PRIVACY STATEMENT

Connected Vehicle Services
Privacy Statement, Last Updated: Sept. 9, 2021


INTRODUCTION


Mitsubishi Motors North America ("MMNA" or "we") provides those who purchase certain models of Mitsubishi vehicles the ability to receive Connected Vehicle Services ("CV Services") via:

The telematics device on your vehicle (the "Device"), which can record information about how you drive, vehicle maintenance data, and your location via GPS;

  • The online MMNA Connected Vehicle Services website for customers (the "Owner Portal");
  • The My MITSUBISHI CONNECT mobile application (the "Mobile App");
  • The MMNA Connected Vehicle Services customer care center at (888) 564-1411 ("Customer Care"); and
  • Dealership records provided to MMNA in connection with the CV Services.

This Privacy Statement explains how personal information about you is collected, used, and disclosed by MMNA with respect to the CV Services. This Privacy Statement does not apply to vehicles, products, mobile applications, or services that are unrelated to the CV Services as listed above. This Privacy Statement supplements our General Privacy Notice, which is available at https://www.mitsubishicars.com/privacy. To obtain an accessible copy of this Privacy Statement please contact us via the methods identified in the "Contact Us" section below.

For more information about the types of Services or Subscription Packages that are offered in connection with the CV Services, please review the MMNA Connected Vehicle Services website. Terms that are used but not defined in this Privacy Statement are defined in the MMNA Connected Vehicle Services Terms and Conditions, available at https://www.mitsubishicars.com/cvsterms. The terms "Location Services", "Parental Control Services", "Remote Services", "Safeguard Services", "Services", "Vehicle Data", and "Vehicle Data Collection" are defined in the Connected Vehicle Services Terms and Conditions.

DEFAULT VEHICLE DATA (AS DEFINED IN THE TERMS AND CONDITIONS, WHICH INCLUDES YOUR GEOLOCATION INFORMATION, ODOMETER VALUE, VEHICLE ERRORS AND OTHER VEHICLE-RELATED DATA) WILL BE COLLECTED, USED, DISCLOSED AND SHARED BY MMNA IN ACCORDANCE WITH THIS PRIVACY STATEMENT, THE CONNECTED VEHICLE SERVICES TERMS AND CONDITIONS, AND U.S. LAWS, RULES AND REGULATIONS, INCLUDING FOR MARKETING PURPOSES TO OFFER PRODUCTS AND OTHER SERVICES TO YOU. THIS DATA MAY START BEING COLLECTED IMMEDIATELY UPON YOUR PURCHASE OR LEASE OF YOUR VEHICLE FROM THE DEALER. YOU WERE NOTIFIED OF AND CONSENTED TO THIS COLLECTION, USE, DISCLOSURE AND SHARING AT YOUR TIME OF VEHICLE PURCHASE OR LEASE. THIS DATA MAY BE COLLECTED FROM YOUR VEHICLE, EVEN IF YOU DO NOT ACTIVATE THE SERVICES OR PURCHASE A SUBSCRIPTION SERVICES PACKAGE OR IF YOUR SUBSCRIPTION, TRIAL OR RENEWAL PERIOD HAS EXPIRED.

IF YOU DO NOT WANT THIS DATA TO BE COLLECTED, CONTACT CUSTOMER CARE TO DEACTIVATE YOUR VEHICLE'S TELEMATICS-ENABLING DEVICE AND REQUEST THAT THIS VEHICLE DATA COLLECTION BE STOPPED. UPON DEACTIVATION OF THE DEVICE, YOU WILL NO LONGER BE ABLE TO RECEIVE ANY SERVICES, AND ANY APPLICABLE SUBSCRIPTION SERVICE PACKAGE. ANY FREE "TRIAL" SUBSCRIPTION, PURSUANT TO WHICH YOU WERE RECEIVING THE SERVICES, WILL IMMEDIATELY TERMINATE.


DATA COLLECTION

I. INFORMATION COLLECTED BY MMNA

We currently collect the categories of personal information listed in the "Categories of Personal Information We Collect" section below, and we may use the data for the purposes identified for in the "Purposes for which Categories Will Be Used" section below. For purposes of this Privacy Statement, aggregated, de-identified or anonymized information, which includes data that is related to you but does not identify you specifically, is not considered to be personal information.

Categories of Personal Information We Collect: Depending on how you use the CV Services, we collect the following personal information from you, your vehicle, and/or your devices (collectively, "Collected Data") when you use the CV Services.

CCPA Category Description CCPA Category
Identifiers

Your name, address, telephone number, and email address

  • Vehicle/Device (Safeguard Services only)
  • Owner Portal
  • Mobile App
  • Customer Care

Vehicle identification number (VIN) and license plate number

  • Vehicle/Device (Remote Services & Location Services only)
  • Owner Portal
  • Mobile App
  • Customer Care
Internet Protocol (IP) address
  • Vehicle/Device (Remote Services, Location Services & Parental Control Services only)
  • Owner Portal
  • Mobile App
  • Customer Care

Unique mobile device identifier and mobile phone number

  • Vehicle/Device (Remote Services, Location Services & Parental Control Services only)
  • Mobile App
  • Customer Care

MAC address and device ID number

  • Owner Portal
  • Mobile App
Categories of personal information described in the California Customer Records statute Your name, address, telephone number, email address, billing information (e.g., credit card number)
  • Vehicle/Device (Safeguard Services only)
  • Owner Portal
  • Mobile App
  • Customer Care
Characteristics of protected classifications Date of birth (age)
  • Vehicle/Device (Safeguard Services only)
  • Owner Portal
  • Mobile App
  • Customer Care
Commercial information Date and time stamp of action recorded in vehicle
  • Vehicle/Device (all services)
Information about the acquisition and financing of your vehicle
  • Vehicle/Device (Safeguard Services only)
  • Owner Portal
  • Mobile App
  • Customer Care

Internet or other electronic network activity information

(This information is gathered by certain tools and methods such as log files, cookies, web beacons, and embedded scripts. For more information about how we automatically collect some of this information, please see the Tracking and Analytics section below.)

Mobile device type, mobile device operating system, type of browser, Internet service provider, screen view time, scrolling, specific actions to activate features and/or otherwise navigate the Mobile App, reactions to alerts, searches, and your interactions with in-application marketing offers
  • Vehicle/Device (Remote Services, Location Services & Parental Control Services only)
  • Mobile App
  • Customer Care
Browser type, usage transaction logs, internet service providers (ISP), referring/exit pages, operating systems, date/time stamps, your usage and activity on our Owner Portal (e.g., clickstream data), device type, log files, campaign engagement (e.g., clicking through campaign emails)
  • Owner Portal
  • Mobile App
Geolocation data Vehicle geolocation information (latitude and longitude at a particular point in time)
  • Vehicle/Device (Remote Services, Location Services & Parental Control Services only)
  • Mobile App
  • Customer Care
Vehicle direction
  • Vehicle/Device (By default and all services)
Mobile device geolocation information
  • Vehicle/Device (Remote Services, Location Services & Parental Control Services only)
  • Mobile App
  • Customer Care
Audio, electronic, visual, thermal, olfactory, or similar information Communication and other user preferences
  • Vehicle/Device (By default, Remote Services & Location Services)
    Owner Portal
  • Mobile App
  • Customer Care
Mileage (odometer information), diagnostic trouble codes, Device errors, oil status, vehicle CAN signals (signals transmitted to, from and across the various software modules contained in your vehicle)
  • Vehicle/Device (By default, Safeguard Services, Remote Services, Location Services & Parental Control Services)

Vehicle speed, air bag deployments, vehicle status information (e.g., status of powered doors), vehicle settings, anti-lock events, information from your vehicle's event data recorder, and infotainment system usage
  • Vehicle/Device (By default, Safeguard Services, Remote Services, Location Services & Parental Control Services)
Voice recordings of interactions with Customer Care and emergency personnel
  • Customer Care



Purposes for which Categories Will Be Used: We may use the Collected Data in order to:

  • provide the CV Services, the Services, and support to you;
  • monitor, measure, and report on vehicle and user engagement and CV Services usage;
  • communicate relevant messages based on pattern and usage of the CV Services;
  • inform you of various features and the CV Services, including to encourage use of certain features;
  • offer other goods and services to you;
  • solicit your feedback on the vehicle and the Services;
  • facilitate, manage, and personalize your experience online or with the CV Services;
  • operate and improve our Owner Portal and other MMNA websites, applications, marketing efforts, products and services;
  • provide information about our products and send you related information, including confirmations, brochures, technical notices, updates, security alerts and support and administrative messages;
  • notify you of the closest Mitsubishi dealer;
  • process and deliver sweepstakes, contests and promotions;
  • respond to comments, questions, or requests for information and provide customer service;
  • communicate with you about our vehicles, products, services, information, contests, promotions, rewards, special offers, upcoming events and other news about MMNA and our selected partners we think will be of interest to you;
  • monitor and analyze trends, usage and activities;
  • develop new products and services, including autonomous vehicle and car-sharing products and services;
  • administer your account(s) and process your payments for products and services;
  • provide customer and vehicle support and service (for example, recall information, servicing and maintenance or warranty service);
  • verify eligibility for vehicle purchase or incentive programs;
  • comply with legal, regulatory or contractual requirements;
  • generate analytics to improve the CV Services and the user experience;
  • link or combine with personal information we get from third parties to help understand your needs and provide you with better service;
  • send you surveys regarding your satisfaction with customer service agents and our services;
  • conduct research and analysis, including focus groups and surveys, on the Owner Portal and other MMNA websites, applications, products and services; and
  • prevent fraudulent transactions and monitor against threats.

In addition, we may share the Collected Data:

  • with third parties in connection with financing your vehicle;
  • with emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers, in order to deliver the Services (including, for example, Stolen Vehicle Assistance services, as defined in the Connected Vehicle Services Terms and Conditions);
  • with certain third parties to provide select products and services to you;
  • when you give us your consent to do so, including if we notify you on the Owner Portal or Mobile App that the information you provide will be shared in a particular manner and you provide such information;
  • with vendors, contractors, consultants, and other service providers who are working on our behalf and need access to your information to carry out their work for us;
  • to the maximum extent permitted by applicable law, to (i) comply with laws or to respond to lawful subpoenas, government inquiries, litigation, dispute resolution, requests and legal process, or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to protect our rights, security, safety and property and those of our agents, customers and others, including to enforce our agreements, policies and Terms and Conditions; (iv) to detect, investigate and prevent fraud; (v) to conduct screening to ensure you are not on any government list of restricted parties; or (vi) in an emergency to protect MMNA and the safety of our customers, employees or any third party;
  • if we believe your actions are inconsistent with our user agreements or policies, including our Terms and Conditions;
  • to the maximum extent permitted by applicable law, we may also disclose IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion;
  • with MMNA's affiliates, parents and subsidiaries;
  • with MMNA's dealer network, for vehicle servicing and for their own marketing purposes;
  • in connection with, or during negotiations of, any merger, sale of company assets (including a liquidation, realization, foreclosure or repossession), restructuring, reorganization, financing, disposal, conveyance, transfer lease, or any other type of acquisition of all or a portion of our assets or business to another company; and
  • for a purpose disclosed elsewhere in this Privacy Statement or at the time you provide your information.

As permitted by applicable law, we may use and disclose all of the personal information that we collect in order to:

  • Comply with federal, state, or local laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • Cooperate with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate federal, state, or local law;
  • Exercise or defend legal claims; and
  • Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.

Additional Data Collection and Uses: We will not collect categories of personal information other than those disclosed above without providing a new notice at collection. In addition, we will not use your personal information for any purpose other than those disclosed above. If we intend to use your personal information for a purpose that was not previously disclosed in the notice at collection, we will directly notify you of the new use and obtain consent from you to use it for the new purpose.

II. PERSONAL INFORMATION COLLECTION DURING LAST 12 MONTHS VIA THE CVS SERVICES

Personal Information Collected: We have collected the categories of personal information listed below during the preceding 12 months.

  • Identifiers
  • Categories of personal information described in the California Customer Records statute
  • Characteristics of protected classifications
  • Commercial information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information

Personal Information Disclosed for a Business Purpose: We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months:

  • Identifiers
  • Categories of personal information described in the California Customer Records statute
  • Characteristics of protected classifications
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation Data
  • Audio, electronic, visual, thermal, olfactory, or similar information

Categories of third parties with whom we share personal information: We have shared each category of personal information with the following categories of third parties:

Subsidiaries and affiliates

Service providers (e.g. accounts, attorneys, advisors, mailing, marketing, shipping fulfillment, payment processing, Site administration, technical support, modeling, analytics)

  • Third parties in connection with financing your vehicle
  • Emergency service providers
  • Unaffiliated third parties to provide select products and services to you
  • Governmental entities or law enforcement agencies

III. TRACKING AND ANALYTICS

1. Log Files

We collect certain information automatically and store it in log files. This information may include, without limitation, internet protocol (IP) addresses, browser types, internet service providers (ISP), referring/exit pages, operating systems, date/time stamps and clickstream data.

2. Cookies

When you visit the Owner Portal, you may be issued a "cookie", which helps track your session while online. Cookies are small data files stored on your hard drive. Among other things, cookies help to make your website visit more relevant and personalized for you. We use cookies on the Owner Portal, including both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate the Owner Portal. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

We use cookies to see which areas and features are popular and to count visits to the Owner Portal. Most browsers are initially set to accept cookies. If you would prefer, you may set your browser to refuse cookies or alert you when cookies are being sent; however, it is possible that some parts of the Owner Portal will not function properly if you do so and we may not be able to provide you with the most convenient or tailored experience.

3. Web Beacons

The Owner Portal and any communications sent by MMNA may contain electronic images (generally, single pixel ".gif" images) called "web beacons". These web beacons allow MMNA and third parties to monitor and collect certain information about the viewer of a web page, email message or other communication, such as the type of browser requesting the web beacon, the device identifier of the device the web beacon is sent to and the time the web beacon was viewed. Web beacons may be used to count unique users, visits and page views; monitor traffic and conversion patterns; personalize your experience when you visit the Owner Portal, including content you see; and determine whether or not messages were opened, links were clicked and/or notifications/offers were acted upon.

4. Embedded Scripts

An embedded script is programming code that is designed to collect information about your interactions with the Owner Portal. It is temporarily downloaded onto your computer from our web server or a third party with whom we work, is active only while you are connected to the Owner Portal, and is deleted or deactivated thereafter.

Information we automatically collect about you, such as how you interact with the Owner Portal, may be combined with your Personal Information. If we associate any such automatically-collected information with Personal Information about you, we will treat the combined information as Personal Information.

5. Do Not Track

Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, MMNA currently does not alter its practices when it receives a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track", you may wish to visit www.allaboutdnt.com.

6. Analytics Services

We use Google Analytics to provide analytics about the use of the Owner Portal, our other websites, and the Mobile App. Such third parties may be able to collect limited information about you, including through the use of cookies. We use Google Analytics to learn more about the types of users that visit the Owner Portal and the Mobile App to help improve these resources. For example, Google Analytics provides us with certain data regarding the demographics of the users. It also collects and processes statistical data about the number of people using the Owner Portal and the Mobile App in order to better understand how they find and use our services. The data collected includes data related to your device/browser, your IP address, and activities on the site or mobile app to. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout/ or downloading the Google Analytics Opt-out Browser Add-on (located at https://support.google.com/analytics/answer/181881?hl=en)

7. Choices About Cookies

We provide you with choices regarding the personal information you provide to us, and we have created ways to give you control over your information. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow cookies via the cookies consent banner or set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a "persistent" cookie and to only accept "session" cookies, but you will need to log in each time you want to enjoy the full functionality of the site.

Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the site. In addition, adjusting the cookie settings on the site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your Cookie Settings on the site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browser providers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471

To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.


HOW LONG DO WE STORE AND USE YOUR PERSONAL INFORMATION?

We will retain Collected Data as needed for legitimate business purposes in accordance with our data retention policies or for regulatory requirements. After the Collected Data is no longer needed for these purposes, we will store it in de-identified form and/or delete it.

SAFEGUARDING YOUR INFORMATION

We take reasonable measures to help protect your personal information in an effort to prevent misuse and unauthorized access, disclosure and alteration. Although MMNA uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and MMNA cannot guarantee the security of your information collected from your vehicle or through the use by you of the CV Services.

CHOICE; OPTING-OUT

1. Review and Correction of Personal Information

You may review and update any personal information that you provided to MMNA during your registration process by logging into the Owner Portal or the Mobile App.

2. Transmission of Vehicle Data

If you would prefer to not have MMNA collect any Vehicle Data (defined in the Connected Vehicle Services Terms and Conditions at https://www.mitsubishicars.com/cvsterms) from your vehicle, you will need to contact Customer Care and request that your vehicle's telematics-enabling Device be deactivated and that the Vehicle Data Collection be stopped. Upon deactivation of the Device, you will no longer be able to receive any Services, and any applicable Subscription Service Package, including any Trial Subscriptions, pursuant to which you were receiving the Services will immediately terminate.

3. Marketing Communications

From time to time, you may also receive mail, email, text message, and telephone communications from MMNA, including communications regarding product information, marketing or promotions, research, and/or other topics. To contact you, MMNA may use the information you provide to us, including email, direct (postal) mail, mobile number or other telephone phone. You may, at any time, inform us that you do not want MMNA to contact you with marketing communications using certain or all methods by (1) indicating your preference through MMNA's communication preferences page, available at https://owners.mitsubishicars.com/s/communication-preferences, (2) contacting Customer Care, (3) indicating your preference through the Owner Portal, or (4) managing your email and text alert notification preferences from within the Mobile App.

In addition, you may also opt-out of promotional email communications from MMNA by clicking on the designated link provided in the promotional email message. You may also opt-out of promotional text message communications from MMNA by texting MITSUSTOP from the mobile device that you have registered with MMNA. After opting-out, you will no longer receive marketing or promotional communications through the applicable method, but will continue to receive other messages, such as Remote Services notifications and specific information related to your use of the Services or vehicle (e.g., warranties, service reminders).

Note that deactivating your Device will not automatically opt-you out of receiving such marketing or promotional communications.

4. Service and Other Safety Notifications

Regardless of what may be said above, at the point of information collection, or your stated privacy preferences, MMNA reserves the right to contact you in the event of a service notification for your Device or vehicle (e.g., a recall notice), or to issue other notices concerning the safety of your vehicle.

5. California Rights

Please see our General Privacy Notice, which is available at https://www.mitsubishicars.com/privacy, for information about your rights under California law.


YOUR OBLIGATIONS

It is your sole responsibility to tell your vehicle occupants and users about the Services and the CV Services, how they work, what data may be collected (e.g., collection of geolocation data), how that data may be shared, and what the limitations of the Services and CV services are (e.g., they may not work in remote areas). If you choose to activate features such as curfew, boundary or speed alerts, you have the obligation to explain that remote monitoring of the vehicle will be conducted using parameters that you set. You agree to make all vehicle occupants and users aware of this Privacy Statement and the privacy choices you have made.

If you sell, lease or otherwise transfer your vehicle directly to another person, it is your responsibility to notify such subsequent owner of the CV Services, the Services (including the Vehicle Data Collection and any other collection of data), this Privacy Statement, and the Terms and Conditions. In addition, prior to such transfer, you should delete all information (such as contacts and saved map addresses stored in the vehicle) from the vehicle and contact Customer Care to cancel your account. Any information you do not delete may be accessible to future users of the vehicle. Please refer to your Owner's Manual for instructions on how to delete information from your vehicle's system.

OTHER IMPORTANT NOTICES

1. Children

The CV Services, including the Owner Portal and the Mobile App, are not intended for and are not targeted to children under the age of 13. Children under the age of 13, are not permitted to use the CV Services and should not send any information about themselves to us through the use of the CV Services. It is your sole responsibility to tell your vehicle occupants and users that the Services are not to be used by children.

We do not knowingly collect any personal information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information in accordance with the Children's Online Privacy Protection Act ("COPPA"). If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at privacy@mitsubishicars.com.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

2. Third Party Links

The Owner Portal and Mobile App may contain links to third party websites and services, including but not limited to social media sites and applications. Because of the dynamic media capabilities of these platforms, it may not be clear to you which links are to the Owner Portal and Mobile App and which are to external, third-party websites. You can check the URL to confirm that you have left the platform.

This Privacy Statement does not apply to the linked sites, and we do not control, nor are we responsible for, the content or privacy and security practices of those sites. Any personal information you provide to a linked site or service is provided directly to a third party and is subject to such third party's privacy policy. We encourage you to learn more about such third party's privacy and security practices and policies before providing any of your personal information.

3. Consent to Transfer Information

The CV Services are operated from within the United States. If you are located outside of the United States and are accessing the Owner Portal or Mobile App or otherwise using the CV Services, please be aware that information we collect will be collected and stored in the United States. By using or accessing the Owner Portal or Mobile App, using the CV Services or providing us with any information through the CV Services, you consent to this transfer, processing and storage of your information in United States.

UPDATES TO PRIVACY STATEMENT

From time to time, we may update this Privacy Statement. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. If the changes being made are material, we may provide you with additional notice. Your inaction or continued use of the Services, including access to the Owner Portal, after any such updates or notices will tell us that you agree to these changes.

CONTACT US

If you have any questions or concerns about this Privacy Statement, please contact MMNA by calling 1-888-MITSU20 (1-888-648-7820), or emailing us at privacy@mitsubishicars.com, or sending us a request at the address below:

Mitsubishi Motors North America, Inc.
Customer Relations Department
PO Box 689040,
Franklin, TN 37068