Effective Date: January 1, 2020
Mitsubishi Motors North America, Inc.
Please note that authorized Mitsubishi dealers (“Mitsubishi dealers”) are independent entities and their processing of information is subject to their own privacy policies. For information on how a specific Mitsubishi dealer processes your information, please direct your request to the relevant Mitsubishi dealer.
For information about data practices with respect to our Connected Vehicle Services, please visit our Connected Vehicle Services Privacy Statement. If you are a California resident, please see the “Additional Disclosures for California Residents” section.
Information Collected by MMNA
Information You Provide to Us
We collect information that you voluntarily provide to us, such as when you register for an account, participate in a sweepstakes, contest, survey or other promotion (“Promotion”), request a brochure or other materials, sign up to test drive a vehicle, locate or make inquiries to a Mitsubishi Dealer, request a credit score estimate or otherwise contact MMNA. We may use service providers to collect this information.
The categories of information we collect and have collected in the last 12 months includes the following:
- Contact information, including first and last name, postal address, telephone number, mobile phone, and email address;
- Credentials, including password and information for authentication and account access;
- Demographic information, including age, ethnicity, marital status, and size of household, income;
- Profile information, including username, email address, alias, interests, and social media username/handle;
- Driver’s license information, including date of birth;
- Vehicle information, including make, model, year, condition, purchase and service dealerships, dates of ownership or lease, and vehicle identification numbers;
- Financial information, including current and estimated loan payments;
- Marketing profile information, including when you plan to purchase or lease a vehicle, the Mitsubishi vehicle you are interested in, details about your current vehicle, and your thoughts about the Mitsubishi brand.
- Content of any message you send to us, including feedback and information you provide to customer support;
- Names and email addresses of your friends and family, if you choose to provide MMNA with this information; and
- Job applicant information, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
In addition, we collect information you provide to us at auto shows, and may combine such information with information we collect about you through the Sites.
You are responsible for maintaining accuracy of the information you submit to us, if any.
Information We Collect Automatically
When you access and use our Sites, some information is automatically collected by us and our service providers. The categories of information we automatically collect and have collected in the last 12 months includes:
- Sites use information, including information about the page-by-page paths you take as you browse through the Sites, the website that referred you to us and your exiting pages, your access times, the emails and advertisements you view, and the features you use;
- Device connectivity and configuration data, including information about your device hardware, operating system, browser type and language, internet protocol (IP) address, MAC address, and AD ID (e.g., IDFA or AAID);
- Location data, including imprecise location data (e.g., location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (e.g., latitude/longitude data); and
- With your consent, driving information, including motion and wellness program activity, trip information (e.g., trip start and end date and time), miles traveled, speed acceleration, deceleration, and braking data, road surface information, location and directional information, and mobile device usage information (e.g., whether the hands-free feature was used or texts were sent during a trip).
This information is gathered by certain tools and methods such as:
We collect certain information automatically and store it in log files. This information may include, internet protocol (IP) addresses, browser types, internet service providers (ISP), referring/exit pages, operating systems, date/time stamps and clickstream data.
The Sites and any communications sent by MMNA may contain electronic images (generally, single pixel .gif images) called "web beacons" or "pixels". Web beacons are used in combination with cookies to track activity by a particular browser on a particular device. When you access a website, video, email, or advertisement that contains a web beacon, the web beacon may permit us or another party to drop or read cookies on your browser. These web beacons allow MMNA and other parties to monitor and collect certain information 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, including advertising and content you see both on and off the Sites, and determine whether or not messages were opened, links were clicked and/or notifications/offers were acted upon.
An embedded script is programming code that is designed to collect information about your interactions with the Sites. It is temporarily downloaded onto your device from our web server or another party with whom we work, is active only while you are connected to the Sites, and is deleted or deactivated thereafter.
There are a variety of tracking technologies that may be included in our apps, and these are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include another party's SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Sites, and provide you with additional functionality, such as the ability to connect our Sites with your social media account.
GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device's location, delivering or restricting relevant content and advertising based on that location, and monitoring your driving behavior with your consent.
Information We Collect From Our Partners and Other Sources
We obtain information from other sources and combine that with the information we collect directly from you. The categories of sources we collect and have collected information from, including in the last 12 months, include:
- Data brokers from which we purchase demographic data to supplement the data we collect;
- Social networks when you reference our Sites or grant permission to MMNA to access your data on one or more of these services;
- Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities; and
- Publicly-available sources such as data in the public domain
How We Use Your Information
- Operate and manage our Sites, including your account;
- Respond to comments, questions, or requests for information and provide customer service;
- Send you technical notices, confirmations, updates, security alerts and support and administrative messages;
- Prevent, monitor against, and address fraud, breach of policies or terms, and threats or harm;
- Monitor and analyze trends, usage and activities;
- Evaluate your job applications for open positions, interview applicants and extend offers of employment;
- Conduct research and analysis, including focus groups and surveys, on our Sites and other MMNA websites, applications, products and services;
- Facilitate, manage and personalize your online experience;
- Improve our Sites and other MMNA websites, applications, marketing efforts, products and services;
- Notify you of or help you find the closest Mitsubishi dealer;
- Provide you with roadside assistance at your request;
- With your consent, monitor your driving information and process, analyze, and score that information;
- Allow you some control of the vehicle through your device;
- Provide information about our products and send you related information, including brochures;
- 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;
- Process and deliver sweepstakes, contests and promotions;
- Serve advertising on our Sites and unaffiliated online services; and
- Fulfill any other business or commercial purposes at your direction or disclosed to you or with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
Sharing Your Information
- With agents, 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. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us;
- With our affiliates for their internal business and commercial purposes;
- With Mitsubishi dealers in connection with the services we provide to them. For example, we share information with Mitsubishi dealers when you request a price quote on a vehicle or trade-in appraisal, when you request a test drive for a vehicle, when you use the credit score estimator for purposes of facilitating the car buying process, and for the dealers' own marketing purposes;
- With vendors and other parties for business and commercial purposes, including analytics and advertising technology companies. Vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Advertising and Analytics Services” section below;
- With other parties in connection with facilitating your request to finance your vehicle and to publicly post information on unaffiliated online services;
- ·With partners to provide select products and services to you (including but not limited to roadside assistance, car insurance, and safe and uninterrupted electric service for electrical vehicle drivers);
- With other parties or partners to provide you with discounts, coupons, and other promotions on MMNA and other party products and services.
- To the maximum extent permitted by applicable law, to (i) comply with laws or to respond to lawful subpoenas, 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 or (iv) in an emergency to protect MMNA and the safety of our customers, employees or any person or party;
- If we believe your actions are inconsistent with our user agreements or policies;
- To the maximum extent permitted by applicable law, we may also use 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. Such disclosures may be carried out without notice to you;
- 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;
- When you give us your consent to do so, including if we notify you on the Sites that the information you provide will be shared in a particular manner and you provide such information; and
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with our affiliates or other parties for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
Certain areas of the Sites, such as leaderboard profiles through our Road Assist app, are designed to help you share information with the world. If you make information public through our Sites, other people will have access to it. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information.
We have partnered with LexisNexis Risk Solutions Inc. (“LexisNexis”) to bring you the Road Assist + app. The primary purpose of the app is to allow you to request roadside assistance for your vehicle. If you request roadside assistance, we may share information about you, including your precise location data, with other parties to provide you with the roadside assistance. We may also use the information you provide through the app to update your contact information in our database.
The Road Assist+ app integrates with the LexisNexis Telematics program. When you first register through the app, you will be enrolled in the LexisNexis Telematics program.
You will also be automatically opted in to trip recording and given the opportunity to opt in to the public leaderboard. You can opt out of trip recording or the public leaderboard at any time through your app account settings.
Trip recording collects your driving information and analyzes that information to allow you to achieve scores and badges, and level up within the app. For example, if you drive a certain number of miles within a set period of time, you may receive a badge. Once you collect enough badges, you will level up within the app. Your driver score and profile leaderboard alias name, will be publicly displayed to other registered users of the Road Assist+ app so please do not provide information or images that you would not want to be public, or make sure to opt out of the public leaderboard through your app account settings.
Your driver score, badges, and levels may qualify you to receive certain discounts, coupons, and other promotions on MMNA and other party's products and services. We may share your information with other parties in order to provide you with these promotions, and such promotions may be delivered to you by email or through the app. Additional terms may apply. If you do not want to receive promotions, please opt out of trip recording through your app account settings and unsubscribe from any promotional emails you receive. In addition, if you use trip recording, information about your driving data will be visible to all drivers on your insurance policy who are enrolled in the LexisNexis Telematics program and may be disclosed to the parents or guardians of those drivers who are minors.
When you first register through the app, you will also have the option to receive insurance quotes. If you agree to this option, you give us and LexisNexis authorization to share your information with various insurance agents, insurance companies, and related parties (“Insurance Providers”). The Insurance Providers may obtain consumer reports about you from a consumer credit reporting agency and use the information and consumer reports to determine your eligibility for insurance and provide you with quotes. Those reports may include information concerning character, general reputation, personal characteristics, mode of living and driving record. The Insurance Providers may provide your information to their vendors, suppliers and insurance carriers in order to generate price and other information relevant to insurance policies, and the Insurance Providers may use the information to contact you directly including by the phone number you provide if you select that option regarding insurance products. You can revoke your authorization for insurance quotes at any time through your app account settings. Any revocation is prospective, and you may still receive insurance quotes related to data already shared.
Sweepstakes, Contests, Promotions, and Surveys
We may offer you the opportunity to participate in Promotions that may require you to submit information. Participation in these Promotions is completely voluntary. If you choose to enter a Promotion, your information may be disclosed to other parties in connection with the administration of such Promotion, such as in connection with winner selection, prize fulfilment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. MMNA may offer opportunities to enter a Promotion or other feature that we offer jointly with another party. As a result of your participation in such feature, your information may be shared with the other party that is jointly offering the feature, which will be disclosed at the time your information is collected.
Links to Unaffiliated Websites
Advertising and Analytics Services
We serve ads on and through another party’s services, such as Facebook and Google, that are targeted to reach people, or people similar to people, who have visited our Sites or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the other party’s service or incorporating a pixel from the other party’s service on our Sites, and the other party’s service matching common factors between our data and their data.
Certain functionality on the Sites is specifically designed to permit interactions that you initiate between the Sites and unaffiliated websites or services, including social networks (“Social Features”). Examples of Social Features include to “like” or “share” our Sites’ content to other websites or services; and to otherwise connect our Sites to an unaffiliated website or service.
If you choose to use Social Features, information you post or provide access to may be publicly displayed on our Sites or by the provider of the Social Feature that you use. Similarly, if you post information on another party’s platform that references our Sites (e.g., by using a hashtag associated with MMNA in a tweet or status update), your post may be published on our Sites in accordance with the terms of the other party’s website or service. Also, both MMNA and the other party may have access to certain information about you and your use of our Sites and the unaffiliated site or service.
Your Rights and Choices
Updating Your Account Information.
If you have an account with MMNA, you may review and update certain information in that account by logging into your online account or sending an email to firstname.lastname@example.org. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
You may opt out of receiving promotional emails and SMS messages from MMNA at any time by visiting http://www.mitsubishicars.com/preferences and changing your communication preferences. To opt out of SMS messages, you can also text STOP in response to any SMS messages you receive from MMNA. In addition, you can opt out of receiving promotional emails by following the instructions in those emails. Please note that we may still send you non-promotional emails, such as emails about your account or our ongoing business relations, even if you opt out receiving promotional emails.
You may also request changes to your contact preferences by writing to:
Mitsubishi Motors North America, Inc.
Customer Relations Department
PO Box 6400
Cypress, CA 90630
Tracking Technologies Generally.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please note that disabling or removing cookies may not limit collection through other types of tracking technologies.
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 and will continue this practice unless and until the law is interpreted to require us to do so.. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
You can stop all collection of information via an app by uninstalling the app. You can also reset your device AD Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you.
You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.
Please be aware that if you disable or remove these technologies some parts of the Sites may not work and that when you revisit the Sites your ability to limit tracking technologies is subject to your browser and device settings and limitations.
Analytics Services and Interest-Based Ads.
Certain companies we work with may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com and its opt-out program for mobile apps at http://www.aboutads.info/appchoices. In addition, some companies we work with may participate in the Network Advertising Initiative (“NAI“). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members′ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices. Please be aware that such opt-outs do not affect nontargeted ads and will only apply to the specific browser or device from which you opt-out.
To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will request that the applicable technology service not serve you Matched Ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out.
We are not responsible for the effectiveness of, or compliance with, any other parties’ opt out options or programs or the accuracy of their statements regarding their programs.
Road Assist+ If you use the Road Assist+ app, you can opt out of trip recording or the public leaderboard at any time through your app account settings. You can revoke your authorization for insurance quotes at any time through your app account settings. Any revocation is prospective, and you may still receive insurance quotes related to data already shared.
We take reasonable measures to help protect your information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. 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 through our Sites.
Consent to Transfer Information
The Sites are operated in the United States. If you are located outside of the United States, and are accessing or using the Sites, please be aware that information we collect will be collected, processed, and stored in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. By using or accessing the Sites or providing us with any information through the Sites, you consent to this transfer, processing and storage of your information in United States and other jurisdictions.
Our Sites are not intended for and are not directed to children under the age of thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use the Sites and should not send any information about yourself to us through the Sites.
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 thirteen (13) has provided us with personal information without COPPA-required consent, please click here to contact us.
We do not knowingly "sell" the personal information of minors under 16 years old who are California residents without their affirmative authorization.
If you are a California resident under 18 years old and registered to use the Sites, you can ask us to remove any content or information you have posted on the Sites. To make a request, email us at the email address set out in "Contact Us" section with "California Under 18 Content Removal Request" in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
By email: email@example.com.
Mitsubishi Motors North America, Inc.
Customer Relations Department
PO Box 6400
Cypress, CA 90630
By phone: 1-888-MITSU2018 (1-888-648-7820)
Additional Disclosures for California Residents
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 ("CCPA") provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
Notice of Collection
In the past 12 months, we have collected the following categories of personal information listed in the CCPA:
- Identifiers, including name, alias, address, email address, social media username and handle, account name, IP address, and an ID number assigned to your account.
- Customer records, including driver’s license number and information such as date of birth, credit or debit card information, financial information.
- Demographic information, including age, ethnicity and marital status. This category includes pieces of personal information that also qualify as "a protected classification characteristics" under other pre–existing California or federal laws.
- Commercial information including, purchases and engagement with the Sites, vehicle information, such as make, model, year, condition, purchase and service dealerships, dates of ownership or lease, and vehicle identification numbers;
- Internet activity, including history of visiting and interacting with our Sites, browser type, and browser language.
- Geolocation data, including location enabled services such as WiFi and GPS.
- Inferences, including information about your vehicle interests, preferences, favorite features and your thoughts about the MMNA brand.
For more detail on information we collect, including the sources we receive information from, review the "Information Collection by MMNA" section. We collect and use these categories of personal information for the business purposes described in the "How We Use Your Information" section, including to provide and manage our Sites.
Right to Know and Delete
If you are a California resident, you have the rights to delete the personal information we have about you and to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
To exercise any of these rights, please submit a request through our online form available here, call our toll-free number at 1-888-MITSU2018 (1-888-648-7820), or email us at firstname.lastname@example.org. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
Please note that Mitsubishi dealers are independent entities and their processing of information is subject to their own privacy policies. If you wish to exercise any of these rights with respect to the processing of information by or on behalf of a Mitsubishi dealer, please visit your local Mitsubishi dealer location to directly submit your requests to them, and we will work with the Mitsubishi dealer to address your request to the extent required by applicable law.
Right to Opt-Out
To the extent MMNA sells your personal information as the term "sell" is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking here. You may also submit a request to opt-out emailing us at email@example.com.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
Shine the Light
Under California’s "Shine the Light" law, Cal. Civ. Code § 1798.83, California customers have the right to request and obtain, once per year, information regarding MMNA’s disclosure of personal information as defined by Shine the Light to third parties (and, in some cases, affiliates) for their own direct marketing purposes. To request a list of the categories of information MMNA has shared, and the names and addresses of such third parties and affiliates, please send your request to:
Mitsubishi Motors North America, Inc.
Customer Relations Department
PO Box 6400
Cypress, CA 90630
Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
Additional Disclosures for Nevada Residents
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at firstname.lastname@example.org.
1 Manufacturer's Suggested Retail Price. Excludes destination/handling, tax, title, license etc. Retailer price, terms and vehicle availability may vary. See your Mitsubishi retailer for details.