Information Collection Statement

INFORMATION COLLECTION STATEMENT

Reliance Motors Ltd. (the “Company”, “we”, “us” or “our”) recognises its responsibilities in relation to collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate. The Company will take all practicable steps to ensure security of the personal data and to avoid unauthorised or accidental erasure or other use.

This Information Collection Statement describes how the Company uses your information in connection with your Honda vehicle’s update of Engine Control Module (“ECM”) through Over The Air (“OTA”) or Secured Reprogramming (“SR”). Please take the time to read it carefully.

Performing an ECM update for your Honda vehicle

When you perform an ECM update for your Honda vehicle purchased from us (“Honda vehicle”) through OTA or SR, some information may be collected from your Honda vehicle as part of the update procedure. The information will be transferred to Honda Motor Co., Ltd. (“HM”)’s data centre located in Japan via a distribution server located in the United States.

Information we may collect

We may collect the following information from your Honda vehicle (the “Information”) for the purposes stated to the right of each data type below:

Data type	Purpose
Vehicle Identification Number (“VIN”)	To search for an update and record the history of the update
Engine Control Unit (“ECU”) part number	To search for an update
ECU version	To search for an update
ECU serial number	To detect part replacement
Language selected	To be used for providing change point description to customer in the customer preferred language
Update method	To record the update method (i.e. OTA or J2534 dealer rewrite)
Event type	To record the update activity timestamps (i.e. notification, download, update approval, and update start)
Mileage	To record when the update is performed
Download file size	To record data volume for cost calculation
Download retry count	To perform an analysis for cost calculation
IP address	Captured by server for security log
Timestamp	To record a timestamp
Result code	To record the update result
Error code	To record the cause when update failure happens
Diagnostic Trouble Code (“DTC”)	To be used for analysis when software update cannot perform
Warning lamp brining status	To be used for analysis when software update cannot be performed
ECU boot status	To be used for analysis when software update cannot be performed
Client application version	To be used for analysis when software update cannot be performed

How we may use the Information

The Information collected and stored with HM may be used for the following purposes:

To provide services in relation to the update of your Honda vehicle;
To maintain the server systems;
To analyse for development of services and products;
To analyse for improvement of services and products;
To provide service support to HM’s subsidiaries (“Genpo”); and
To provide report to government authorities upon request.

Who we share the Information with

We will ensure the confidentiality of the Information and/or personal data collected but may provide such information to the following parties:

Dah Chong Hong (Motor Service Centre) Limited – for conducting maintenance, repair and other after-sale services;
HM and Genpo – for the provision of services and data storage;
Third party server development and operation vendors (and their sub-processors) – for maintaining and developing the server systems;
Third party external infrastructure vendors (and their sub-processors) – for maintaining the server systems and data hosting;
Our legal advisors or similar professional consultants – for the purpose of supporting, providing advice and representing us in relation to claims and/or court proceedings; and
Government authorities upon request or as required by law.

We limit how, and with who, we share the Information and/or your personal data. Each processor is limited by contracts in their ability to use the Information and/or your personal data other than to provide services for us. Each processor has an obligation to keep the Information and/or your personal data confidential and only process the personal data in compliance with the contracts.

How long will the Information be kept

We will retain the Information for 10 years from the date of this Information Collection Statement.

Your rights

You have the right to request access to and correction of the Information collected from your Honda vehicle and/or your personal data held by us at any time, by sending an email to our Data Protection Officer at [email protected].

Data Protection Officer of our Company

The person to whom requests for access to data or correction of data or for information regarding our Company's privacy policies and practices and kinds of data held and for any other communications hereinabove described are to be addressed is as follows: -

The Data Protection Officer

9/F, DCH Building, 20 Kai Cheung Road, Kowloon Bay, Hong Kong

Tel: 2216 8183

E-mail: [email protected]

Language

If there is any discrepancy between the Chinese and English versions, the English version shall prevail.