Audi on demand Privacy Policy (translation) 


Audi on demand is a service organized by Audi Japan KK (“we,” “us,” or “our”)  and operated by HERS Inc. (the “Operator”). We are highly aware of the necessity and importance of protecting your personal information, and we hereby provide this privacy policy (this “Privacy Policy”) as follows, in order to collect, use and/or share your information in compliance with the various laws, regulations and codes relating to personal information protection. Any matter not set forth in this Privacy Policy shall be handled in accordance with our “Regarding Use, etc. of Personal Information” (https://www.audi.co.jp/jp/web/ja/privacy.html).

For a full description of the services and features available through Audi on demand, please visit https://www.jp.audiondemand.com (the “Web Portal”).



How We Obtain Your Consent

By starting to use Audi on demand by checking the box next to “I have read and consent to the document below” of the Terms and Conditions and submitting personal information to Audi on demand through using the Web Portal or the Audi on demand mobile website, you shall be deemed to have given your consent to our collection, use and provision of your personal information in accordance with the terms and conditions of this Privacy Policy.


Information We Collect

 

Information About You
We (or our contractors) receive and collect the following information from you, online or in person:


- Name;
- Date-of-birth;
- Street address;
- Email address;
- Mobile phone number;
- Credit card information; and
- Driver´s license number and information

Unique Number Identifiers, Device Information, and Geolocation

We automatically collect the following identifiers information from your mobile device, from the Audi on demand hardware installed on the vehicle, or from your computer’s Internet browser:

- Vehicle Identification Number (VIN);
- Authorization tokens;
- Mobile device identifiers;
- Geolocation, including both GPS and network-based geolocation;
- Log-in information;
- Bluetooth pairing information for your mobile device, including device identifiers;
- Unique number identifiers contained in browser or Flash cookies;
- IP address;
- Information collected from web beacons, including data stored in cookies;
- The last page you visited before coming to the Web Portal and other browser related information;
- Language settings and device information;
- Data related to your usage of the Audi on demand system; and
- Other unique number identifiers;

Vehicle Operations and Usage Data
When you use Audi on demand, various categories of information will be stored within the Audi vehicle and may be automatically transmitted during or after your use of the vehicle. This data includes the operational status of the Audi vehicle, including the engine, mirrors, brakes, temperature, fluids, vehicle speed, transmission, fuel level, battery, inspection information, key access, steering wheel, headlights, whether doors or hood are opened, and other data points related to the access, status, location, and operation of the vehicle. Some of such information may be transmitted while the vehicle is being operated, while other information becomes available to us once vehicles are returned.



Purposes of Our Use of Information and How We Use and Share Information

We use the information we collect to manage the number of our vehicle fleets in operation or in stock, provide the full range of Audi on demand services, and find missing or stolen vehicles. We may de-identify and aggregate certain records so that the information no longer reasonably identifies you or the Audi vehicle you used, for purposes of research and product development.

Audi on demand uses all information, including personal information we obtain from you, for the purpose of providing certain Audi on demand services, processing payments, improving our services, managing the number of the Operator’s fleets in operation or in stock, performing other Audi on demand functions, and for marketing other Audi services of ours and products (including vehicles) to you. In addition, Audi on demand shares such information with us, our affiliates and our business partners for the purposes specified above.

We may share and jointly utilize any and all information we obtain from you with our affiliates and those listed below for the limited purposes specified above and below. In addition, when we share and jointly utilize information, all information we obtain from you may be provided to joint users, located overseas:

(a) Items of Personal Information
Any and all reservation related data provided in “Information About You,” “Unique Number Identifiers, Device Information and Geolocation” and “Vehicle Operations and Usage Data” under the title of “Information We Collect” above, as well as any and all  information related to vehicles including geolocation, pick-up location, drop-off location, and reservation period;  



(b) Purpose of Sharing and Joint Utilization
― Purposes listed above;
― Provision of information and proposals customized for individual customers from our automobile sector to the customers, such as service information, product information, news (e.g. location of a new outlet of the Audi Mobility Services), promotion information, complimentary services, customer satisfaction survey, customer support and others; and
― Provision and delivery of automobile–related services of Audi AG, Audi Business Innovation GmbH and cooperating companies.



(c) Scope of Sharing and Joint Utilization
― Audi AG (Federal Republic of Germany)
― Audi Business Innovation GmbH (Federal Republic of Germany)
― Audi authorized dealers in Japan
    (For further details, please refer to the web page related to handling of personal information in our website.)
ー Volkswagen Group Japan KK
ー Volkswagen Financial Services Japan Ltd.
― NIPPON TRAVEL AGENCY CO., LTD. (In case customer use Audi on demand travel concierge.)
ー The Operator (HERS Inc.)

 

(d) Business operator responsible for management of Personal Data

    Us


We may share information about your use of Audi on demand if:
― Requested by any judicial or administrative organ, etc., under the laws and regulations;
― Required by laws or regulations;
― Provision of such information is necessary to protect the life, limb or property of a person, and it is difficult to obtain the consent from you; or
― We obtain your consent thereto.

We may share information about your use of Audi on demand with a successor to all or part of our business in accordance with the succession of all or part of our business.

We will only retain your information as long as the retention is required for (i) the purposes for which your information was collected and (ii) for legal and business purposes. Generally, we do not retain your information after the original purp

oses for which your information was collected are reasonably considered to have been fulfilled, unless otherwise required by the laws and regulations.


Voluntariness of Provision of Your Personal Information and Consequences in a Case Where You Decline to Provide Your Personal Information

 

Although providing your personal information to us is on your voluntary basis, please note that we may not be able to provide Audi on demand services and respond to your inquiries properly if you did not provide your personal information to us.

 

Our Commitment to Data Security

We use reasonable safeguards to prevent unauthorized access or divulgence of, to maintain the accuracy of, and to use efforts to make appropriate use of your personal information. Data security threats are many and evolving, however, and we cannot guarantee the security and accuracy of your personal information.

Your personal information may be transferred and stored outside of Japan in our secure system or a third party system under contract with us or an affiliate. Where your personal information is transferred and stored in a country or territory outside Japan, we will take appropriate steps to cause the overseas business operators to whom we transfer your personal information to protect such information in accordance with a standard of protection which is at least comparable to the standard under the laws of Japan. You shall give your consent to such transfer by submitting personal information to Audi on demand through using the Web Portal or the Audi on demand mobile website.



No Use of Audi on demand by Children

We take children's privacy seriously. We do not knowingly collect personal information from children. If you, as a user of Audi on demand, are under 13 years of age, please do not submit any personal information through Audi on demand without the express consent and participation of your parent or guardian.  Should we obtain any information from users of Audi on demand under 13 years of age for any reason, we will take necessary measures to delete such information.



Third Party Links

Our Web Portal or mobile website may contain links to third-party websites and services that are beyond our control. We are not responsible for the security or privacy of any information collected by these websites or other services operated by third parties. We encourage you to confirm the privacy policies of such third party websites or service providers.



Open-Source Licenses

Audi on demand incorporates the following open-source software or resources:

Library URL license

Nginx
URL: http://nginx.org
License: http://nginx.org/LICENSE

Laravel
URL: http://laravel.com
License: http://opensource.org/licenses/MIT

jQuery
URL: https://jquery.org
License: http://opensource.org/licenses/MIT

AngularJs
URL: https://angularjs.org
License: http://opensource.org/licenses/MIT

Twitter Bootstrap
URL: http://getbootstrap.com
License: http://opensource.org/licenses/MIT



Changes to this Privacy Policy

From time to time, we may change and/or update this Privacy Policy. We will notify you of any material changes by updating the Privacy Policy available on the Web Portal. We encourage you to periodically check this Privacy Policy. You shall be deemed to have consented to such changes by continuing to use Audi on demand.


Notice on Direct Marketing

We may use your information to send you marketing-related information such as emails containing news, offers and/or promotions on Audi vehicles and joint marketing offers about related services such as travel insurance, automobile insurance, accident & health insurance.

We may also provide your personal information to third parties including our marketing partners, financial service partners, etc. for the purpose of marketing their products and services to you.

We will use your personal information for the purpose of direct marketing set forth above after we have obtained your consent.


Withdrawal of Consent

You may withdraw your consent for the collection, use and provision of your personal information at any time by giving us notice. You may withdraw your consent by:

1. Following the opt-out instructions contained in the communications; or
2. Calling to us at the following. Please note that we may charge postage (actual cost) and a handling fee of 1,000 JPY (consumption tax excluded) per request for answering to your request: 

Audi on demand Personal Information Protection Contact
Telephone: 0120-929367

Upon receiving your written request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to collect, use and provide your personal information, unless otherwise permitted or required by the laws or regulations.

Please note that if you withdraw your consent to any or all use or provision of your personal information, we may not be able to offer or provide to you our products or services or maintain our contractual relationship with you.


Contact Information for Questions or for Updating or Correcting Your Personal Information

Keeping your personal information accurate and up-to-date is very important. You, as a member of Audi on demand, may confirm your personal information, obtain information about our provision of your personal information or update or delete your personal information, by logging in and accessing the “Customer Center” section by yourself. If you cannot change your information online, or if you prefer to request changes offline, please use the means set forth in the “Contact Us” section or call or write to us using the contact information listed on the Web Portal. We will correct or update your personal information as soon as reasonably practicable. Before such correction or update, we may ask you to verify your identity. In addition, we may refuse any unreasonable request or any request with respect to which we are not legally required to make any disclosure.


You may obtain information regarding your personal information that is in our possession or under our control or in possession of a business operator entrusted by us or under its control, or is in possession of our consignor, as well as information about the ways in which your personal information has been or may have been provided by us within the one (1) year period before the date of your request.

 

The contact information for our personal information protection officer is as follows:

Audi on demand Personal Information Protection Contact
E-mail: contact@jp.audiondemand.com

Telephone: 0120-929367

 

Precedence

 

In the event of any inconsistency between the English version and the Japanese version of this Privacy Policy, the Japanese version shall prevail.

 

Established: [19/03/2019]

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