Land Rover Care MENA Mobile Application Privacy Policy
Last updated: 03 October 2023
WHAT YOU CAN EXPECT TO SEE FROM READING THIS PRIVACY POLICY
Jaguar Land Rover is one of the world’s leading producers of premium cars. Innovation and design give our customers experiences they love for life – anticipating and exceeding their needs and expectations. Quality and excellence are our hallmarks. Taking care of our customers is paramount.
We respect the privacy of every individual whose information we process. This Privacy Policy explains how we use personal data received from your use of the Land Rover Care MENA Mobile Application and use of our vehicles (referred to as ‘vehicles’ throughout this Privacy Policy), products and services, and informs you of your data protection rights.
DATA PROTECTION INFORMATION
1. DATA CONTROLLER INFORMATION: WHO WE ARE AND HOW TO CONTACT US
Who We Are: When we refer to ‘Jaguar Land Rover’ and its affiliates, subsidiaries, service providers, authorized third parties and its agents, ‘JLR’ ‘we’, ‘our’ or ‘us’ in this Privacy Policy, we refer to the data controller: Jaguar Land Rover Limited, whose registered office is at: Abbey Road, Whitley, Coventry CV3 4LF, England, and whose registered number is: 1672070.
If you want to find out more about the Jaguar Land Rover group, please have a look at the “Tell me more” box below.
Customer Relationship Centre contact details: For any queries relating to this Privacy Policy or the products and services included with it, you can contact us by email at: crcmena@jaguar.com or crcmena@landrover.com.
2. WHAT THIS PRIVACY POLICY APPLIES TO
- This Privacy Policy will apply to your use of the “Land Rover Care MENA Mobile Application” is the smartphone applications (“MENA Care App”, “Care App”, “App”) that you have downloaded from the Online Store onto your smartphone or handheld device (collectively referred to as “Device”)
Please note that this Privacy Policy does not apply to third party websites which you may access in connection with your use of the Care App or otherwise, or to services or features which you sign up to receive directly with a third party – please refer in these cases to the relevant third party’s privacy policy.
This Privacy Policy sets out the basis on which data, including any personal data we collect from you, or that you provide to us, will be processed by us, following your use of the App. Please read it carefully to understand our practices regarding data collection and your personal data and how we will treat it.
3. THE TYPES OF INFORMATION WE COLLECT
We may collect and process the following data about you and/or your vehicle(s):
- Submitted Information: Information that you provide by filling in online forms during the setup of your Care App account or during your use of Care App (including but not limited to use of any voice activated services), or submitted information which you may otherwise provide to us directly (for example, when you communicate to us via telephone or email), or that which the authorised retailer (from whom you purchased or leased the vehicle) provides on your behalf when setting up your Care App account, or otherwise in connection with, or following up on, any other communication with you. This information will depend on the nature of your actions, but may include your name, address, telephone number (including smartphone number), e-mail address, language preference, password and PINs for your App account, geo location and/or destination information you choose to sync, upload or request is checked on your behalf,, and information about your preferred authorised retailer(s).
- Additional Information:
o if you contact us, we may keep a record of that correspondence
- Device Information (including location): We may collect information about the Device you may use to download a copy of the Care App, including the operating system, make, model and version, the Care App installation unique identifier, the Device’s locale settings and country code. The Care App may also collect information about the location of your device and tokens and username for identification. The consents you provide to download the Care App include consent for use of GPS or location data for app services, including map information. You can restrict the access to, or collection of, your Device’s location by disabling the location features of your Device or by not using the features of the Device that require location information. Please note, this may have an impact on the App services that are available to you. Our Apps may offer you the choice to enable the use of your Device’s fingerprint or retina scan technology to validate your identity within the App, in such cases we will not collect your fingerprint or retina scan information, we will only receive confirmation from your Device that the validation check was successful More information on Device data, automated data collection and cookies can be found in our Cookies policy below.
- Vehicle Identification Information: Information about the vehicle(s) that you have registered to the Care App or such other vehicle that is otherwise identified to us (for example, via a retailer) as connected with you, including the Vehicle Identification Number (VIN), the make, model, model year, features, registration number, date of purchase or lease, and the authorised retailer from whom you purchased or leased the vehicle.
- Location Information: In order to provide you with the Care App Services it might be necessary for us and our service providers to make use of location data sent from your Device.
- Speech Data Log Information: The voice data and Submitted Data that is shared with our voice services providers to allow your voice commands to be responded to, may include the following: audio files, associated transcriptions and log files.
- Log Information: When you access the Care App we may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, internet service provider (ISP), clickstream data, language, viewed and exit pages and date or time stamps (“App Log Information”). We may also collect, and store information related to your usage of the Care App services.
- Security Authentication: Vehicle identification data and authentication tokens.
- Feature information: Feature specific information such as favourites, notes, media, and information you choose to submit to the App; security authentication data; localisation information such as time zone, language and country; vehicle make and brand and relevant Log Information.
- Marketing data: We may receive from you direct, or receive from retailers or other third party partners, your contact details, marketing preferences or other information, where there is appropriate notice and in compliance with applicable data protection laws. You have the right to ask us not to use your personal data for marketing purposes. Please see your data protection rights at Section 9 (Your data protection rights) below for further information on these.
- Public sources of data: We may use public sources of data, for example, to support functionality or services (e.g. to support authenticate or fraud checks), and/or to maintain the accuracy of the data we hold. For example, we may make checks from time to time with the vehicle licensing and transport authorities (e.g. Road and Transport Licensing Authority in Dubai, UAE to check our vehicle owner information remains up to date).
- Third party data: We may send data to third parties and receive data from third parties in order to provide your requested services and in the ways we explain in Section 5 below.
Please be aware, we may associate Submitted Information with the other information detailed above, and where we do so, we will treat the combined information as personal data in accordance with this Privacy Policy for as long as it is combined.
4. HOW WE USE VEHICLE DATA AND YOUR PERSONAL DATA.
We use vehicle data and personal data to manage and meet service requirements and information requests, to understand service, vehicle and App use, for internal research and development purposes, and to make our products and services as effective as possible. For more information on our processing, and the legal grounds that are relevant, please see the “Tell me more” box below.
TELL ME MORE ... The main uses of your personal data: Activities that may require the collection or handling of personal information: | The types of information we handled: | o Industry mandated/legislative requirements such as: § Maintaining features and services cyber security and safety (including through the release of software over the air updates). § Communicating or sharing vehicle originated data with applicable authorities as legally mandated. o Communication of urgent safety or product recall notice o Management of legal and regulatory requirements or legal claims, including for purposes such as: § To comply with our legal obligations or defend our legal rights. § For the prevention/detection of crime, (including where required to assist law enforcement agencies such as the Police, Public Prosecution in UAE or any other public authority or criminal investigation body, or for the safeguarding of national security). | § Submitted Information § Vehicle Identification Information § Location Information § Log Information, § Public Sources data § Third Party data. § Device Information | o Set up and operation of vehicle features and services (including through third party feature providers): Note in particular that: § Location Information will be processed as necessary for the provision of location-based features and services you have signed up to or requested. § Speech Data Log Information will be handled and shared with relevant service providers strictly for the purposes of operating speech activated features and services. o Maintenance of features and services (including through the release of software over the air updates): § Identification of failure modes, bug fixes and diagnostic and prognostic issues. § Resolution of issues, queries and complaints (including the management of warranty related issues). o Network and information security: § To maintain our platform information security and more generally to protect your information against loss or damage, theft or unauthorised access. § Authentication data is used for log-in to your accounts with us and for security when you use the Features and with the purpose of preventing unauthorised access. This is automatically communicated between our providers of security authentication and hosting services in order to verify identity and prevent unauthorised use of our services including Care App. o Service contract and subscription related communications o Records maintenance and general contract/services administration | § Submitted Information § Vehicle Identification Information § Location Information § Log Information, § Feature Information § Public Sources data § Third Party data § Security and Authentication information § ‘Remember me’ | o Responding to customer enquiries and resolving issues (pre or post-contract) § For internal operations and administrative purposes (for example, this will include troubleshooting, testing, supporting our audit requirements, investigating potential misuse and in responding to any enquiries you may make) and to support your queries. § We may record calls with you for training and quality purposes and to help resolve disputes. o Customer product/feature related communication (where those are not of a marketing or promotional nature, e.g. providing updates regarding contracted services or features) o Vehicle Health Notification (VHN): § To communicate with you regarding the status of specific health warnings in your vehicle. o Marketing and promotional communications (where those do not otherwise require consent) such as: § Post, phone, marketing or promotional communications; § Digital or social media marketing where this is not individually targeted; § Service contract and subscription renewal offers regarding your existing services; § Marketing and promotional communications related to similar products and services, except where you have opted-out from receiving such communications. o Research and Development, Data Aggregation and Data Analytics: For the purposes of: § product development and improvement; § identification of failure modes, required bug fixes, diagnostic and prognostic issues; and § evaluation of feature usage, trends and preferences. This includes the process of anonymising data for the purposes of further research/analytics/statistical purposes (including without limitation for network and information security purposes). o Enhancing your website, infotainment and overall customer experience: § To enhance and simplify your experience across Jaguar Land Rover websites, in-vehicle experiences, in-app features (for example, to detect screen size to fit the Device you are accessing the service on) and supporting your use of personalised website areas (including processing in your access and use of the ‘Customer Portal’ and in your single sign-on authentication journeys). § Pre-filling website data fields to enhance and streamline your online experience. o Verify changes to your vehicle ownership and support to unbind your Care App Account o Records maintenance and general administration: § To maintain our records, administer and maintain our services, apps. § To support your queries and any other internal operations and administrative purposes (for example, this will include troubleshooting, testing, supporting our audit requirements and in responding to any enquiries you may make, including any data protection rights you raise). We may record calls with you for training and quality purposes and to help resolve disputes. o Corporate acquisitions and disposals | § Submitted Information § Vehicle Identification Information § Marketing data, § Location information § Device information § Third Party data § Log information § Call Log Information § App Log Information § Security and Authentication data § Public Sources data | o Data aggregation, analytics and profiling: As indicated above, we will carry out research and analytics activities to inform our marketing strategies, to create a better understanding of our customers and visitors; to support our website advertising, and to better improve the website information, functionality and the services we provide. Where we use the output of those activities for profiling and tailored marketing purposes, as further described below, we will seek your consent. o Marketing and promotional communications: § We may send marketing communications to you including by electronic means (e.g. email, text, digital or social media, etc.), related to products or services that may be of interest to you. § We may also share your details with our network of independent third parties, for sending marketing communications, including by electronic means. § We may use cookies for tailored marketing purposes (please see our Cookies_Policy). o Use of Location Information for Research and Development, Data Aggregation and Data (where consent is required by law for the use of non-aggregated/specific geolocation data) Note: Where we collect your personal data with consent for any of the above purposes, you may withdraw your consent for us to use your information at any time. Please see Withdrawing your consent in Section_9 below for further details. Your right to withdraw consent does not affect the lawfulness of processing that was based on that consent before its withdrawal. | § Submitted Information § Vehicle Identification Information § Location Information § Third Party data § Marketing data |
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5. WHO WE SHARE PERSONAL DATA WITH
We may share your personal data with (and may receive information about you and your vehicle(s) from):
- Those third parties who need to handle it, including suppliers (see more information below), third party app, navigation and other Feature providers and service providers for related services (insurance, warranty), and Care App, so we can provide to you, and monitor the usage and performance of, the products and services you are eligible for, have signed up to or requested, or that are appropriate for your vehicle.
- In order to enable third party services and Features, you may be required to connect your Care App account to your applicable third party account. If you choose to connect your accounts, we may share certain Submitted Information, Vehicle Identification Information, Location Information, Journey Information, Vehicle Operation Information, Log Information and/or Feature information required by the third party service provider in order for them to provide the service or Feature you have chosen to enable. Please refer to the relevant third party’s privacy policy for information on how their services process personal data.
- For the purposes of providing the Care App to you: our roadside assistance provider, local authorities, our providers of hosting services, our provider(s) of anonymised analytics services, and our marketing services provider(s).
- Our network of retailers, authorised repairers and where relevant our importers network (together our “Retail Network”), so as to be able to fulfil requests for, and communicate to you about, goods, services, etc., and for assessment and training, to be able to enhance the quality of the services you obtain when interacting with our Retail Network.
- Jaguar Land Rover group companies in line with the data uses set out in this Privacy Policy.
- Third parties in the event we sell or buy any business or assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or requests, or to the extent disclosure is permitted by legislation or a legal exemption, (including but not limited to, disclosure for the purpose of legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights, the prevention or detection of crime, the apprehension or prosecution of offenders, or the safeguarding national security); or in order to enforce our contract terms, to investigate actual or suspected breaches, or to protect the rights, property or safety of Jaguar Land Rover or its customers.
We have safeguards in place with our service providers to ensure that your data is kept securely and used in accordance with the purposes set out in this Privacy Policy. TELL ME MORE ... … about JLRs network of Independent Third Parties ... We work with a number of independent third parties to provide services, such as our Retail Network, credit product providers and contract hire products. Personal data may be sent directly to these entities by you (for example if you contact them by phone or email or via their website pages), or we may share personal data with them where appropriate to support with your queries or other service requirements. Where you use the Jaguar Land Rover websites to find or make contact with our Retail Network, a credit provider, or a contract hire product provider, these are (unless otherwise stated), independent businesses and not Jaguar Land Rover group companies. Any contact you make to them (for example, to call or send an email) and any data you provide to them in use of their websites, will be controlled by them, not by JLR. If you have questions regarding a third party’s (such as a retailer, importer, credit provider, contract hire product provider or repairer's) use of your personal data, we recommend you contact those parties directly. For information on independent third parties we work with: For Jaguar: - Our Retail Network is generally identifiable from the ‘locate a retailer’ website functionality. They can be searched for by name, location or postcode. A full list of all authorised retailers is accessible here: https://www.jaguar.com/retailer-locator/index.html.
For Land Rover: - Our Retail Network is generally identifiable from the ‘locate a retailer’ website functionality. They can be searched for by name, location or postcode. A full list of all authorised retailers is accessible here: https://www.landrover.com/dealer-locator.html.
… about Suppliers ... We use a number of service suppliers to support our business and these service providers may have access to our systems and data in order to provide services to us and on your behalf, for example payment processors, information technology such as hosting or cloud service providers, marketing, analytics and digital advertising support services, connected car technology providers, including vehicle content support, authentication services, customer services and relationship handling, service and system specialists, administrative or support services and website analytics support. … about JAGUAR LAND ROVER Group companies, and how they may provide service support ... As a member of the Tata Group of companies, we can benefit from the large IT infrastructure and expertise that exists within our wider corporate structure. This means that the personal data you provide to us may be accessed by members of our group of companies only as necessary for service and system maintenance and support, aggregate analytics, business continuity, IT and administrative purposes. For example, where necessary to support particular website enquiries, or to provide technical support that maintains website functionality. … about Public bodies, law enforcement and regulators ... From time to time, the police, other law enforcement agencies and regulators can request personal data, for example for the purposes of preventing or detecting crime or apprehending or prosecuting offenders. |
6. INFORMATION ABOUT INTERNATIONAL DATA TRANSFERS.
The data that we collect from you will be stored in the United Kingdom (UK) and the European Economic Area (“EEA”) and/or other countries to the extent required for us or our service providers to provide the vehicle and Care App. It may be processed by personnel operating outside the UK and the EEA who work for us or for one of our service providers, including those engaged in the provision of the Care App. Where personal data is shared outside of the UK and/or the EEA, we apply safeguards to add to the data protections that apply to those data transfers. This includes an assessment of the adequacy of the third country in question, use of European Commission approved (or where applicable, UK approved) model contract terms where appropriate, and assessment of Privacy Shield certification for US located entities (where this is deemed as an adequate method of transfer).
TELL ME MORE ... … about the adequacy checks JAGUAR LAND ROVER puts in place for international data transfers … Where JAGUAR LAND ROVER chooses to share personal data with a third party located outside the EU, the following factors are assessed to support adequate transfer of this data: - Internal checks to identify the existence or absence of any applicable adequacy decision by the European Commission. We have group companies, and use suppliers located in countries that have been approved by the European Commission as having essentially equivalent data protection laws. A full list of these countries as at the date of this Privacy Policy is: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Switzerland, Japan, Jersey, New Zealand, Uruguay and the Isle of Man. (The EU-US Privacy Shield programme is described below). This list and information about the protections the European Commission has considered is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
- Use of measures like European Commission approved measures to support adequate transfers of personal data. We also have group companies, and use suppliers located in countries that are elsewhere in the world. To manage data protection compliance with these transfers, we will use European Commission or UK approved data transfer mechanisms such as use of approved model contractual clauses. We will also assess, where applicable, where a supplier is able to demonstrate to us they have Binding Corporate Rules. (Binding Corporate Rules is a GDPR – recognised Data Protection mechanism to ensure adequate personal data transfers). We may work with suppliers who are able to demonstrate to us they are Privacy Shield certified where this is deemed as an adequate method of transfer.
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7. HOW LONG WE HOLD PERSONAL DATA FOR.
We’ll keep your personal data for as long as we need it to provide the products and services you’ve signed up to. We may also keep it to comply with our legal obligations, meet service or contract commitments, respond to queries and resolve any disputes, to meet our legitimate interests and to enforce our rights.
The criteria we use to determine storage periods include the following: contractual provisions that are in force, legal statutory limitation periods, applicable regulatory requirements and industry standards.
8. KEEPING YOUR INFORMATION SECURE
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
We require all of our service providers to have appropriate measures in place to maintain the security of your information and such service providers will only be able to access and use your information for the purpose of providing the agreed services.
Where we have given you (or where you have chosen) a password that enables you to access your Care App account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone else. We do not store login credentials to third party services you have chosen to connect to, we will securely store an authorisation token only.
Unfortunately, due to the nature of the internet and telecommunications, the transmission of information via these channels is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet; any transmission is at your own risk. Your information will be kept in a secure environment protected by a combination of physical and technical measures such as encryption technologies or authentication systems to prevent any loss, misuse, alteration, disclosure, destruction, theft or unauthorised access. Where you have a vehicle with a web browser, you are advised to take care in its use and to only access websites you trust.
9. YOUR DATA PROTECTION RIGHTS.
Depending upon the laws applicable to you, you may have rights in connection with your personal data, which may include: to withdraw consent where you have given it, to be informed and have access to your personal data, to correct or complete inaccurate data, and in certain circumstances to restrict, request erasure, object to processing, for direct marketing purposes, the right to object to processing that causes harm or distress to you or others, the right to automated decision or request portability of your personal data to another organisation.
You may at any time update your personal data held by us via the Care App.
We try to ensure that we deliver the best levels of customer service. If you do need or want to get in touch with us for any reason regarding your data protection rights, please get in touch using either of the Customer Relationship email addresses below and add into the subject header that it relates to your data protection rights.
If you are not happy and have a data protection related complaint, please contact our Data Protection Officer directly at this email address: DPOffice@jaguarlandrover.com. If you are not satisfied, you also have the right to complain to a supervisory authority.
To learn more about these data protection rights, see the “Tell me more” box below.
TELL ME MORE ... … about my data subject rights ... If you have given us consent to process your personal data, including for electronic marketing communications, you have the right to withdraw that consent at any time. Just use the unsubscribe options presented, for example, these are present in the email marketing communications sent by us. - You can ask for access to the personal data we hold about you, object to the processing, request that we correct any mistakes, restrict or stop processing or delete it. If you do ask us to delete or stop processing it, we will not always be required to do so. If this is the case, we will explain why.
- In certain circumstances you can ask us to provide you with your personal data in a usable electronic format and transmit it to a third party (right to data portability). This right only applies in certain circumstances. Where it does not apply, we will explain why.
…about how I can get in touch with the UK supervisory authority… The Information Commissioner’s Office (the ICO) is the supervisory authority that regulates personal data in the UK. You can get in touch with the ICO in any of the following ways: · By going to their website: www.ico.org.uk · By giving them a call on 0303 123 1113 - or by writing to them at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF.
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10. CHANGES TO THIS POLICY
Updates to this Privacy Policy will be within the App.
11. THIRD PARTY SERVICES AND LINKS TO OTHER WEBSITES
The Care App may contain links to other websites run by other organisations which we do not control. This Privacy Policy does not apply to those other websites‚ so we encourage you to read their privacy statements. Please note that this policy also does not apply to third party services and websites more generally, including those which you may access in connection with your use of the Care App, or when you sign up to an app or services directly with a third party. Please refer in these instances to the relevant third party’s privacy policy. We are not responsible for the privacy policies and practices of other websites and apps (even if you access them using links that we provide). We provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness.
COOKIES POLICY
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. Cookies can help a website to arrange content to match your preferred interests more quickly - most major websites use cookies. Cookies alone cannot be used to identify you. A cookie will typically contain the name of the domain from which the cookie has come; the "lifetime" of the cookie; and a value, usually a randomly generated unique number.
We use two types of cookies as described in the tables below.
- Session Cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site; and
- Persistent Cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
Session Cookies are used:
- To allow you to carry information across pages of our site and avoid having to re-enter information; and
- Within registration to allow you to access stored information.
Persistent Cookies are used:
- To help us recognise you as a unique visitor (using a number, you cannot be identified personally) when you return to our website;
- To allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly; and
- To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website. We cannot identify you personally in this way.
App Analytics
We use analytics tools, including Google Analytics, on our Apps. These are used to compile anonymous, aggregated statistics that allow us to understand how our customers use our Apps and to help us improve them. This includes the logging of App crashes and failures for quality assurance purpose and App usage in the event of a vehicular issue such as a collision or stall.
This data does not identify you personally. Please see www.google.com/policies/privacy/partners for further information.
You may choose to disable Google Analytics on the Apps via your account settings.