MAZDA CONNECTED SERVICES PRIVACY POLICY

This Privacy Policy describes how Mazda Canada Inc. (“us”, “our”, or “we”) may collect, use, and share your Personal Information (Personal information refers to any personally identifiable information about you) and vehicle data collected from your Mazda vehicle equipped with an activated, factory-installed telematics system (“Connected Vehicle”), which is remotely transmitted to us for certain business purposes, including to provide you with available connected services (“Connected Services”) and to provide you with services through the MyMazda mobile application (“MyMazda”) (collectively, “Services”).

PRIVACY POLICY SUMMARY

What information we collect

The information we collect depends on the settings for your Connected Vehicle, and the Services you have access to and/or use.

Vehicle Data: When you purchase or lease a Connected Vehicle, the telematics system is active by default and transmits vehicle data, including driving behavior data (including the acceleration and speed of your Connected Vehicle, travel direction, and use of steering and braking functions) and vehicle health data (which includes Vehicle Identification Number (VIN); odometer, fuel level, and oil life readings; Diagnostic Trouble Codes (DTCs); and data from the Connected Vehicle’s OBD system, including engine coolant temperature, fuel injection volume, engine Rotation Per Minute (RPM), and the status of doors, hood, trunk, and hazard lights). If your Connected Vehicle has a Connected Services plan, we also collect geo-location coordinates of your Connected Vehicle’s latitude and longitude.

Connected Services and MyMazda: If you have an active Connected Services plan and/or use MyMazda, we collect information including your name, address, email, phone number, VIN, and any other information you choose to provide.

MyMazda Data: If you use the MyMazda app, we collect the location of your device, device type, device operating system, Internet Protocol (IP) address, unique identifier, type of browser, Internet service provider, phone number, and information about your use of MyMazda, including screen time, scrolling, specific actions and taps, reactions to alerts, the progress, completion and/or abandonment of in-application purchases, and crash reports.

How we use the information we collect

We use the information we collect to: analyze safety concerns and product trends, issue product recalls, provide support and service; to conduct research and development, analyze quality, for product improvement, and to improve, troubleshoot, and evaluate the use of our products and services; to provide our products and services to you, administer your accounts, to communicate with you, to allow us and our dealers to customize and conduct advertising, including by email, phone and direct mail, and for legal purposes such as protecting our interests.

We may use Location Data to provide you with a Vehicle Finder feature and other Services. We may use Driving Data and Vehicle Health Data to provide you with the status information of your Connected Vehicle, and to provide you with notifications when your Connected Vehicle is due for maintenance or service or when it reports a malfunction and other Services. We and our dealers may access Vehicle Data to provide you with servicing and respond to requests.

How we share the information we collect

We may share the information we collect with our Affiliates and service providers who assist us with the purposes we describe in this Privacy Policy. We may transfer personal information if we undergo a business transaction such as a sale or merger. We may share your information with your dealer so your dealer can provide you information such as product or service offers. Our dealers may access Connected Vehicle information to provide you with servicing and respond to requests.

If your MyMazda account has both a Primary and Secondary Users, the Primary User is able to see the name, app permissions and the complete remote request history initiated by Secondary Users. If you invite someone to be a Secondary user, you must have the Secondary User’s permission. We may send them an invitation that identifies you.

Your Choices

If you receive promotional emails from us, you may unsubscribe from them using the unsubscribe link. You may also opt-out of our use of your personal information for marketing by contacting us.

If you would like to disable the collection of Vehicle Data from your Connected Vehicle please contact our Customer Assistance Centre (see ‘Contact Us’ section below for details). You may have the ability to choose to limit the collection of Vehicle Data in a manner that allows you t reactivate it if you choose, in which case some limited Vehicle Data is still collected. You may also permanently halt the collection of Vehicle Data, in which case we will not be able to provide you with the Connected Services.

You can also review the ‘Your Choices’ section of this privacy policy for more information about how you can withdraw your consent.

Application of this Policy

This Privacy Policy only applies to the collection, use and sharing of information obtained from Connected Vehicles and MyMazda and information you provide related to Connected Services and MyMazda, and does not apply to data collection in other contexts, such as: our other websites, applications, and online services that we provide (“Online Services”); any third-party websites or applications that we do not own, operate, or control; or features available through your Connected Vehicle’s Mazda Connect infotainment system. For information regarding our Online Services, please review our general Privacy Policy at www.mazda.ca/privacy. For details regarding Mazda Connect, please refer to your Owner’s Manual.

INFORMATION WE MAY COLLECT

Vehicle Data

When you purchase or lease a Connected Vehicle and/or if you have an active Connected Services plan, your Connected Vehicle will transmit certain vehicle data to us automatically from time to time, including (“Vehicle Data”):

• “Location Data”: geo-location coordinates of your Connected Vehicle’s latitude and longitude. This is collected if your Connected Vehicle has an active Connected Services plan;
• “Driving Data”: driving behavior data, which includes the acceleration and speed at which your Connected Vehicle is driven, travel direction, and use of the steering and braking functions in your Connected Vehicle; and
• “Vehicle Health Data”: includes Vehicle Identification Number (VIN); odometer, fuel level, and oil life readings; Diagnostic Trouble Codes (DTCs); and data from the Connected Vehicle’s OBD system, which includes, but is not limited to, engine coolant temperature, fuel injection volume, engine Rotation Per Minute (RPM), and the status of doors, hood, trunk, and hazard lights.

Additional collection of Information for the Services and MyMazda

In addition to our collection, use, sharing, and storing of Vehicle Data, if you have an active Connected Services plan and/or use MyMazda you will need to provide us with certain other information, which includes certain information about you or your Connected Vehicle that alone or in combination with other information could be used to identify you, e.g., name, address, phone number, and your Connected Vehicle’s Vehicle Identification Number (VIN).

For example, if you choose to subscribe to a Connected Services plan or register for a MyMazda account, you will be prompted in your MyMazda account to provide certain required Personal Information, which may include, but is not limited to, the following:

1. First and Last Name
2. Email
3. Phone Number
4. Address
5. VIN

All Personal Information and other information that is required to enroll in the Services will be identified as a required field in the MyMazda, and you will not be able to complete enrollment without providing responses to all required fields. You may additionally provide other requested information that is optional but not required to use Services.

You can log-into your MyMazda App to review, correct, revise, or update certain of your Personal Information.

MyMazda Data

When you install or use the MyMazda app, in addition to the Vehicle Data and Personal Information described above, we may also collect (“MyMazda Data” and together with Vehicle Data, “Data”):

1. Device information, such as the location of your Device, Device type, Device operating system, Internet Protocol (IP) address, unique identifier, type of browser, Internet service provider, and phone number;
2. Information about your use of MyMazda, including screen view time, scrolling, specific actions and taps to activate features and/or otherwise navigate the application, reactions to alerts, and the progress, completion and/or abandonment of in-application purchases.

You can restrict our access to and collection of certain types of data using settings on your mobile device and/or settings in MyMazda. For example, you can disable location sharing on your device, if that feature is available on your device, and you can disable the collection of certain data for troubleshooting purposes in the MyMazda app settings.

To improve the stability and reliability of MyMazda, we use crash reports (currently through "Firebase Crashlytics", a service of Google). In case of an error of MyMazda, app and Device related data might be transferred to Google's servers, including without limitation device status information, device IDs, information relating to the physical location of a device, crash trace, log-files, device operational system and language information and information about how the app was used. The data may be used by Google for own business purposes (e.g. improve its services; see references below for details). We ask for your consent to enable these crash reports and you can withdraw your consent to them in the MyMazda app settings. You can revoke your consent at any time by deactivating the respective function in the app settings under analytics.

For further information on how data will be processed by Google please see:

• FIREBASE CRASHLYTICS
• CRASHLYTICS TERMS
• CRASHLYTICS PRIVACY

HOW WE USE YOUR INFORMATION

We may use your information, including Personal Information, as follows:

1. analysis of safety concerns, issuance of product recalls and to provide customer and vehicle support and service;
2. analysis of product trends;
3. product quality analysis;
4. product research and development;
5. product improvements, for safety reasons or otherwise;
6. to improve, troubleshoot, and evaluate the use of our products and Services (including MyMazda);
7. provide our products and Services to you, including:
   1. Location Data: If your Connected Vehicle has an active Connected Services plan, we may use your Location Data to provide you with Vehicle Finder, which allows you to use the MyMazda App to view the geo-location coordinates of your Connected Vehicle’s position at last Ignition-Off, and other services from time to time.
   2. Driving Data and Vehicle Health Data: We may use both your Driving Data and Vehicle Health Data to provide you with the status information of your Connected Vehicle, including the status of doors, hood, trunk, and hazard lights. You can remotely view the status of your Connected Vehicle at any time using the MyMazda App.
   3. Vehicle Health Data: Subject to your communications preferences, we may use your Vehicle Health Data to provide you with notifications via the MyMazda App or email when your Connected Vehicle is due for maintenance or service (“Maintenance Notification”), or when your Connected Vehicle reports a malfunction-related event (“Malfunction Notification”).
8. to administer your accounts with us and to maintain customer relationships and communicate with you;
9. to advertise our products and services, and those of third parties we think may interest you, including contacting you by email, phone and direct mail, using the contact information you provide or that we have for you. For example, we may share your contact information such as your email address with your preferred dealer so your dealer can provide information that may be of interest to you, such as product or service offers;
10. we and our dealers may access Vehicle Data to provide you with servicing and respond to service related requests;
11. customize and improve communication content and your experience;
12. if we have reason to believe that using such information is reasonably necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; or (iii) to protect our rights, safety or property including for fraud prevention; and
13. we may combine the information collected under this privacy policy with information you provide us through other means, such as our contests, lead generation, sales data, service data. We may use this information to advertise our products and services, and those of third parties we think may interest you, including contacting you by email, phone and direct mail.

We may anonymize, aggregate or otherwise strip any Personal Information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purpose we deem appropriate.

SHARING INFORMATION

We may share your information as follows:

• With our parent company, Mazda Motor Corporation, and our affiliates (collectively, the “Mazda Family of Companies”) for the above uses.
• With other users of your MyMazda account. The first person to register for MyMazda with respect to a particular Connected Vehicle will become the primary user of the Connected Services plan for that Connected Vehicle. There can only be one primary user per Connected Vehicle. As a primary user, can you share the Service with another user (“Secondary User”). When doing so, certain Vehicle Data and Personal Information (such as your name and VIN), Secondary User’s name and email address will be collected, used and shared by us to process the invitation of the Secondary User. You may only share your Connected Service plan with a Secondary User, and provide their information to us, if they are your friends and family from whom you have received permission to provide their email address to us. Your Secondary Users may only be friends with whom you have had a direct voluntary two way communications, and with whom it is reasonable to conclude you have a personal relationship considering shared interests, experiences, opinions and other relevant factors, or family members to whom you are related by, marriage, a common-law partnership, or parent-child relationship, and with whom you have had direct voluntary two way communications. Each Secondary User will be sent an email which may indicate that it has been sent on your behalf and may identify you, and invite them to register as a Secondary User. The Secondary User can use the Services after successful registration. You will be able to see the name, app permissions and the complete remote request history initiated by Secondary User. You can deactivate at any time particular Services for the Secondary User such as Vehicle Status, Vehicle Health Report, Remote Control Access, Vehicle Finder and POI Send to Car.
• With our network of independently owned and operated Mazda dealers to inform you of offers, to provide Services and to facilitate service. If you do not indicate a Preferred Dealer, we may use other information to assign one to you (e.g. the dealer you purchased your vehicle from, the dealer you service with, and/or your postal code).
• Third-party service providers who work on our behalf in connection with the uses described in this Privacy Policy.
• Where required or permitted by law we may share your information. For example, we may share your information with law enforcement, courts, administrative bodies or government entities if we are required to do so by applicable law; legal process; in response to government investigations; as may be required for national security; or where we have a good faith belief that disclosure of your information is required or permitted by law or legal process. We may also share your information where we have a good faith belief it is necessary to do so to prevent harm, injury, or loss, and we may use your information to pursue or defend legal actions, even if harm, injury, or loss has already occurred.
• We may transfer any information we have in the event of bankruptcy, or if we or any part of our business merges with or is acquired by a third party, or if any such transaction is proposed.
• With third-parties for educational and research purposes in an anonymized and aggregated format.

STORAGE

We store the Data and your Personal Information for as long as reasonably necessary: for us to provide you with the Services; for us to support all other uses we make of the Data and Personal Information, as detailed in this Privacy Policy; and as required by law or legal process, or as may be needed in the event of anticipated or pending litigation.

SECURITY

We take data and information security seriously. We continuously strive to protect the Data and Personal Information against loss and unauthorized access or use by maintaining and continually updating our formal security program, which employs physical, organizational and technical security practices to protect Data and Personal Information.

Information may be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes described in this Privacy Policy, or as otherwise permitted or required by applicable law.

Even though we have taken steps to help protect the Personal Information in our control, you should know that we cannot fully eliminate security risks associated with Personal Information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

INTERNATIONAL DATA TRANSFERS

Personal Information that we collect may be stored and processed in Canada or any other country in which we or our service providers maintain facilities, including in the United States and Japan. Personal Information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

By using our Services or by providing us with Personal Information, you consent to any such transfer of information outside of your country.

YOUR CHOICES

To summarize, we provide you with choices about what data and information you share with us and how it is used:

1. Review and Update: You may log-into your MyMazda App at any time to review, correct, revise, or update Personal Information you provided to us that is available through the MyMazda App.
2. Connected Vehicle Agreement and Privacy Policy: You must affirmatively agree to our terms and conditions before starting any complimentary period or paid subscription of a Connected Services plan. You can use the MyMazda App to cancel your subscription.
3. Marketing: If you receive promotional emails from us, you may unsubscribe from them using the unsubscribe link we include in these emails. You may also opt-out of our use of your Personal Information for marketing purposes by contacting us using the contact information provided below.
4. Disable Services in the Vehicle: Depending on your vehicle’s capability, you may be able to temporarily disable the Services in your vehicle’s settings.
5. Disable Services: You can also disable your Connected Vehicle in a manner that enables us to re-connect your Connected Vehicle in the future upon your request. By doing so, we may still collect and use limited amounts of Vehicle Data, including a file indicating that the system is on/off, time/date of the last ignition cycle, and total number of ignition cycles, in order to ensure your vehicle can be re-connected in the future. To select this option, you will need to follow these steps: (i) Download the MyMazda mobile app on a compatible smartphone via the Apple App Store or Google Play Store; (ii) Register for a MyMazda account through the app and add your vehicle; (iii) Once your account is setup and vehicle added, please go to the vehicle homepage in the MyMazda app and select the ‘hamburger menu’ (i.e. three vertical lines icon on the top right of the app screen). Tap MyMazda; (iv) Tap My Vehicle; (v) Tap on the more options menu (i.e. three vertical dots icon) on the top right of the app screen; and (vi) Tap on Unsubscribe Connected Services and confirm the pop-up warning message. If you are unable to complete the above for any reason (e.g. you do not have a compatible smartphone) you may need to visit a Mazda dealership to have them assist you. If you wish to fully deactivate your Connected Vehicle then please see ‘Disable TCU’ below.
6. Disable TCU: You can also contact us to permanently deactivate your TCU, thereby disabling our collection of all Vehicle Data. If you choose to deactivate your TCU, you will be unable to subscribe to or continue using any Services, and we may not be able to reactivate your vehicle’s connection if you decide you want the Services in the future.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, or updated. Please note that in some cases, we may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons.

To help protect against fraudulent requests for access to your Personal Information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your Personal Information.

If you would like to exercise this right, please contact us through the contact information below.

YOUR OBLIGATIONS

The nature of our Connected Services means that there may be circumstances where you might let someone else use a product or service that we provide to you (for example, you let someone else drive your Vehicle). It is important that if you do let someone else use one of our products or services that you inform them of this Privacy Policy and of the privacy choices that you have made.

If you sell or otherwise transfer your vehicle, it is your responsibility to delete all information (such as contacts, address look-ups, saved map addresses) from the vehicle’s system and contact us to transfer or cancel your account. This is important to help protect your account and your information, and that of the new owner. If you do not delete this information, it may remain on the vehicle’s system and may be accessible to future users of the vehicle. For example, we may continue to send reports or other information about the vehicle or account to the Primary User’s contact information currently on file with us, and the previous owner may be able to continue to use the services in respect of the Connected Vehicle. SUCH CONTINUED USE OF THE SERVICES BY THE PREVIOUS OWNER IS STRICTLY PROHIBITED. For instructions on how to delete information from your vehicle’s system, please refer to your vehicle owner’s manual. If you do not inform us of any sale or transfer of your vehicle, we are not responsible for any privacy related damages or claims you or anyone else may suffer. If you sell or transfer your Connected Vehicle, you must cease using any Services in respect of such vehicle. If a new owner opens an account in respect of a Connected Vehicle, any prior accounts in respect of such Connected Vehicle may be terminated.

CHILDREN'S PRIVACY

We do not knowingly target or collect any information from children under the age of 13. If you are above 13, and above the legal driving age where you reside, but under the age of majority, you must have the consent of your parent/legal guardian to our Privacy Policy to use the Services.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time by posting a new version to our website or in another manner that is likely to come to your attention. We will ask for your consent to any changes as required by applicable law.

CONTACT US

If you have any questions or concerns about this Privacy Statement, please contact our CUSTOMER EXPERIENCE CENTER.

You may also contact our Privacy Office, if you have any questions or complaints regarding our privacy practices, or if you would like to access or request correction of your personal information:

Mail: Mazda Canada Inc., 55 Vogell Road, Richmond Hill ON, L4B 3K5, Attention: Privacy Office

Email: PRIVACY@MAZDA.CA

Last updated: October 21, 2021