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FordPass Privacy Notice (“Notice”) for FordPass Users in the United Arab Emirates

Version: 1.0

Ford Smart Mobility UK Limited

Version date: January 2025

 

This Notice applies to the personal information Ford Smart Mobility UK Limited (“we”) collects about FordPass customers in the United Arab Emirates (“UAE”); from the vehicle(s) you connect to the app; and through your Ford Account, which you can access in the app (the “Services”).

For privacy policies relevant to other Ford products and services, please see the local Ford website and Fordconnected.com.

Personal Information We Collect

Depending on how the vehicle is equipped, the subscriptions you have and the in-vehicle privacy settings you select, we collect the following types of personal information through your use of FordPass:

Account Information: Information you provide to create an account such as contact information (including name, email address) and Vehicle Identification Number (VIN).

Connected Vehicle Information including:

  • Vehicle Location: The Vehicle’s current location which can be used to determine your vehicle’s travel direction and speed.
  • Driving Data: How the vehicle is operated and used (such as speed, use of accelerator, brakes, and seat belts).
  • Vehicle Data: Vehicle status, performance and diagnostics (including odometer, tire pressure, fuel and fluid levels, battery, door lock, warning indicators, and alerts).
  • Connected Voice Data: Voice commands/utterances when you activate the in-vehicle voice recognition system.
  • Environment Data: The weather conditions, road segment data, road surface conditions, traffic signs, and other surroundings collected when the vehicle is driven.

Mobile Device Location: Your current location combined with your device sensors can be used to determine your travel direction and speed. If you have enabled location services on your device, this data will be collected when the app is running in the foreground or background.

Route and Destination Information: Including address or point of interest search requests when you use navigation features.

Computer or Mobile Device Information: Unique device identifiers and IP address.

FordPass Usage: We collect information about your use of FordPass and how it is performing, including information such as when and for how long you use particular Services and features through cookies such as Adobe Analytics, Aptelligent, and DynaTrace. When required, we collect this information on the basis of your consent. When we process information on the basis of your consent, you can revoke your consent (where provided) at any time via the “Privacy” tile in the “Account” section of FordPass app. For additional information regarding cookies, please see the section headed “Cookie-like Technologies on FordPass App”.

How We Use Personal Information

We use the personal information we collect about you through FordPass and from the vehicle(s) and may combine this with other information we collect to:

  • Services and Feature Delivery: To provide and deliver our products and services, allow you to control certain vehicle features, benefit from any Services, and to fulfil your requests.
  • Customer Support: To provide support and answer enquiries.
  • Quality and Improvement: To verify that a feature or Service meets its intended purpose including prognostics; to assess and improve the quality of the Services provided to you by us, our distributors, and our suppliers; and to diagnose or repair technical errors that impair existing or intended functionality. We use this information to understand and enhance the customer experience.
  • Research and Development: To conduct internal research to evaluate the quality of and improve our products, services, processes, and technologies; or to conduct internal research to develop new products, services, processes, and technologies.
  • Recommendations and Personalization: With your consent, we may analyse, learn from, and use information about your vehicle and how it is used, including driving data (such as speed and braking) and vehicle location, to make recommendations and deliver personalized experiences centered around you.
  • Security, Integrity, Safety, Legal, and Compliance: To comply with our legal and regulatory responsibilities; to respond to legal process or requests for information issued by government authorities or other third parties; to prevent, detect, protect against, investigate, prosecute those responsible for, or otherwise respond to a security incident, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; to investigate, establish, exercise, prepare for, or defend a pending or anticipated investigation or legal claim; to cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws or regulations, where permitted by law; and in the event of exigent circumstances, to help prevent the loss of life or serious injury or to protect the personal safety of individuals; and to protect the rights or property of others.
  • Business Operations: To manage and improve our business operations and our relationship with you; to operate our business and perform business functions, including accounting, finance, tax, regulatory compliance, litigation, information security, fraud detection and prevention activities; to preserve the integrity or security of our systems or vehicle systems; to protect our rights and property; to manage our supplier and vendor relationships, including to evaluate the quality of the products and services that our suppliers provide to us or on our behalf; to manage human resources and information technology; to improve our internal operations; and to facilitate a corporate transaction, such as a merger or acquisition, where permitted by law.

How We Share Personal Information

We may share personal information obtained through FordPass and from the vehicle(s) you connect to it:

  • With our Authorised Distributors and our Affiliates: We may disclose Vehicle Data to our authorised distributors so they may more conveniently assist in the diagnosis and repair of the vehicle.
  • Vendors, Suppliers, and Agents: We disclose personal information to companies or other organisations that we have engaged to provide services on our behalf, such as hosting and information technology providers.
  • Professional Advisors: We disclose personal information to help us operate our business and provide our Services, including to obtain audit, legal, or other professional advice.
  • Law Enforcement Agencies, Courts, Regulators, Government Authorities, or Other Third Parties: We will disclose personal information when we believe this is necessary to comply with a legal or regulatory obligation; protect our rights, the rights of any third party or individuals' personal safety; detect, prevent, or otherwise address fraud, security, or safety issues; operate and maintain the security of our Services, including to detect, investigate, prevent, stop, or remediate an attack on our computer systems or networks; or protect the rights or property of ourselves, our affiliates, or others, including by enforcing our agreements, terms, and policies.
  • Parties to Corporate Transactions: We may also disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets.

Google: FordPass uses Google Maps services and Google Application Programming Interfaces (APIs) to provide essential functionality for FordPass features with maps, address information, and searches for places or points of interest, including features like FordPass Location (to help locate a vehicle in your FordPass garage). ​

When enabled, Google will use cookies and other tracking technologies, and the following data will be shared with Google for their purposes described in their privacy policy (below).

  • Precise location – depending on the FordPass feature or the functionality being used, this could be the precise location of a vehicle, your mobile device, or another place or point of interest you search for. Your location information will only be shared with Google in the foreground.​
  • Identifiers (such as device IP address, a unique Maps Software Development Kit (SDK) identifier, a generic FordPass App identifier)​.
  • Technical device information (such as device type, operating system version number, SDK version number, screen size, and color theme).
  • Maps performance and interaction events data (such as panning, zooming, and abnormal termination/crash metrics).
  • Your search queries.​

Google uses cookies and the personal information it collects through use of the Google Maps services and Google APIs: to provide the Google Maps services and other services supported by the Google APIs; to troubleshoot and provide technical support; to maintain Google Maps platform security and capacity; to improve Google Maps and other Google APIs, products, and services; and for their other purposes described in Google’s Privacy Policy.

You have the opportunity to provide consent before using a FordPass feature that includes the Google Maps services or Google APIs. You can withdraw your consent at any time in your Privacy Settings, located under the “Account” tab. If you decline, you will not be able to use Google Maps in the FordPass features that rely on it for functionality.

Where Personal Information is Stored and Transferred

Your personal information is stored locally on your mobile device, and on servers operated by us and our service providers. Your personal information will be treated in accordance with UAE data protection law and may be transferred within the UAE, as well as to countries outside the UAE (including to the UK, the USA, South Africa, and our Affiliates).

How Long We Keep Personal Information

We only keep your personal information in identifiable form for as long as is necessary for the purposes set out in this Notice. This generally means holding the personal information for as long as one of the following apply:

  • your personal information is reasonably required in order to provide the Services to you;
  • your personal information is reasonably required in order to satisfy the purpose for which you submitted or we collected the personal information;
  • your personal information is reasonably required in order to protect and defend our rights or property (this will generally be the length of the relevant limitation period in your jurisdiction); or
  • we are otherwise required to keep your personal information by applicable laws or regulations.

Cookie-like Technologies on FordPass App

What are cookie-like technologies?

Cookie-like technologies, including software development kits, are widely used in order to make apps operate more efficiently. These technologies are used in the app for the following purposes:

  • Strictly necessary: These technologies are required for the basic app functionality and to provide the Services.
  • Performance: These technologies allow us to improve our app functionality and conduct market research by tracking usage. We use Adobe Analytics to create pseudonymous profiles about how the app is used. You may object to the creation of such pseudonymous profiles. We also use Aptelligent to collect technical information from your device when the app crashes in order to understand what went wrong.
  • Guides purposes (Help): If you contact a Ford Guide, we may use these technologies with your permission to enable the Ford Guides to see your recent use of the app. This makes it easier for them to help you.

Your Choices, Rights, and How to Contact Us

Your Choices

You can:

  • update and manage your location preferences at any time via the ‘Privacy’ tile in your ‘Account’.
  • choose not to provide certain personal information, but this may limit or prevent use of certain Services (for example, if you stop sharing vehicle data, you will be unable to use remote lock and unlock).
  • stop data being shared between the vehicle and FordPass or permanently disconnect a vehicle from FordPass (such as when you sell the vehicle). For more information, see the in-vehicle Connectivity Settings and the FordPass FAQs. If you disconnect a vehicle from FordPass, or stop data being shared between the vehicle and FordPass using the in-vehicle controls, you may not be able to use some Services. Please remember to unsubscribe from FordPass and disconnect your vehicle from FordPass before you sell your vehicle.

If you let others drive the vehicle(s) you connect to the FordPass app, please tell them about how you use FordPass, how to prevent the sharing of data between FordPass and the vehicle(s) connected to it, and explain that a copy of this Notice is available on your local Ford website or at Fordconnected.com.

Your Rights

You have the right as an individual to find out what personal information we hold about you, for what purposes and other details about the processing, as well as to make corrections if necessary. You also have the right in some circumstances to object to our continuing to process your personal information, or to ask us to delete or restrict the use of your personal information. In some circumstances you can also request that your personal information is provided to you in a commonly used electronic format so that you or we can share it with other organisations (this is often referred to as the right to 'data portability'). Where we rely on consent to process your personal information, you may withdraw your consent at any time.

We encourage you to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate.

Contact Us

If you are unhappy about how we use your personal information, we hope that you will let us know so that we are able to address your concerns. However, you are also entitled to lodge a complaint with the UAE Data Office.

If you have questions or concerns regarding our use of your information, or would like to exercise any of your rights, you can call a FordPass Guide or write to:

Ford Middle East Customer Relationship Center

P.O. Box 21470 Dubai, United Arab Emirates

menacac@ford.com

Security of Personal Information

We use appropriate technical and organisational measures to implement the necessary standards to protect and secure personal information in order to preserve confidentiality and privacy, and to safeguard against breach, destruction, alteration, or tampering, taking into account the nature, scope, and purposes of processing and the possibility of risks to the confidentiality and privacy of the personal information.

Other Websites

FordPass may contain links to other apps or websites which are outside our control and are not covered by this Notice. If you access other websites using the links provided, the operators of those websites may collect information from you which will be used by them in accordance with their privacy policies, which may differ from ours.

Privacy Notice Effective Date and Revisions

This Notice may be updated in order to reflect any changes to FordPass, our privacy practices and use of your information, or applicable law.

If we change this Notice, we will notify you of the changes, when required by applicable law.