This Policy covers any Personal Data we collect in connection with your use of cert.mirrolink.org, www.carconnectivity.org and www.mirrorlink.com (the “Websites”), where you can:
You can navigate to the relevant sections of the policy by clicking the links below:
Some of these provisions here, particularly your rights in respect of your data, will only apply if you are an individual based in the EU or the state of California. We have highlighted these sections as relevant.
For the purposes of applicable data protection laws, Car Connectivity Consortium, LLC, a company incorporated in Oregon, USA with its registered address at 3855 SW 153rd Drive, Beaverton, OR 97003 USA is the controller of your data. This means that we are the primary entity who decides the purposes and means for dealing with your personal data.
When you access or receive the CCC Services, we may collect a variety of Personal Data about you, including:
The CCC primarily collects Personal Data provided by you directly when you receive or request the CCC Services. For example, we may receive your name, address, telephone number, company name, job title, e-mail address and any other information that you voluntarily submit to us (e.g. special access or dietary requirements for events) when you register for an account on our Websites or to access the Bugzilla tool, sign up to or attend our events, or raise an enquiry/correspond with us face to face, through phone, email or our online contact form.
We will let you know at the point of collecting your information whether this is optional, or whether it is necessary for you to provide this information to meet certain statutory or contractual requirements. If the latter and you do not wish to provide us with this information, this may limit the services we are able to provide to you.
We may also receive information about you from:
The Application Certification Management System is run by Comarch on our behalf, and collects the following types of information when you visit or use the ACMS:
We will only use your personal data if we have a permitted lawful basis to do so. The primary purpose for which we collect information about you is to provide members and developers with services to support the technologies developed by the CCC (e.g. what you need to develop MirrorLink and Digital Key devices and applications). We also collect information about you for the following purposes:
To perform our contract with you (i.e. to provide you with our services and resources if you sign up to be a CCC member or developer)
For our legitimate interests
To comply with our legal obligations
We may also (where required by law) use your Personal Data for marketing purposes with your consent (see “Marketing communications” below).
Where you are a CCC member, we may also use your Personal Datato keep you updated about CCC events and activities through marketing communications.
This means we may use your contact information to contact you by email with announcements and newsletters regarding information that we think may be of interest to you.
If you are based in the EU, we will only make marketing communications if you have given your consent to do so if you are a developer using your individual, sole trader or partnership (rather than company employee) email address. You have the right to withdraw your consent to these activities at any time, which will mean (unless we have another lawful basis to continue using your data) that we will cease to use your Personal Data for these marketing purposes.
If you wish to stop receiving marketing emails from the CCC, you can do so by contacting the CCC at contact information below or changing your communications preferences in your member portal (under “User Settings” and “Manage Your Email Subscriptions”).
We may disclose the Personal Data that we collect with the following third parties:
Please note that the ACMS and member/developer portal systems on the Websites use a shared sign-on system. This means that your name, email address and company name will be shared between Comarch and VTM as our external providers of these systems (regardless of whether you actually use the ACMS features), as this enables you to use one set of log-in details to access all member/developer features of the CCC Services.
Additionally, Metric Data and Activity Data collected through the ACMS (see “What data do you collect about me?” above) can be viewed by many users of the ACMS, including other developers, members of the CCC, and system administrators. The Developer ID, Server Device ID and Application ID can all be determined by examining the files of a MirrorLink application.
Our main database is located in the U.S. and we collect, store and process the information from our Websites, the ACMS and Other Tools in both the U.S. and the EU. This means that if you are outside the U.S., then your Personal Data may be transferred abroad to a country with different data protection laws. By providing your Personal Data in connection with the CCC Services, you agree to this potential international transfer of your Personal Data.
If you are based in the EU, we will ensure that such transfers are made subject to appropriate safeguards as required by applicable data protection laws to ensure that a similar degree of protection is afforded to your personal data, including by ensuring that overseas recipients of your data have been self-certified under the Privacy Shield framework or through the use of EU Commission approved standard contractual clauses . You can obtain further information about the safeguards in place for your international transfers of personal data by contacting us (see “Contact Us” below) and the Privacy Shield scheme at www.privacyshield.gov.
You can exercise all the rights applicable to you by contacting us (see details in the “Contact Us” section below) or submitting an online enquiry form on our Websites.
If you are based in the EU
You may, in circumstances, have the following rights in relation to the Personal Data we hold about you. You can request to:
· access a copy of the information held about you
· rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal information we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal information corrected. You can also update any incorrect contact information yourself by updating your profile information in the member’s portal or by emailing email@example.com.
· delete, restrict or remove the data we hold about you
· transfer the data we hold about you to another party
· object to any further processing of your data, if we are processing your Personal Data on the basis of our legitimate interests (see “How do we use your personal data and for what grounds” above), or for direct marketing.
We will endeavor to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
· refuse your request based on the exemptions set out in the applicable data protection laws.
· request for proof of your ID to process the request or request further information
· charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
If you have any concerns about how we handle your data, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with the data protection regulator for your country of residence.
If you are based in California
If you are based anywhere else
The CCC acknowledges that you have the right to access your Personal Data. In case you request us to remove data, we will respond within a reasonable timeframe.
Upon request, the CCC will provide you with information about whether we hold any of your Personal Data. You can update or correct your Personal Data or remove it from our system by making a request to us at the contact information provided below. Requests typically receive a response within thirty (30) days. If access cannot be provided within that time frame, we will provide the requesting party with an estimated date by which the information will be provided. If for some reason access is denied, we will provide an explanation of why access has been denied.
We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorized use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
We are committed to taking reasonable efforts to secure the information that you choose to provide us, and we use a variety of security procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of Personal Data. We restrict access to Personal Data to our employees, contractors and service providers (described in “Who we share your data with” above) who need to know the information to operate, develop, or improve the CCC Services.
We retain your Personal Data for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. We retain Personal Data collected through the Platforms we process for as long as needed.
The CCC Services are not intended for use by or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. Children under 13 should not use the Websites, the ACMS or Other Tools.
Address: Car Connectivity Consortium, 3855 SW 153rd Drive, Beaverton, OR 97003 USA