Information Collection Statement

INFORMATION COLLECTION STATEMENT

Reliance Motors Ltd. (the “Company”, “we”, “us” or “our”) recognises its responsibilities in relation to collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate. The Company will take all practicable steps to ensure security of the personal data and to avoid unauthorised or accidental erasure or other use.

This Information Collection Statement describes how the Company uses your information in connection with your Honda vehicle’s update of Engine Control Module (“ECM”) through Over The Air (“OTA”) or Secured Reprogramming (“SR”). Please take the time to read it carefully.

Performing an ECM update for your Honda vehicle

When you perform an ECM update for your Honda vehicle purchased from us (“Honda vehicle”) through OTA or SR, some information may be collected from your Honda vehicle as part of the update procedure. The information will be transferred to Honda Motor Co., Ltd. (“HM”)’s data centre located in Japan via a distribution server located in the United States.

Information we may collect

We may collect the following information from your Honda vehicle (the “Information”) for the purposes stated to the right of each data type below:

Data type

Purpose

Vehicle Identification Number (“VIN”)

To search for an update and record the history of the update

Engine Control Unit (“ECU”) part number

To search for an update

ECU version

To search for an update

ECU serial number

To detect part replacement

Language selected

To be used for providing change point description to customer in the customer preferred language

Update method

To record the update method (i.e. OTA or J2534 dealer rewrite)

Event type

To record the update activity timestamps (i.e. notification, download, update approval, and update start)

Mileage

To record when the update is performed

Download file size

To record data volume for cost calculation

Download retry count

To perform an analysis for cost calculation

IP address

Captured by server for security log

Timestamp

To record a timestamp

Result code

To record the update result

Error code

To record the cause when update failure happens

Diagnostic Trouble Code (“DTC”)

To be used for analysis when software update cannot perform

Warning lamp brining status

To be used for analysis when software update cannot be performed

ECU boot status

To be used for analysis when software update cannot be performed

Client application version

To be used for analysis when software update cannot be performed

 

How we may use the Information

The Information collected and stored with HM may be used for the following purposes:

  1. To provide services in relation to the update of your Honda vehicle;
  2. To maintain the server systems;
  3. To analyse for development of services and products;
  4. To analyse for improvement of services and products;
  5. To provide service support to HM’s subsidiaries (“Genpo”); and
  6. To provide report to government authorities upon request.

Who we share the Information with

We will ensure the confidentiality of the Information and/or personal data collected but may provide such information to the following parties:

  1. Dah Chong Hong (Motor Service Centre) Limited – for conducting maintenance, repair and other after-sale services;
  2. HM and Genpo – for the provision of services and data storage;
  3. Third party server development and operation vendors (and their sub-processors) – for maintaining and developing the server systems;
  4. Third party external infrastructure vendors (and their sub-processors) – for maintaining the server systems and data hosting;
  5. Our legal advisors or similar professional consultants – for the purpose of supporting, providing advice and representing us in relation to claims and/or court proceedings; and
  6. Government authorities upon request or as required by law.

 

We limit how, and with who, we share the Information and/or your personal data. Each processor is limited by contracts in their ability to use the Information and/or your personal data other than to provide services for us. Each processor has an obligation to keep the Information and/or your personal data confidential and only process the personal data in compliance with the contracts.

How long will the Information be kept

We will retain the Information for 10 years from the date of this Information Collection Statement.

 

Your rights

You have the right to request access to and correction of the Information collected from your Honda vehicle and/or your personal data held by us at any time, by sending an email to our Data Protection Officer at [email protected].

Data Protection Officer of our Company

The person to whom requests for access to data or correction of data or for information regarding our Company's privacy policies and practices and kinds of data held and for any other communications hereinabove described are to be addressed is as follows: -

The Data Protection Officer

9/F, DCH Building, 20 Kai Cheung Road, Kowloon Bay, Hong Kong

Tel: 2216 8183

E-mail: [email protected]

Language

If there is any discrepancy between the Chinese and English versions, the English version shall prevail.

 

 

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