receiving your complaint.
12. Contact us
If you would like more information about the way we manage your personal information or if you have a complaint, please contact your respective Privacy Officer via the details below.
Privacy Officer
PO Box 249
EXPORT PARK, SA 5950
Email: privacy@mmal.com.au