FordPass Privacy and Cookie Policy

Version: 0.9

FordPass Privacy and Cookie Policy (“Policy”) for FordPass Users in Europe
- UK, Isle of Man, Jersey, Guernsey, Gibraltar

This Policy applies to the personal information we collect through FordPass, from the vehicle(s) you connect to the app and your Ford Account which you can access with the same login details as the app.  

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

The Ford Motor company affiliate who is responsible, as data controller, for your personal information will depend on the country where you download FordPass. See <here> for details of the relevant Ford Motor company affiliate acting as your data controller (“we”) and its contact details.

Information We Collect: 

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

·  Information you provide to create an account such as contact information (including name, email address, telephone number), photo (optional) and Vehicle Identification Number (VIN).

·  Connected Vehicle information including:

Vehicle Location: Your current location which can be used to determine your vehicle’s travel direction and speed and your charging locations used (if applicable).

Driving Data:  How the vehicle is operated and used (such as speed, use of accelerator, brakes, seat belts, etc.).

Vehicle Data:    Vehicle status, performance and diagnostics (including odometer, tyre pressure, fuel and fluid levels, battery, door lock, warning indicators, alerts etc.).

Charging Data:  How and when the battery is charged including the rate and duration (where applicable)

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.  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 active on FordPass app".

·  Ford Credit.  You may also be able to access your Ford Credit Account Manager via the app. Ford Credit will use this personal information as described in the Ford Credit privacy policy

How we use your information:

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

Purpose

Legal Basis

Provide Features and Services: To allow you to control certain vehicle features and to fulfil your requests

Performance of a Contract

Customer Support:  To provide support and answer enquiries

 

Performance of a contract

Product quality and development: To verify that a feature or service meets its intended purpose including prognostics.  To research and develop new products and services.

Legitimate Interest

Assess and improve the quality of the services provided to you by us, our dealers and our suppliers.  We use this information to understand and enhance the customer experience

Legitimate Interest

Develop marketing strategies

 

Legitimate Interest

 

Send you marketing material in line with your communications preferences.

Consent

Make recommendations and personalize your experience. 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.

Consent

Comply with our legal and regulatory responsibilities, to respond to legal process or requests for information issued by government authorities or other third parties, and to prevent and detect crime and fraud, or protect your, our or others’ rights.

Legal obligation or Legitimate interest

 

How We Share Information:

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

·  With our authorized dealers to dealer locator and our affiliates

·  We may share Vehicle Data with our authorized dealers so they may more conveniently assist in the diagnosis and repair of the vehicle. Subject to your consent, we may also share this information for the purposes of dealer marketing. 

·  With companies or other organisations that we have engaged to provide services on our behalf such as hosting and information technology providers;

·  With professional advisors;

·  With a law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues

·  With any new owner if we sell some or all of our business.

Some of the Services require us to share your personal information with the following:

·  If you choose to purchase a product or subscription from Ford Smart Mobility UK Limited (FSM) through Ford Account, we will share with them your account information (such as your VIN, name, country, email and postal address, if available).  FSM will use this data along with any additional information you provide to them to communicate with you about your order, fulfil your order request and assist you with any queries.  FSM may also use aggregated data, for example, to understand the number and type  of subscriptions purchased.  FSM use your information to perform a contract with you, by providing the subscription you have requested, and they have a legitimate interest in understanding subscription purchases to help inform product development and marketing. FSM may inform us that you have purchased the subscription so that we can provide you with in-vehicle functionality and you can access and control the feature via the app.  Where necessary to provide the service, FSM may also share some data with the provider

Product

Provider

Information shared

FordPass Charging Network

Ionity GmbH

FordPass charging card number, partial VIN

 

The New Motion B.V.

FordPass charging card number

 

BP Chargemaster Limited

(UK only)

FordPass charging card number, unique reference number, name, email, postal address

Neutral Server

Caruso

Subject to your chosen service, this may include vehicle location, vehicle information and driving data

 

High Mobility

Subject to your chosen service, this may include vehicle location, vehicle information and driving data

Live Traffic

Local Hazard Information (LHI)

HERE Global B.V

Vehicle location, direction and speed which has been de-identified

Each provider will use the information in accordance with their privacy policies

When you pay through FordPay (which is operated by FCE Bank Plc), FSM will share with them your user ID, details of your requested product and your payment amount.  FordPay will use your data in accordance with their privacy policy https://www.fordpass.com/content/ford_com/fp_app/en_gb/terms.html. For more information on how FSM will use your data, international transfers and exercising your rights, please refer to this privacy policy. To contact FSM, please see https://www.fordpass.com/content/ford_com/fp_app/all_eu/eu-data-controllers.html.

·  If you use a complimentary trial for real-time traffic and local hazard information, we share your vehicle location, direction and speed with our provider, HERE Global B.V..  We only share this data in a way that does not identify you or your car.

·  If you choose to activate your vehicle's WiFi Hotspot with our network provider, Vodafone Global Enterprise Limited ("Vodafone"), we will send them your VIN and vehicle SIM identifier to enable the service. You can find out how Vodafone use your personal information in their privacy policy. Vodafone will inform us when certain data use thresholds are met so that we can show this information in the app or if you call our customer service centre.

·  If you use the SYNC4 Connected Navigation or Connected Built-In Navigation services, we will share with Garmin a unique vehicle identifier, the vehicle’s current GPS location, route, destination information, address and point of interest search requests.  Garmin will use this information in accordance with their privacy policy.

·  When you use the Digital Roadside Assistance functionality on a vehicle connected to the app, we share, unless you opt-out, your name, location, phone number with your local Roadside Assistance provider (RSA) so that they can provide you with the service. Your RSA will use this information in accordance with their privacy policy.  Information, such as your VIN, vehicle health information and reason for your Roadside Assistance call, may be shared with us for the purposes set out in this policy (such as product improvement, research and development).

·  When you ask us to electronically share vehicle information with your selected service provider, for example, if you have entered into an agreement with a third-party provider for a usage based insurance product or a product supported by a neutral server platform

·  When connecting with your other authorised FordPass account holders, your profile picture and first name will be shared.

·  We may share de-identified information, for example, Environment Data with third parties

Where Your Information is Stored:

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 the data protection law of the country where you downloaded the app and may be transferred within the European Economic Area ("EEA"), as well as to countries outside the EEA (including to the UK, USA, India and our Affiliates listed at Ford Motor Company Group)

How long do we keep your information?

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

-       your information is reasonably required in order to provide the Services to you;

-       your information is reasonably required in order to satisfy the purpose for which you submitted or we collected the information;

-       your 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 information by applicable laws or regulations.

Cookie-like technologies active on FordPass app

What are cookie-like technologies?

Cookie-like technologies 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 site 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.

·         Advertising: Where you have consented, we may use these technologies to assess the success of our advertising campaigns and personalize the marketing you receive. You can revoke consent of advertising cookies at any time via the ‘Privacy’ tile in the ‘Account’ section of the app.

·         Guides purposes: 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 marketing, advertising cookies and 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 GPS data, Live Traffic will be unable to provide up-to-date traffic data and, 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. 

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 Policy is available on your local Ford website or at Fordconnected.com

·         Your Rights

You have the right as an individual to find out what information we hold about you and for what purposes, 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 data, or to ask us to delete, restrict the use of your 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 can share it with other organisations (this is often referred to as the right to 'data portability').

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 information, we hope that in the first instance you will let us know so that we are able to address your concerns. However, you are also entitled to lodge a complaint with your local data protection authority.

 

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:

Privacy Enquiry, PO Box 616, Hull HU9 9PR

You can also contact our Data Protection Officer directly here:

dpeurope@ford.com

Security of Your Information

 

We use appropriate systems, policies, procedures, and technology to protect and maintain the security and accuracy of your information. 

 

Other websites

FordPass may contain links to other apps or websites which are outside our control and are not covered by this Policy. 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 and Cookie Policy Effective Date and Revisions

 

This Policy 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 Policy, we will notify you of the changes. Where the changes will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).