GWM Connected Vehicles Privacy Policy
Last updated: 12/02/2024
HAVAL MOTORS AUSTRALIA PTY LTD and its affiliates (referred to as GWM or we) will protect and respect any personal information you share with us in accordance with our obligations under the Australian Privacy Act 1988 (Cth) and the New Zealand Privacy Act 2020.
This Privacy Policy explains what kind of personal data we collect and process, to what extent and for what purpose, how we share personal data with others, how you can change and manage the information we hold, how you can contact us and what rights you have, each in connection with the internet-connected services and functionality available in applicable GWM and Haval vehicles (Services).
Some of our vehicles contain telematic hardware called a “T-Box”, which enables the vehicle to connect to the internet. All vehicles which contain a "T-Box" offer some internet-enabled functionality which is available as soon as you purchase the vehicle. We offer additional remote control and information services, known as the “GWM Connect Services”, which you may elect to activate via the GWM Connect mobile phone application (GWM App).
For GWM’s privacy policy relating to in-vehicle infotainment units, please see [www.gwmanz.com/privacy/infotainment]. For GWM’s general privacy policy, which applies to all other personal information which GWM collects, uses, holds and discloses, please see [www.gwmanz.com/privacy].
In this Privacy Policy, personal data or personal information includes any information or an opinion about an identified individual or an individual who is reasonably identifiable, and regardless of whether or not it is true. References to “personal data” or “personal information” also include, where applicable, sensitive information, or the equivalent term under applicable law.
1. Data collection by internet-connected vehicles
If you drive any GWM or Haval vehicle with internet-enabled functionality, the following personal data will be collected, via your vehicle, whether or not you also use the GWM Connect Services and GWM App:
A) Location information: Our internet-connected vehicles contain GPS technology which allows you to utilise a third-party navigation system provided by HERE Technologies. Details of the location of your vehicle will be collected by us and shared with HERE Technologies in order to provide this functionality.
B) Voice commands: Details of any voice-commands which you set up and use, to allow you to control certain features in Your vehicle.
C) In-Vehicle Infotainment: If you use the In-Vehicle Infotainment services, we will collect and process information relating to your vehicle (including the vehicle identification number (VIN)), your device information and account information. For further information in relation to how we process your personal data when you make use of these services, please see our In-Vehicle Infotainment Privacy Policy [www.gwmanz.com/privacy/infotainment].
If you do not provide us with this personal data, you will not be able to utilise certain functionality within your vehicle.
2. Data collection when using the GWM Connect Services and GWM App functions
If you elect to use the GWM Connect Services, including the GWM App, additional remote control and information services will be provided. We collect and process your personal data as described below when you use Services via the GWM App:
A) Registration and management of a GWM account: The use of the GWM App requires that you register and create a user account (Account). We collect and process personal data as follows through the GWM App:
· Create an Account: When you create an Account via the GWM App, you must enter your email address, password and the verification code that is automatically sent by email. You will then receive your GWM ID, which you will need in order to use all the Services and functions within the GWM App.
· Management of your account information: In addition to your registration data (e-mail address and password), you also have the option of adding optional information to your profile, such as username, gender, date of birth and other information about yourself in a free text field, which you can update at any time.
The data processing that takes place in this context is for the purpose of granting you access to the GWM App and its functions.
B) GWM Connect services: Our GWM Connect offering allows you to receive live updates from your car straight to your GWM App, including vehicle status, battery charge and estimated range, tire pressure and other elements, and the ability to control some functions in the car remotely through the GWM App including locking/unlocking, headlights flash, horn, closing sunroof (where provided) and windows, air conditioning and temperature controls, seat ventilation, battery charging (where provided) and additional location-based services.
To operate the GWM Connect service, we collect and use the following personal data: car owner name, a unique GWM identification we assign to you, your email address, the VIN relating to your car, the unique part number relating to a telematic hardware component in the car called a "T-Box", the nature of GWM Connect subscription (where relevant) and certain mobile network unique identifiers which are crucial to enable the GWM App to communicate with hardware in the car so your GWM Connect service can work, including the SIM ICCID (or Integrated Circuit Card ID assigned to the SIM), the IMSI number (or International Mobile Subscriber Identity) and the SIM MSISDN (Mobile Station international ISDN number).
With your consent, we will also collect information relating to the location of your device which you use to access the GWM App. You have the ability to link the GWM App with the camera on your device in order to access additional functionality, however please note that we are not able to view any of the saved photos on your device if you elect to use this functionality.
Please note that you can revoke your consent to access location, camera and images in the Settings section of the GWP App.
C) Product monitoring and improvement: When you use our GWM Connect Services and GWM App, we may automatically collect information about your usage patterns and store this information as “network log” information. This allows us to maintain account security, understand customisation and optimisation opportunities of our products, identify unusual occurrences or events in accounts, and provide goods and services of interest to you. Information we collect for this purpose includes:
· Device Information: We receive information about the devices you use to access the GWM App (including device model, browser version, operating system version and other software, hardware and device environment information) and device location information (including GPS location of your device if approved by the user in the settings) according to the specific functionality in the installation and use of the GWM App. As noted above, you can revoke your consent to access location information in the Settings section of the GWP App.
· Services log information: When you use our products and Services, we automatically collect detailed usage information about your usage of our products and Services and store this information as “service logs”; this includes information about your browsing, clicking, searching, collecting, performing functions and the timing of corresponding events.
· To improve the design, functionality, stability and security of our products and Services and to provide a better experience for all users, our internal analytics tools record information relating to your use of the GWM App including those elements referenced above and your IP address, device IDs, device make, device model, operating system and version of your device and country of residence to review your activity in relation to our products and Services, including browsing behaviour.
Device and services log information is pseudonymised before being used for these purposes and does not directly identify a natural person.
The personal data described in this section 2 is collected from you directly, when you use the GWM App, or is obtained from your vehicle or device.
If you do not provide us with your personal data, you may not be able to use the GWM App, or may not be able to utilise certain functionality within the GWM App.
3. Purposes of the processing
Your personal data may also be used for the following purposes:
· to activate and maintain your Account;
· to respond to your enquiries and communicate with you, or provide you with access to certain information that you have requested from us;
· to provide our Services, including technical and operational support and the Services described in sections 1 and 2 above;
· to back up our databases;
· to maintain the security of our website and apps, including the GWM App;
· to communicate with you and to personalise this communication;
· to carry out other activities, such as advertising campaigns and promotional communications (based on your consent, where required). You can also sign up for email subscriptions and choose to receive promotional communications from us by email, SMS, post and telephone or other means of communication;
· to locate vehicles for security purposes; and
· to conduct data analysis studies to review and better understand customer satisfaction and needs and improve our products and services.
4. Disclosure of your personal data and transfer of personal data outside of Australia and/or New Zealand
We may share your personal data within our company and to our related entities and affiliates, both in Australia, New Zealand and overseas. We may also disclose your personal information to carefully selected third-party service providers who carry out certain activities on our behalf. These include, for example, call centre providers, technology service providers, operators of the communication networks over which our Services operate, payment providers, delivery service providers and operators of third-party applications and services available via the vehicle and/or the GWM App, including HERE Technologies. Where possible, we aim to ensure that these third parties are legally and contractually bound to ensure a high level of data protection and to process your personal data only in accordance with applicable laws, however such third parties may (in some cases) process your information in accordance with their own privacy policies, which we are not responsible for.
All data relating to the GWM App will be hosted in Singapore.
We are a global company and operate worldwide. Therefore we collect and transmit personal data worldwide, including to China where our headquarters are located, and other locations where GWM has operations. In addition, some of the recipients described in this section may be located outside of Australia and/or New Zealand in a range of jurisdictions.
5. Your data subject rights
In Australia and New Zealand, you have the following rights in respect of your personal data:
· the right to information about the processing of your personal data and access to the personal data we hold about you; and
· the right to request rectification of your personal data we hold about you if it is inaccurate or incomplete.
You can contact us to exercise these rights using the contact details set out in section 11 of this Privacy Policy. We may require that the person requesting access provide suitable identification and, where permitted by law, we may charge an administration fee for granting access to your personal information.
6. Advertising messages
We may send you advertising or other marketing materials about GWM’s goods and Services by email, text message and in-app messaging.
For a better user experience, we may recommend products, Services and activities of interest to you based on personal data you have provided to us.
If you do not provide your personal data or do not give the corresponding consent, we will not be able to provide you with individualised information and recommendations. You can revoke your consent at any time (e.g. by clicking on the unsubscribe link contained in the e-mails) or by e-mailing [[email protected]].
7. Protection of your personal data
As noted above in section 4, personal data collected by us relating to the GWM App is stored with a third-party cloud hosting provider in Singapore.
We take reasonable steps to ensure that the personal data we collect is processed in accordance with the terms of this Privacy Policy and all applicable laws.
We have implemented organisational, physical and technical security measures, in line with industry standards, to protect the personal data you provide and to prevent unauthorised access, disclosure, use, alteration, damage or loss of your personal data, including the following:
· We use AES256 and RSA and other algorithms or technical measures to encrypt our Services and products and in particular your personal data, such as your location information, recorded audio etc. We regularly review our data processing activities (including physical security measures) in order to prevent unauthorised system access.
· Our employees and third-party personnel may only access personal data which they strictly need to access to support the processing of your personal data and provision of the Services. These employees and third-party personnel are bound by strict confidentiality obligations.
· We use encryption and other security measures to transfer and store certain types of your personal data.
· We have established a regular testing procedure to test and evaluate how effective the technical and organisational measures are to ensure the security of such data processing.
· We select business partners and service providers prudently and ensure that these business partners and service providers are contractually bound to comply with appropriate data protection obligations and relevant laws regarding data protection and confidentiality.
· We conduct training or testing on security and privacy to increase employee awareness of the importance of protecting personal data.
· Personal data in the GWP App can only be accessed by a user with an individual password. To protect the integrity of respective personal data, you should not disclose or otherwise communicate your password to third parties. Please let us know immediately if you suspect that your password or data is no longer secure.
8. Retention of your personal data
We will only keep personal data for as long as is necessary for the purpose for which it can be used or disclosed by us under the privacy laws, including for the purposes of satisfying any applicable legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If the retention period for your personal data expires, we will (1) permanently delete your personal data or (2) ensure that your personal data is anonymised and thus no longer identifiable.
9. Cookies and other tracking technologies
GWM uses technology such as “cookies” on its website and in emails you have agreed to receive from us so we can improve our website and services provided by our websites and enhance your user experience. Cookies can be used to provide you with information tailored to your needs. A cookie is a small file that can be sent from a website to your browser and then stored on your computer so that we can recognise you when you revisit our website. You can set your browser to notify you when you receive a cookie. We may use similar technologies help us provide our products and Services, understand and customise your preferences and optimise our Services.
You can accept or reject the cookies used by our website or by changing your browser. Information on how to change your cookie preferences can be found in the Help-menu. If cookies are disabled, you may not be able to fully use the GWM App and all associated features.
10. Updates to this Privacy Policy
This Privacy Policy may be amended from time to time. We will contact you, where reasonably possible, when such updates occur and changes to the Privacy Policy will be published on the GWM App. We recommend that you regularly check back to review the latest version of this Privacy Policy.
11. Contact us and complaints
If you would like further information about the processing of your personal data or the exercise of the rights set out in this Privacy Policy, please feel free to contact us using the “contact us” section in the GWM App or the relevant details below:
· Email: [email protected]
· Mail: 745 Springvale Rd, Mulgrave Victoria 3170
We welcome your queries or comments about our Privacy Policy and personal information handling practices. If you have any questions, concerns or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy or any applicable privacy laws, please contact us using the details above.
When contacting us please provide as much detail as possible in relation to your question, concern or complaint. We take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
We will notify you of the outcome of this investigation and any subsequent internal investigation.
You may also approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) or, if you are located in New Zealand, the Office of the New Zealand Privacy Commissioner (https://www.privacy.org.nz) for guidance on alternative courses of action which may be available.