Privacy Policy of KawasakiSPIN

Kawasaki Motors, Ltd. （”we”, ”us” and ”our”） is pleased that you are visiting our Internet pages and our mobile applications (also referred to collectively as “Online Offer”) and that you are interested in our company and our products.

We view the protection of your private sphere during the processing of data and the security of all business data to be important considerations which we take into account in our business processes. We process data collected during your visit to our online offers on a confidential basis and only in compliance with the statutory provisions. Data protection and information security are part of our company policy.

This privacy policy is prepared in English and translated into other languages. If there is a difference between the English version and other language versions, the English version shall govern.

1. Data controller and contact

Kawasaki Motors, Ltd. is responsible for the processing of your data; exceptions are explained in this privacy policy.

Our contact details are as follows:

Kawasaki Motors, Ltd.
1-1, Kawasaki-cho, Akashi, Hyogo, Japan, 673-8666
E-Mail: kawasaki-spin@rideology-the-app.com

2. Children

The KawasakiSPIN is not intended for children under the age of 16.

3. Processing of customer related data

3.1 Categories of data processed

　Communication data (e.g. IP address).

3.2 Processing principles

Some of the data that we process is information which is not readily attributable to a specific individual person. With regard to this information, we do not have any interest in the identification of a natural person, nor do we have the necessary knowledge or the legally permissible means to establish a reference to an individual person. We can use this non-personal data to improve our products, for example.
We only collect, process and use customer related data if there is a statutory basis to do so or if you have granted us your consent in this regard; in the course of a registration, for example.

3.3 Purposes of the processing and legal basis

We and the service providers commissioned by us will process your customer related data for the following processing purposes:

3.3.1 To provide the functions of KawasakiSPIN

Legal basis: The fulfillment of the contract.

3.3.2 For the detection/elimination of faults and for security reasons

Legal basis: The fulfillment of our statutory obligations in the area of data protection as well as a justified interest in the elimination of faults and the security of KawasakiSPIN.

Further information: To use KawasakiSPIN, it is not necessary for you to enter your name and/or other contact data, for example. Of course, you can provide us with this data voluntarily, for example, by email as part of a support request if you require help and support with the app. If you do this, this data will be transmitted in encrypted form and stored temporarily on the servers of Kawasaki Motors, Ltd. For the purpose of troubleshooting on our part, technical data such as crash reports may be passed onto third parties (e.g. external development partners) in anonymous form. No conclusions can be drawn about your person from this technical information.

3.3.3 Safeguarding and defense of our rights

Legal basis: Legitimate interest on our part in the assertion and defense of our rights.

3.3.4 Your inquiry to Kawasaki Motors, Ltd.

Legal basis: Performance of the contract or completion of pre-contractual measures; justifiable interest on our part in the consideration and clarification of inquiries made by our customers.

3.3.5 Consent

If we wish to process or use customer related data in the future for purposes other than the fulfillment of the contract and this is not permitted by law, we will make this dependent on your prior consent. You can actively give your consent in good time, i. e. before the respective collection, processing and use of your customer related data. This can take place during the installation or the start of the app or at a later point in time during the activation of additional functions or services. We consider the following confirmatory actions, for example, to be consent:

4. Collection and processing of customer related data by KawasakiSPIN

Depending on your choice of smartphone settings, the following customer related data are processed by KawasakiSPIN to enable the specialist functions of KawasakiSPIN (apps integrated in the KawasakiSPIN Launcher, such as the calendar, contacts, music, telephone, vehicle finder):

4.1 Integrated "Contacts" app

If you activate access to your stored telephone contacts, KawasakiSPIN will transfer them to the integrated "Contacts" app and save them locally only. If you want to navigate to an address which is stored in your contacts, you can start the navigation process directly from the contacts. An address is then transferred to the navigation app installed on your smartphone (if available). Kawasaki Motors, Ltd. is not responsible for third-party apps that access and use this position data. Please refer to the privacy policy of the provider of your navigation app. You can deactivate access to your telephone contacts at any time.

4.2 Integrated “Calendar" app

If you activate access to your stored calendar entries, KawasakiSPIN will transfer these to the integrated “Calendar" app and save them locally only. If you want to navigate to an address which is stored in a calendar entry, you can start the navigation process directly from the KawasakiSPIN calendar. An address is then transferred to the navigation app which is installed on your smartphone (if available). Kawasaki Motors, Ltd. is not responsible for third-party apps that access and use this position data. Please refer to the privacy policy of the provider of your navigation app. You can deactivate the access to your calendar entries again at any time.

4.3 Integrated “Music” app

If you activate access to your stored Music entries, KawasakiSPIN will transfer these to the integrated “Music" app and save them locally only. If you use music streaming services (e.g. Apple Music), KawasakiSPIN gains access to the media library of the respective streaming service. No transfer takes place from KawasakiSPIN to Kawasaki Motors, Ltd. or third parties. You can deactivate the access to your music library again at any time.

4.4 The telephone module of your smartphone

If you activate access to the telephone module of your smartphone, KawasakiSPIN saves it locally only. No transfer takes place from KawasakiSPIN to Kawasaki Motors, Ltd. or third parties. You can deactivate the access to the telephone module again at any time.

4.5 Location data of your smartphone and the vehicle to which the smartphone is connected

If we wish to process or use position data in the future for purposes other than the fulfillment of the contract and this is not permitted by law, we will make this dependent on your prior consent. You can actively give your consent in good time, i. e. before the respective collection, processing and use of your position data. This can take place during the installation or the start of the app or at a later point in time during the activation of additional functions or services. We consider the following confirmatory actions, for example, to be consent:

4.5.1 Vehicle finder

As a location based service, the KawasakiSPIN includes the vehicle finder option. To be able to offer you these functions, provided that you have activated this function for the KawasakiSPIN, we will log the GPS position transmitted by your smartphone after the parking process has been completed. Your parking position will then be stored locally in the KawasakiSPIN, but it will not be transferred to us or shared with other third parties. In this context, we expressly point out that we do not create any detailed motion profiles of individual users. You can deactivate and reactivate the GPS function in the operating system settings of your telephone, temporarily deactivate it in pause mode, or withdraw permission from the KawasakiSPIN to use the GPS function of your telephone.

4.5.2 Location for third-party apps

If you activate access to the location in KawasakiSPIN, KawasakiSPIN provides the possibility for KawasakiSPIN compatible third-party apps to use the location coordinates of the vehicle with which your smartphone is connected to enable the full functionality of such third-party apps. Kawasaki Motors, Ltd. is not responsible for third-party apps that access and use this location data. In this respect, please refer to the privacy policy of the provider of the respective third-party app. If you do not want KawasakiSPIN to pass on the vehicle location to individual apps, you must deactivate the location access of the respective app in the settings of your smartphone.

4.6 IP address/device ID for the technical evaluation of KawasakiSPIN

Upon the installation of the KawasakiSPIN, an anonymous user ID is created. On smartphones with an iOS operating system, a pure random number is created for this purpose; on smartphones with an Android operating system, the Instant ID (or GUID）of your smartphone is also used for this purpose. This user ID is used exclusively when using KawasakiSPIN and only if your smartphone is connected to the Internet while KawasakiSPIN is running in order to activate the latest KawasakiSPIN-compatible apps, to provide you with KawasakiSPIN news and, after active approval, to analyze the user behavior (in particular the stability and frequency of use of the individual apps). The transmission of your IP address is technically indispensable for establishing contact with our servers. No conclusions can be drawn about your person from this user ID.

5. Collection and processing of technical data

In the following you will find an overview of the technical data to be collected and processed by KawasakiSPIN. We also collect statistical information about the use of the KawasakiSPIN to make it more user friendly and to measure its range. For this purpose, we use the analysis tools described in this section.

5.1 Installation data

The data for the installation of the KawasakiSPIN are only saved locally on your smartphone. No conclusions can be drawn about your person from this information.

5.2 Technical vehicle data

KawasakiSPIN supports the possibility for third-party apps to be able to access specific types of technical vehicle and environmental data (e.g. vehicle movement information, information about the technical equipment of the vehicle and its condition, information about the physical environment of the vehicle and the environmental conditions).

This technical information and data is transmitted without a vehicle identification number.

Kawasaki Motors, Ltd. is not responsible for third-party apps that access and use the above technical data.

The following technical data are processed by KawasakiSPIN and can be transferred to Amazon Web Services Germany (see Section 6.2):

The use of this technical information and data allows us to statistically analyze the use of KawasakiSPIN and/or third party materials and to provide product support, technical administration and other services (including customer relationship management) in connection with KawasakiSPIN.

5.3 Connection with Kawasaki APP "RIDELOGY THE APP KawasakiSPIN"

Depending on your operating of smartphone, you can select to connect the KawasakiSPIN with the Kawasaki APP "RIDELOGY THE APP KawasakiSPIN". With this connection, you can operate the Kawasaki APP "RIDELOGY THE APP KawasakiSPIN" while riding. For more information on the handling of your data, please refer to the privacy policy of "RIDEOLOGY THE APP KawasakiSPIN".

6. Disclosure of data

6.1 Disclosure to other data controllers

In general, we shall only transfer your data to other controllers if this is required for the performance of the contract or if the third party has an overriding legitimate interest in the disclosure or if you have provided your consent thereto. Third parties can also be other companies in the Kawasaki Motors, Ltd. Group. To the extent that data is transferred to third parties on the basis of a legitimate interest, this is explained in this privacy policy. Furthermore, data can be transferred to other data controllers to the extent that we are obliged to do so due to statutory provisions or due to enforceable official and/or judicial orders.

6.2 Disclosure of data to service providers

We commission external service providers with the provision of data hosting and hotline services. We have chosen these service providers carefully and monitor them on a regular basis, in particular their careful treatment and protection of the data stored with them. We oblige all service providers to maintain confidentiality and to comply with the statutory regulations. Service providers can also be other companies in the Kawasaki Motors, Ltd. Group. However, we can also commission service providers outside the Kawasaki Motors, Ltd. Group who we can assume will maintain a high standard of data protection and who are able to demonstrate this to us.

6.3 International transfers of customer related data

Because of the international nature of our business, we may need to transfer your data within companies in Kawasaki Motors, Ltd. Group, and to third parties as noted in this privacy policy, in connection with the purposes set out in this privacy policy. The storage as well as the processing of your data as described above may require that your data are ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence.
We may transfer your data to a third country. In such case, we will take appropriate measures such as obligating the third party to conduct appropriate security management through a data protection agreement.
Regarding data of residents in European Economic Area, we may also disclose data to recipients based outside the European Economic Area, in so-called third countries. In this case, before the disclosure, we shall ensure that the recipient either has an appropriate data protection level in place (on the basis of an adequacy decision by the EU Commission for the country in question or the agreement of so-called EU Standard Contractual Clauses of the European Union with the recipient, for example), or that you have granted your consent to the disclosure.

7. Duration of storage; retention periods

As a matter of principle, we only store your data for as long as it is necessary to provide the functions of KawasakiSPIN within the scope of your use (including the data that you provide to us voluntarily within the scope of a possible support request). In all other cases, we shall delete your data with the exception of data which we have to keep for the fulfillment of legal obligations or if we are entitled to the continued storage for the enforcement of our legal claims.

8. Collection of data or further processing by app store

The transfer of data such as user name, email address and individual device identification number to an app store (such as Google Play by Google, App Store of Apple, Galaxy App Store of Samsung) in the course of downloading the respective application shall not constitute the collection of data on our part and is outside our scope of responsibility. As the data controller, we do not have any influence over this collection of data or the further processing by the app store.

9. External links

The KawasakiSPIN may contain links to the Internet pages or online offers of third parties. After clicking on the link, we do not have any influence over the collection, processing or use of any personal data transferred to the third party by clicking on the link (such as the IP address or the URL of the page which contains the link) as we naturally have no control over the behavior of third parties. We do not assume any responsibility for the processing of such personal data by third parties.

10. Security

Our employees and the service providers acting on our behalf are obliged to maintain confidentiality and comply with the provisions of the applicable data protection laws.

We shall take all of the required technical and organizational measures in order to ensure an appropriate level of protection and to protect your data that we manage against the risks of accidental or unlawful destruction, manipulation, loss, alteration or unauthorized disclosure and/or unauthorized access. Our security measures are subject to continuous improvement according to technological developments.

11. Your rights

Please use the details set out in the “Data controller and contact” section to assert your rights (see Section 1). When doing so, please make sure that we are able to clearly identify you.

11.1 Right to information and right of access:

You are entitled to obtain information from us on the processing of your data. For this purpose, you can assert a right of access regarding your data that we process.

11.2 Right of rectification and erasure:

In addition, you can require us to rectify incorrect data and – to the extent the statutory provisions are fulfilled – to complete or erase your data.

This does not apply to data required for accounting and bookkeeping purposes or that is subject to statutory retention requirements. To the extent that the access to such data is not required, its processing will be restricted (see below).

11.3 Restriction of processing:

Insofar as the statutory requirements are fulfilled, you can ask us to restrict the processing of your data.

11.4 Data portability:

You are furthermore entitled to receive data with which you have provided us in a structured, commonplace and machine-readable format or – to the extent technically feasible – to request the transfer of such data to a third party.

11.5 Right to object

11.5.1 Case-by-case right to object

If we process data on the basis of an overriding legitimate interest as set out in this privacy policy, you have the right to object to this processing at any time for reasons that arise from your particular situation.

We will then cease processing your data, unless we can – in accordance with the statutory provisions – demonstrate compelling legitimate grounds for the further processing which override your interests, rights and freedoms or the further processing serves the assertion, exercising or defense of legal claims.

11.6 Right to object

If you have given us your consent to the processing of your data, you can withdraw it at any time with effect for the future. A withdrawal shall not affect the lawfulness of the data up until the time of the withdrawal.

11.7 Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint at a data protection authority. To do this, you can contact the data protection authority which is competent for your place of residence or your federal state or the data protection authority with responsibility for us.

12. Changes to the privacy policy

We reserve the right to amend our security and data protection measures to the extent that this is necessary due to technological advancements. In these cases, we will also adjust our data protection information accordingly. Therefore, please note the respective current version of our privacy policy.

13. Contact

If you would like to contact us or to assert your rights and for suggestions and complaints regarding the processing of your data, please use the address details provided in the “Data controller and contact” section.



Last updated: 15th, February, 2022