PRIVACY AND PROTECTION
Welcome to our Toyota Entune™ 3.0 Privacy and Protection section. This section is intended for Toyota owners whose vehicles are equipped with the technology to electronically manage, transmit and exchange information about our Toyota Entune™ 3.0 service and assistance benefits.
Connected Vehicle Services Privacy and Protection Notice
This Connected Vehicle Services Privacy and Protection Notice (this “Notice”) is intended to clearly explain Toyota de Puerto Rico Corp.’s (“TdPR”, “We” or “Us”) connected vehicle data collection, use and handling practices for certain Toyota model motor vehicles.
When you purchased or leased your Toyota vehicle (“Vehicle”) you had the opportunity to subscribe to receive a series of connected vehicle services (such as live 24-hour navigation assistance, integration of popular mobile apps and emergency services at the press of a button) which are designed to offer TdPR customers peace of mind, convenience and infotainment in one comprehensive package (the “Connected Vehicle Services” or “Services”). We at TdPR take your privacy seriously in the design, development and implementation of our Connected Vehicle Services, and in the collection of data that allows Us to provide you with the benefits of these Services.
The Information We Collect
When your Vehicle is equipped with Connected Vehicle Services, TdPR may collect (i) data that identifies you as an individual (such as your name, address, phone number, email address or any other information you may choose to share with Us) (“Personal Information”), and (ii) any data generated or recorded by the computers in your Vehicle (such as location data, and voice recordings) (“Vehicle Data”).
If you do not want to send Us your Personal Information and Vehicle Data, you must contact TdPR at the addresses and/or phone numbers provided below to deactivate this functionality. The various systems and components of your Vehicle are controlled by in-vehicle computers that communicate with each other and record data; if your Vehicle is equipped with Connected Vehicle Services technology the recorded data will be transmitted to Us.
Use of Information We Collect
TdPR shall use your Personal Information and Vehicle Data (collectively the “Client Information”) for the purposes of providing you with the Connected Vehicle Services and for any other related services or purposes, such as to improve vehicle safety; develop new vehicles and features, prevent or detect fraud or misuse of Services, comply with law or legal process, and respond to requests from Toyota Credit de Puerto Rico to address accounts in default.
Location Data. Under certain specific circumstances, your Vehicle may send your location data (meaning an electronic signal with your latitude and longitude at a particular point in time) to our Response Center, which may allow us to provide you with emergency, car collision, or roadside assistance, and stolen or missing Vehicle location services. We record and transmit your location data when you contact Us for emergencies, roadside assistance stolen or missing Vehicles and destination services. Furthermore, Global Positioning System (“GPS”) navigation in your Vehicle is equipped with a traffic feature that automatically collects and transmits your location data, travel direction and speed through the GPS technology, to support HD traffic and weather information available in your Vehicle. This type of information is not tied to your VIN or Personal Information.
Sharing of Information
We may share your Client Information with:
Emergency responders and roadside assistance providers to provide you with emergency or roadside assistance.
Toyota Credit de Puerto Rico to, among other things, verify fraud, repossess in the event of a breach of your lease or finance contract and/or to support vehicle improvement.
Toyota Motor Corporation (TdPR’s parent company) to support safety, research, analysis and product development efforts.
Third Party Service Providers like, for example, Sirius XM Connected Vehicle Services Inc. We contractually bind any third parties acting on our behalf to handle your Personal Information in accordance with TdPR’s standards and as described in this Notice.
Law Enforcement. We DON’T share your Client Information with law enforcement unless We are required to do so by law or legal process, in response to government investigations, as may be required for national security, or where We believe necessary to prevent harm, injury or loss.
We DON’T share your Client Information at any time with data resellers, social networks and ad networks.
TdPR may sometimes share anonymized and aggregated Vehicle Data in analytic reporting with federal and state regulatory agencies and non-profit organizations for the purpose of education and research related to environmental and energy issues, advanced technologies and usage analysis.
In general, We store your Client Information for seven (7) years after expiration of your subscription for Connected Vehicle Services, though some information may be stored for longer periods of time. For example, vehicle location data is stored from the time a client contacts Us until seven (7) years after the expiration of their subscription to emergency, roadside assistance, stolen or missing vehicle, and/or destination services. Likewise, voice recordings of calls made to the TdPR Response Center from a Vehicle may be recorded and stored for two (2) years to support requests from customers and law enforcement. However, please note that sometimes law, legal processes or litigation may require TdPR to keep your Client Information for longer periods of time.
We take information security seriously. We continuously strive to protect your Client Information by employing our industry’s best practices through our formal security program (the “Security Program”). Our formal Security Program includes:
System Defenses. We designed the Connected Vehicle Services technology in your Vehicle to resist security vulnerabilities. We employ layers of defense to drive strong safeguarding practices, including, code and design reviews, regularly scheduled security testing, firewalls, intrusion detection systems, and encryption.
Private Network. When your Vehicle Data is transmitted from your Vehicle to Us, We use a dedicated private wireless network. In addition, your Vehicle is designed only to respond to commands from Us and only for those available features We provide including vehicle location.
TdPR reserves the right to, from time to time, modify its Security Program and/or choose the Client Information storage and processing methods, as it may deem necessary or advisable, at its sole discretion. TdPR cannot completely ensure or warrant the security of any information transmitted to Us by you or your Vehicle. Your use of your Vehicle’s Connected Vehicle Services is at your own risk. You have the option to deactivate your Connected Vehicle Services by contacting Us and requesting deactivation. If you choose to deactivate your system, you may lose features such as Safety Connect, including Automatic Collision Notification.
We give you choices about what data you share with Us. TdPR customers may:
Opt-in/Opt-out. You may opt-in or opt-out of receiving marketing notifications. If you opt-out, you will not receive any marketing notification related to your account.
Review and Update. You may also review and update your Personal Information at any time by contacting Us at the addresses and/or phone numbers provided below.
Deactivation. When you buy a Vehicle equipped with Connected Vehicle Services, data collection is active. However, you may deactivate Connected Vehicle Services at any time by contacting Us at the addresses and/or phone numbers provided below, and We will no longer collect your Client Information.
When you purchase a Vehicle equipped with Connected Vehicle Services, use the Services in your Vehicle, agree to a Subscription Service Agreement or to an End User License Agreement you are consenting to the electronic collection of your Client Information and use thereof as provided for in this Notice.
If you have questions or concerns about this Notice or would like to deactivate your Connected Vehicle Services or update your Personal Information, please contact Us by calling or writing to Us at:
1064 Muñoz Rivera Avenue
Rio Piedras, PR 00927
To learn whether your Toyota vehicle is equipped with the Connected Vehicle Services and whether those Services are active or inactive please contact Us.
Applicability. This Notice DOES NOT apply to data collection or handling practices unrelated to Connected Vehicle Services on Toyota website, or on sites that are not owned, operated or controlled by TdPR.
This Notice is effective as of November 20th, 2017.