At Jaguar Land Rover North America, LLC and Jaguar Land Rover Limited (collectively referred to as “JLR”, “our”, or “we”), we respect and are committed to protecting your privacy.
Information We Collect - We collect various information (“Covered Information,” as defined in the Policy) about you and your InControl-equipped Land Rover vehicle, including:
- information relating to your purchase or lease of your InControl-equipped Land Rover vehicle;
- information about your communications with us, requests made via the My Land Rover InControl website or Remote Smartphone App, and how you access and use the My Land Rover InControl website or Remote Smartphone App (including device-related information);
- information about your vehicle, including its make, model, model year, features, registration number, Vehicle Identification Number, date of purchase or lease and vehicle status;
- location information and information about how you drive your Vehicle: Unless you cancel your InControl Services, we will collect your vehicle’s last-parked location. When the “Journey Tracking” function is activated, we collect the location of your vehicle, average speed, and other information. The full Policy describes how you can turn off the “Journey Tracking” function. But certain events, such as emergency calls which can be automatically triggered by an accident, the deployment of airbags, or manually made, may automatically activate collection of location information even when the “Journey Tracking” function is turned off or if you have declined acceptance of InControl Services. Depending upon the location settings of your mobile device, which you can control, the InControl Remote™ Smartphone App may collect information about your mobile device’s location, but this information is not transmitted to us. The location information is processed on your device;
- Please note that, unless the “Journey Tracking” function is turned off or if you have declined acceptance of InControl Services, users of the InControl Remote Smartphone App or My Land Rover InControl website and JLR may be able to view the Vehicle’s status or location when in use by others, except that if you have an active InControl Services account, the last parked location of the Vehicle will always (subject to network availability) be available on the InControl Remote Smartphone App and the My Land Rover InControl website regardless of whether “Journey Tracking” is enabled or disabled.
- by using cookies and other technologies to track your interactions with our online services and personalize your experience;
- information from your registration/subscription for and use of connectivity services relating to your InControl Services, including any Trial Plan and/or Data Plan;
- information about you and your vehicle from publicly or commercially available sources.
How We Use Information - We use Covered Information:
- to provide you with the InControl Services you have requested and to improve and troubleshoot those services;
- to communicate with you about your account or vehicle, learn about you, and resolve disputes;
- for internal research or product development;
- for safety, operations, compliance and/or warranty purposes;
- to improve, maintain, and troubleshoot InControl Services and provide diagnostics and service information for your vehicle; and
- to provide you with offers that may be of interest to you.
Sharing Information – We share Covered Information:
- with third-parties, including service providers, that process information on our behalf, and to provide you with InControl Services;
- with our corporate affiliates and authorized Land Rover retailers;
- to facilitate a transfer of a business or related assets; when there is a legal obligation to disclose your information; or to protect our legal rights, the public, or others;
- in a de-identified manner for various purposes; and
- with our trusted business partners and other third-parties to provide you with information about offers, goods and services
If we use your Covered Information to provide you with marketing communications from us or others, we may make certain options available regarding those communications via the My Land Rover InControl website.
You can learn about your ability to register your do not track preferences in the “Do Not Track Preferences” section of the full Policy.
We use reasonable security measures to protect your Covered Information.
We and our service providers may collect, transfer, store and process your information outside of your country of residence.
InControl Services are not intended for children under 13.
We are not responsible for any third-party products or services you access via the InControl Package.
How to Contact Us
Jaguar Land Rover North America, LLC
555 MacArthur Blvd.
Mahwah, New Jersey 07430
Attn: Customer Care – Privacy Issues
Last updated: 25 July 2015
SCOPE OF POLICY
This Policy, which is incorporated into the InControl™ Package Terms and Conditions (“InControl Terms and Conditions”), applies to your use of:
- any of the following “InControl” services (depending on your Vehicle model and subscription): (i) the services provided via the InControl Remote™ Smartphone App and the My Land Rover InControl website; (ii) the “SOS Emergency Call” services (including the InControl Connectivity Services); (iii) the “Optimized Land Rover Assistance” services (including the InControl Connectivity Services); (iv) “Stolen Vehicle Locator” services (including the InControl Connectivity Services); (v) InControl Pro™ Features; and (v) the “Live” functionality (“InControl Services”).
- the website from which you can access your InControl Services account and access certain InControl Services (“My Land Rover InControl website”); and
- the mobile phone application (“InControl Remote Smartphone App”) that you may download onto your mobile telephone and which enables you to use the ”Remote” features;
- the 3G network connectivity, which allows you to use the Live Features and Wi-Fi Hotspot functionalities, provided to your Vehicle by a Network Provider, if applicable depending on your Vehicle’s make, model and specifications, limited to the lesser of three (3) gigabytes or three (3) months of data usage, whichever comes first (“Trial Plan”);
- the transmission of data, SMS and Voice by the Network Provider to and from the installed and activated Telematics SIM in the Vehicle in relation to the “SOS Emergency Call” service, the “Optimized Land Rover Assistance” service, the “Stolen Vehicle Locator” service or the services provided via the InControl Remote Smartphone App, and also, depending on your Vehicle’s model and subscription, the transmission of data, SMS and Voice by the Network Provider to and from the installed and activated Personal SIM in the Vehicle in relation to any InControl Pro Features in your Vehicle (“InControl Connectivity Services”).
Words and phrases used in this policy have the same meanings defined in our InControl Terms and Conditions as set out on the My Land Rover InControl website unless otherwise indicated. “InControl Package” as used herein shall mean, as applicable based on your Vehicle’s model and subscription(s), the InControl Services, the My Land Rover InControl website, the InControl Remote Smartphone App, and your Vehicle’s Wi-Fi Hotspot functionality (including the Trial Plan).
Please note that, as described in more detail below in the discussions of information we may collect, certain services and connectivity between your Vehicle and us may continue even if you decline to accept InControl Services.
INFORMATION WE MAY COLLECT ABOUT YOU
We may collect and process the following data about you and/or your Vehicle (“Covered Information”):
- Submitted Information: information that you or the authorized Land Rover retailer from which you purchased or leased your Vehicle provide during the setup of your InControl Package account(s). This information includes, but is not limited to, your name, address, telephone number (including mobile number), e-mail address, language preference, password and PINs for your InControl Services account, and your preferred authorized Land Rover retailer.
- Transaction and Communication Records:
- if you contact us, we may keep a record of that correspondence; and
- details of any transactions, if applicable, you carry out through the My Land Rover InControl website, Live Features and/or the InControl Remote Smartphone App.
- Device Information (including location): We may collect information about the mobile device, tablet (or similar) or any computer you may use (each a “Device”) to download a copy of the InControl Remote Smartphone App onto your Device, including the operating system and version, the InControl Remote Smartphone App installation unique identifier, and the Device’s locale settings and country code. The InControl Remote Smartphone App may also collect information about the location of your device and tokens and username for identification. You can restrict the access to, or collection of, your Device’s location by disabling the location features of your Device or by not using the features of the device that require location information.
- Vehicle Identification Information: information about the vehicle on which you have a current and valid subscription for the InControl Services (“Vehicle”) including the Vehicle Identification Number (“VIN”), make, model, model year, Vehicle features, registration number, date of purchase or lease, and the authorized Land Rover retailer from which you purchased or leased the Vehicle.
- Vehicle Location Information: information about the last parked location of the Vehicle, which will always be collected for availability through the Remote Smartphone App and the My Land Rover InControl website unless you cancel your InControl Services by the method(s) described in the InControl Terms and Conditions. We will also collect and process information about the location of the Vehicle at any point in time as part of the “Journey Tracking” function (“Journeys”) of the InControl Services (when Journeys is activated). The information that we will collect and process as part of Journeys is set out in “Journey Information” below. You are able to switch off Journeys via the My Land Rover InControl website or the InControl Remote Smartphone App. If, however, the “SOS Emergency Call”, the “Optimized Land Rover Assistance”, or “Stolen Vehicle Locator” function is activated, real-time location data relating to the Vehicle will be sent to the relevant service providers and/or emergency services (as appropriate) even if you have not activated Journeys or switched off Journeys. Please note that the “SOS Emergency Call” functions will be activated automatically upon the occurrence of a relevant trigger event such as the deployment of your vehicle’s airbags respectively. Please also note that even if you decline acceptance of InControl Services, certain limited connectivity between your Vehicle and us and/or our emergency service providers will continue, which may be triggered in the event of an emergency. Specifically, if vehicle sensors detect that an accident may have occurred, including through a trigger such as deployment of the Vehicle’s airbags, the Vehicle may automatically initiate a call to contact emergency services via activation of the “SOS Emergency Call” function or you may be able to manually initiate a Voice call for emergency services. The occurrence of such call may transmit information, including Vehicle location, time, and a vehicle identifier to us and/or our emergency service providers. For full details of the relevant trigger events please refer to the Vehicle handbook.
- Information about How You Drive Your Vehicle - “Journey Information”: information about your journey is sent from your Vehicle, including the journey date and distance, the duration of the journey (start date/time and end date/time), the average speed, the distance, the route travelled and data about the Vehicle’s fuel efficiency. You can turn off Journeys via the My Land Rover InControl website or the InControl Remote Smartphone App. This will prevent any of the above information from being sent from the Vehicle (except for the last parked location).
- Vehicle Operation Information: this includes information relating to the Vehicle’s involvement in an accident, such as the deployment of airbags or activation of Vehicle sensors. We may also collect information about the operation of the Vehicle including, but not limited to, the fuel level, the estimated distance to empty, the odometer value, the distance to recommended service status, the coolant level, the washer fluid level, the brake fluid status, the brake pad wear, tire pressure, tire pressure sensor failure, engine malfunction, oil level, door and window status, trunk open, hood open status, battery voltage, and whether the alarm is armed or sounding.
- Security Authentication: Vehicle identification data and authentication tokens.
- “Live” information: app specific information such as favourites, emails, notes, media, and information you choose to submit to the Live Apps you use; content feed usage-related information; user settings such as activation of ‘remember me’ function; security authentication data; localisation information such as time zone, language and country; Vehicle make and brand; relevant Log Information.
We may also collect information about you from public or commercial sources, which shall not be considered Covered Information hereunder.
We may combine any of the above described Covered Information together with any information collected from public and/or commercial sources, and will treat the combined information as Covered Information in accordance with this policy for as long as it is combined.
ACCESS TO LOCATION AND VEHICLE INFORMATION
My Land Rover InControl website
Two types of cookies are used on the My Land Rover InControl website:
1. Session Cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site.
2. Persistent Cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
Session Cookies are used:
- So that you do not have to re-enter information when you visit different pages on the My Land Rover InControl website.
- Within registration to allow you to access stored information.
Persistent Cookies are used:
- To help us recognize you as a unique visitor when you visit the My Land Rover InControl website.
- To allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same ads repeatedly.
- To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website.
We use Google Analytics on the My Land Rover InControl website to compile anonymous, aggregated statistics that allow us to understand how our customers use our app and website and to help us improve them. This data does not identify you personally. Please see www.google.com/policies/privacy/partners and https://tools.google.com/dlpage/gaoptout for further information.
InControl Remote Smartphone App
We use Google Analytics on the InControl Remote Smartphone App to compile anonymous, aggregated statistics that allow us to understand how our customers use the InControl Remote Smartphone App and to help us improve it. This data does not identify you personally. Please see www.google.com/policies/privacy/partners for further information.
You may choose to disable Google Analytics on the InControl Remote Smartphone App via your account settings.
To provide the InControl Services or the functionality of the InControl Remote Smartphone App, the InControl Remote Smartphone App temporarily stores or “caches” some of your submitted information (although please note that your password is never cached and that your PIN is only cached when you are using the remote climate feature), your vehicle identification information, certain vehicle operation information and data related to your use of the InControl Remote Smartphone App features. The cached data, with the exception of the PIN (when using remote climate features), is stored on your device. All cached data will be wiped when you sign out of the InControl Remote Smartphone App.
Some of the pages on the My Land Rover InControl website and electronic communications associated with InControl may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as “clear gifs”). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. These Web Beacons do not personally identify you and are only used to track usage of the My Land Rover InControl website and activities associated with the My Land Rover InControl website or communications. See the Do Not Track Preferences section below.
DO NOT TRACK PREFERENCES
When you visit the My Land Rover InControl website, we may collect certain anonymous information for various purposes, such as learning about how users interact with or come to the My Land Rover InControl website, when you visit the My Land Rover InControl website. Such information may include click stream information, browser type, time and date, and content clicked or scrolled over. We typically use a cookie or Web Beacon to collect this information, as described above. Through these technologies, we may have access to and use non-personalized information about your online usage activity. We do not allow third-parties to collect information about your activities on the My Land Rover InControl website.
We do not otherwise respond to browser ‘do not track’ signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate; if we do so in the future, we will describe how we do so here. Again, see http://allaboutdnt.com/ for more information.
USES MADE OF THE INFORMATION
We use the Covered Information we collect in the following ways:
- Submitted Information: This information is processed to set up your InControl Package account(s) and to send you information about the InControl Services (for example information about any updates to the InControl Services or the InControl Remote Smartphone App).
- Transaction and Communication Records: This information is processed to help to resolve any issues with the InControl Package, to help resolve disputes connected with the InControl Package, to improve our customer service and to manage your transactions via the My Land Rover InControl website, Live Features and/or the InControl Remote Smartphone App;
- We may record calls with you for training purposes and to help resolve issues.
- Device Information: This information is automatically processed to provide you with the best service and to support issue resolution.
- Vehicle Identification Information, Location Information, Journey Information, Vehicle Operation Information: This information is processed to provide the InControl Services to you and to maintain and improve the quality of the InControl Services and to improve our customer service. We will also use this information to assist in resolving any technical issues with the InControl Services and to enhance your experience of the InControl Services. We will use the Vehicle Operation Information to aid in diagnostics and servicing in relation to the Vehicle and this may include sending you notifications by email or SMS or similar communication technology, unless you have opted out.
- Log information: We use Log Information as follows:
- We collect and process Call Log Information for the provision of our services to you, to investigate system issues or potential misuse of the InControl Package and we use anonymized or pseudonymized and aggregated Call Log Information to improve our operational processes regarding, as applicable, our SOS Emergency call, Optimized Land Rover Assistance, Stolen Vehicle Locator, InControl Pro Features and Live Features. Unless otherwise notified to you, we do not record calls.
- We collect and process Website and App Logs Information about your usage of the My Land Rover InControl website and InControl Remote Smartphone App for website/app logging and to investigate website/system issues. We use anonymized or pseudonymized and aggregated Website and App Logs Information for analytics purposes, to maintain and improve the quality of the InControl Package and app features, fault diagnosis and to improve the customer experience on our websites and apps. Please also see the Cookies section above.
- Security Authentication: this information is automatically communicated between our providers of security authentication and hosting services in order to verify identity and prevent unauthorised use of InControl Package;
- “Live” Information: this information is stored on the Vehicle and transferred to JLR or our service providers as necessary to facilitate the service, enable secure access to and download of Live Features from our service provider(s), and to store your settings, data and content relating to Live Features.
We may use Covered Information to generate statistics and analytics about your use of the InControl Package or to assess topics that may be of interest to you. This allows us to personalize your InControl Services and the communications you receive from us, detect and prevent fraud or misuse of the InControl Package, and address security concerns.
We may use Covered Information for internal purposes, and disclose Covered Information to any third parties, for any legitimate business purpose insofar as such Covered Information is processed such that it can no longer reasonably be linked to you and/or your Vehicle. Upon such processing, the anonymized information shall no longer be considered Covered Information under this Policy. Prior to disclosing any such anonymized information to any third party, we impose requirements upon any such third party to prevent them from attempting to de-anonymize any and all such anonymized information.
We may also use your Covered Information to contact you about goods and services that may be of interest to you and InControl Package-related messages as well as to communicate with you about maintenance and repair needs or make you aware of special promotions. We may contact you about these by mail, email, telephone, or text, including via autodialed or prerecorded messages to your home or cellphone. You will be able to register your preferences about such uses via the My Land Rover InControl website. Regardless of the marketing choices you select, we may continue to contact you through various channels for InControl Package-related purposes. For additional information regarding the use of your Covered Information for marketing purposes, please see the below section entitled “Use of Information for Marketing Purposes.”
DISCLOSURE OF YOUR INFORMATION
We may also share Covered Information collected by us with our authorized Land Rover retailers to assist them in servicing your Vehicle and in delivering an improved customer experience to you.
We may also pass the Covered Information collected above to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, including the possibility of providing information about your Vehicle’s location;
- to protect the rights, property or personal safety of JLR, its users, customers or the public; or
- to enforce or apply the InControl Terms and Conditions; or
- to investigate potential breaches, fraud, or misuse.
We may also share Covered Information with third parties or service providers that handle marketing communications on our behalf, including for co-branded offers, subject to you not having chosen to prevent certain marketing communications from us. We will not share your (or your Vehicle’s) non-anonymized geolocation or driving behavior data with unaffiliated third-parties for their exclusive or independent use without your consent.
We may share non-personally identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third-parties to demonstrate the usage patterns for JLR’s advertisements, content, functionality promotions and/or services on the My Land Rover InControl website, communications, and/or on third-party websites.
‘REMEMBER ME’ FUNCTION
Your Vehicle has a ‘remember me’ function for certain features of the InControl Package. This function enables you to remain automatically logged in on the Vehicle for more convenient access to the features. Please be aware that while this function is active any other person using the Vehicle will be able to access any of your stored settings, Live Features and personal details in the Vehicle and to use the InControl Package in the Vehicle as if they were you. If you do not wish other Users to have access, it is your responsibility to ensure the ‘remember me’ function is disabled and to log-out from the relevant features.
USE OF INFORMATION FOR MARKETING PURPOSES
In addition to the uses of Covered Information described above, we may also use Covered Information to contact you about goods and services that may be of interest to you, as well as to communicate with you about maintenance and repair programs or make you aware of special promotions. We may contact you about these by mail, email, telephone, or text, including via autodialed or prerecorded messages to your home or cellphone, unless you have asked us not to do so.
In order to provide this information to you, we may work with our selected third-party service provider(s) who handle marketing communications on our behalf and we will share Covered Information with them only for that purpose.
You have the right to ask us not to use Covered Information for marketing purposes. You are able to change your preferences to receive marketing information via the My Land Rover InControl website and the InControl Remote Smartphone App. You may also contact us at the address in the below “Contact Us” section regarding changing your preferences. Regardless of the marketing choices you select, we may continue to contact you through various channels for non-marketing, InControl Package-related purposes (e.g., product recalls, repairs and maintenance needs, etc.). We will not share your (or your Vehicle’s) non-anonymized geolocation or driving behavior data with unaffiliated third-parties for their exclusive or independent use and/or for marketing purposes without your consent, nor will we use your (or your Vehicle’s) geolocation or driving behavior data for our own marketing purposes without your consent.
We use reasonable administrative, physical, and technical security measures such as encryption technologies or authentication systems to protect Covered Information against loss, misuse, alteration, disclosure, destruction, theft or unauthorized access.
When you have chosen a password that enables you to access the My Land Rover InControl website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, nor will we ever ask you for this password.
In connection with the use of the “Stolen Vehicle Locator” service at the time of set-up of your InControl Services account, you will create a PIN and provide an answer to a security question. In the event that you make use of the Stolen Vehicle Locator service, you will be required to provide your PIN and/or the answer to the security question to the operator.
The transmission of information via the Internet is not completely secure. Although we will do our best to protect Covered Information, we cannot guarantee the security of Covered Information when stored with us or transmitted over the Internet; any transmission or storage is at your own risk. When you are logged into the InControl Remote Smartphone App or My Land Rover InControl website, some of your personal data may be stored by your Device in local cache and will be kept until you log out. When you access the My Land Rover InControl website, cookies may be stored and these do not include any personal data.
We require all of our services providers (those entities performing services on our behalf) to have appropriate measures in place to maintain the security of Covered Information.
We are not responsible for any third-party products or services you access via the InControl Package
CHANGING YOUR ACCOUNT PROFILE SETTINGS
If you wish to update your account profile settings, you may do so via the My Land Rover InControl website.
INFORMATION FROM CHILDREN
InControl is not intended or designed to attract children under the age of thirteen (13). We do not collect personally identifiable data from any person that we know to be under the age of thirteen (13). In any case, InControl IS NOT INTENDED FOR USE BY CHILDREN UNDER 13 THAT ARE UNACCOMPANIED BY THEIR PARENT OR LEGAL GUARDIAN.
YOUR CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2014 will receive information regarding 2013 sharing activities).
To obtain this information on behalf of JLR, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.
Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
UPDATES TO THIS POLICY
Jaguar Land Rover North America, LLC
555 MacArthur Blvd.
Mahwah, New Jersey 07430
Attn: Customer Care – Privacy Issues
800 – 637 – 6837