COLLECTION OF INFORMATION
- your name
- your home and/or office address
- your mobile phone number
- your email address
- your charging station network access card number(s) (or other payment method, if applicable) and the expiration date for charging station network access
Upon successful completion of the registration process, you will be issued a DRIVEtheARC Connected Car Services User ID and password (for EV Co-Driver, your email address will serve as your User ID). This User ID and password will be associated with the Personal Information that you have provided so you should keep them in a safe and secure location and not disclose them to others.
Information collected through access or use of the Services. In addition to Personal Information you provide during the registration process, your access or use of the Services will result in our collection of additional Information about you, your mobile device or computer, your driving habits, or your vehicle in four main ways: (i) Information provided by you through the DRIVEtheARC Apps by manual input or voice command (“User Input Information”), (ii) Information automatically collected from charging stations to which you have been navigated by use of the Services (“Charging Station Information”), and (iii) Information automatically collected by the DRIVEtheARC Apps from your mobile device or computer such as its GPS systems (“Mobile Device/Application Use Information”), and (iv) Information automatically collected from your vehicle’s telematics’ system (“Telematics Information”). Information collected as described above will be transmitted to, used and stored by Kanematsu and/or third parties engaged by Kanematsu to assist in the development, delivery or support of the Services.
Information collected as described above includes Information such as:
User Input Information:
- self-reported battery state-of-charge (SOC) data regarding your vehicle
- feedback, comments, messages, queries or other content
Charging Station Information:
- DRIVEtheARC Connected Car Services User ID
- charging station service card number (or other payment method, if applicable) and the expiration date for charging station network access
- charging station location
- charger unit number or identifier at charging station
- charging start and end times
- charged power measurement
Mobile Device/Application Use Information:
- mobile device identifier (such as IP address or other unique identifier) and other technical and usage information about your mobile device and computer
- locations of charging stations visited during use of the Services
- charging start and stop times
- system information
- other data regarding your use of the Services
- battery state-of-charge (SOC) (obtained through vehicle manufacturer or third party APIs or other connectivity between your vehicle and either or both of the Apps)
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Cookies; Tracking. The DRIVEtheARC Apps may use “cookies” or similar technologies to help us operate the Services and collect certain Information and data about your use of the Services and your mobile device or computer. “Cookies” are small data files stored on your mobile device or computer. A cookie may include an anonymous unique identifier that is sent from a server used to operate the Services to your mobile device or computer. Each time you use the Services, a cookie will transmit information to us or our third party service providers to identify the mobile device or computer you are using. The information transmitted by cookies may enable us to facilitate your signing on to the Services, track your preferences when using the Services, provide you with customized content, provide us with data for analytical or research purposes, assist in the identification of fraudulent or unlawful activities, or for other purposes described in the “Use of Information” section below.
Cookies may often be disabled through the settings in your mobile device or your computer’s browser settings. If you disable cookies used by the Services, you may not be able to use some or all of the Services.
De-Identified Personal Information: Personal Information does not include your Personal Information that has been de-identified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable (collectively, “De-identified Personal Information”), meaning that the data can no longer be attributed to a specific individual by reasonable means without the use of additional information, provided such additional information (if in our possession or control) is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual.
USE OF INFORMATION
We may use your Information for the following purposes:
- to manage your User Account
- to send you information regarding the Services or our other products or services
- to enable us to operate and provide the Services
- to monitor and improve the performance of the Services
- to provide updates of the DRIVEtheARC Apps
- to provide customer service and respond to queries
- to conduct surveys and questionnaires
- to take any action in the event of a dispute or legal proceeding between us
- to comply with applicable law and legal process or respond to requests from law enforcement or governmental authorities
- to investigate or prevent fraud or other unlawful activities or misuse of the Services
- for inclusion in our data analytics
- for statistical or research purposes
- to prepare and include in reports to our business partners
- for internal business purposes
- to share with third parties subject to the “Sharing Information with Third Parties” section below.
SHARING INFORMATION WITH THIRD PARTIES
We will not sell, lease or rent your Personal Information to third parties.
We may use or share with third parties your Personal Information or Usage Information which is, or has been transformed into, aggregated, non-personal, anonymized or de-identified information in order to optimize the Services, for operational or research purposes, or where legally required or permissible.
Additionally, we may share Information with third parties as follows:
Service Providers. We may share Information with third party service providers that we have engaged to help facilitate or improve our provision of the Services, such as third parties engaged in the provision or operation of communications and hosting, wireless connectivity, network security, data analysis and storage, mapping and related services, charging stations, software development, technical and customer support, payment processing, marketing and other functions. If Information is provided to such service providers, they may only use it to fulfill their responsibilities in connection with the Services and they must abide by our data privacy requirements.
Business Partners. We may share Information with other business partners we work with in the development or provision of the Services and parties that have helped to fund or subsidize the Services. If Information is provided to such business partners, they may only use it to help us improve the Services, for administrative, statistical or research purposes, or to confirm that we have complied with our obligations to them. These business partners must also abide by our data privacy requirements.
Other Users. The Services may include functionality to allow you to post comments, feedback, messages or other content via “chat” directly with other users or on blogs, bulletin boards or by other means. Such content will be accessible by other users of the Services or the public at large.
Legal Authorities or Proceedings. We may share Information with law enforcement officials, governmental agencies or other legal authorities when permitted or required by law or legal process or to respond to requests from law enforcement, government agencies or other legal authorities. We may also share Information with third parties in connection with legal proceedings in order to establish, protect, exercise or defend our reputation, rights or property.
Successors. If we sell or otherwise transfer part or all of our business or assets to another company or organization, such as in the course of an acquisition, merger, corporate reorganization, bankruptcy or liquidation, Information may be sold, transferred or otherwise shared as part of the transaction or proceedings.
ACCESSING AND REVISING PERSONAL INFORMATION
Upon request sent to us by email at email@example.com for issues related to the DRIVEtheARC app and the DRIVEtheARC EV Co-Driver app, we will permit you to access, make changes or updates to, or delete your Personal Information. You may also have the ability to access and revise certain Personal Information in your User Account through the DRIVEtheARC Apps (such revisions shall also be considered requests from you). Your right to access, make changes or updates to, or delete Personal Information is subject to our verification of your identity and applicable law. Notwithstanding any requests to change or delete Personal Information, we may need to retain Personal Information for purposes of recordkeeping, back-up, legal compliance or the provision of Services sought prior to the request. Revisions or deletions of your Personal Information may impair or prevent you from obtaining the Services in whole or part.
We will implement reasonable security measures to protect Personal Information from unauthorized access by physical or electronic intrusion. Unfortunately, no data transmission or storage method is 100% secure. Therefore, while we strive to protect your Personal Information, we cannot ensure or warrant its security and we are not responsible for any damages or liabilities relating to any loss, misuse, theft, interception, or alteration of any Personal Information.
When you transmit Personal Information to register your User Account, we encrypt that information in transit using secure socket layer technology (SSL).
Messages, feedback, comments, queries or other content you provide or publish through the Services and emails you send us are not encrypted and may not be secure. You should not provide or publish any of your Personal Information or other sensitive or confidential information through such means of communication.
CALIFORNIA PRIVACY RIGHTS
Residents of California have additional rights. Click here to learn more.
EMAIL MESSAGE OPT-OUT
We may periodically send you emails regarding the Services or new products or services we may offer. If you prefer not to receive these periodic email messages, you may opt-out by following the instructions in the email.
The Services are not directed to minors and persons under the age of 18 are not allowed to register User Accounts. We do not knowingly collect personal information from anyone under the age of 18 (including children under the age of 13). If you are the parent or guardian of a minor under the age of 18 and believe personal information regarding the minor has been disclosed to us, please contact us at firstname.lastname@example.org. If we discover that we have collected personal information from a person under the age of 18, we will delete it as soon as reasonably practicable.
Effective May 29, 2020
CALIFORNIA PRIVACY RIGHTS
Summary of Information We Collect
|Identifiers||Names, email addresses, mailing addresses, unique personal identifier (e.g., customer or account name or number), Internet Protocol address|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Names, addresses, telephone numbers, credit card numbers, debit card numbers. Note: Some personal information here may overlap with other categories.|
|Commercial information||Records of goods or services purchased or obtained or other purchasing or consuming histories or tendencies (such as vehicle make, model, and year, vehicle ID, license plate number)|
|Geolocation data||Physical location|
|Inferences drawn from other Personal Information||Profile reflecting a person’s driving behavior and preferences|
Personal information does not include:
- Publicly available information from government records;
- De-identified or aggregated consumer information; or,
- Information excluded from the scope of the CCPA, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and,
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Use of Personal Information
Sharing Personal Information
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Identifiers and Geolocation data.
Consumers who are California residents have certain rights under the CCPA. In particular, you have the right to request that we:
- Disclose to you the categories of Personal Information we have collected or disclosed about you in the preceding 12 months; the categories of sources of such information; the business or commercial purpose for collecting or selling (if we engage in that activity in the future) your Personal Information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of the specific pieces of Personal Information we hold about you (also called a data portability request).
- Delete Personal Information we have about you, subject to certain exceptions permitted by law.
- If we, in the future, engage in the sale of your Personal Information, you may request that we cease such activity.
To exercise the rights above, please submit a verifiable consumer request to us by either sending us an email to email@example.com or mailing us at the following address: Kanematsu USA Inc., 2154 Paragon Drive, San Jose, CA 95131, Attn.: General Manager.
We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. Government identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You may only make such a request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not discriminate against you for exercising any of your CCPA rights.
CALIFORNIA MINOR CONTENT REMOVAL
If you are a resident of California, under 18 and a registered user of our services, you may ask us to remove content or information that you have posted to these services by contacting us. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
CALIFORNIA DO NOT TRACK DISCLOSURE
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.
Effective as of May 29, 2020