Effective July 20, 2020
Additionally, CalAmp Wireless Networks Corporation (“CalAmp” or “LoJack”) is the provider of the LoJack services that power the Services, defined below. As such, certain portions of this Policy such as Types of Data and Collection Methods, Collection Purposes, Use of Data, Where We Store and Process Data, Disclosures of Personal Data, Your Choices, Retention, and Security describe actions by LoJack on Pioneer’s behalf.
This Policy applies to the websites, products, services, software, or applications, including the rDrive mobile application (“rDrive App”) and certain related Pioneer products, services, software and applications, on which we post a direct link to this Policy or refer to within this Policy (collectively the “Services”). This Policy covers only data collected through the Services and not any other data collection or processing, including, without limitation, data collection practices of other services that maintain their own, separate privacy policies. Occasionally, we refer to this Policy in relation to surveys and special-purpose web pages, for examp1e, our Careers web pages; under such circumstances, this policy applies as modified in the particular notice or consent request (e.g., with respect to types of data collected or purposes of collection).
Types of Data and Collection Methods
We collect a variety of personal data through the means described below. You have choices about the data we collect. When you are asked to provide data to us, you may choose not to. But if you decline to provide data, your ability to use the applicable Services may be diminished or restricted.
- Data you submit. We collect your name, email address(es), mailing address(es), telephone number(s), Vehicle Identification Number (VIN), and other data when you request information from us, register, purchase or subscribe to a Service, or otherwise intentionally send or request an rDrive dealer to send us such information. In connection with chargeable Services, we will also collect payment information (e.g., credit card number and related verification data), phone number, and billing and shipping addresses. Additionally, as part of the CrashBoxx™ Instant Crash Alerts, you may choose to provide the name and contact information of a person to be contacted in the event of a collision.
- Data we automatically collect from our websites. When you visit the rDrive website located at https://rdrivebypioneer.com (“rDrive Website”), certain information is automatically collected by Google LLC (“Google”) as part of Google Analytics, as explained below under “rDrive Website Analytics.” Such information may include the Internet Protocol (IP) address of the computer or device you use to connect to the rDrive Website, domain name, country location, other computer/device and connection information such as browser type and version, operating system, entry and exit points/pages, date/time of access, the areas or pages of the rDrive Website you visit, the amount of time you spend viewing the rDrive Website, the number of times you return, and other click-stream data.
- rDrive App: Our rDrive Powered by LoJack mobile application Service includes a Pioneer telematics device installed on a vehicle that communicates information to the rDrive App, including: CrashBoxx® Instant Crash Alerts; Tripwire™ Early Warning; stolen vehicle location assist; setting virtual boundaries (notifications when a driver arrives at their destination; 'Where's My Car?' (which pinpoints the vehicle on the map); and setting speed alerts. When the telematics device is installed in your car, information is collected about your vehicle (including make, model, color, year and vehicle identification number, speed, and location. Information that identifies your vehicle and other personal information may be shared when it is necessary to provide various rDrive Services, such as alerting emergency personnel of your location if a crash is detected, or helping authorities locate your vehicle if you report it stolen. rDrive information may also be used on its own or in combination with other information about you to determine aggregate insights about our users. Information that identifies your vehicle and other personal information will be shared when it is necessary to provide the Services.
- Children's Privacy. Our Services are not directed at children under the age of 16. We do not intentionally or knowingly collect personally identifiable information from children under 16. If you are under 16, please do not provide any personal data to us.
Collection Purposes, Use of Data
We collect and process personal data about you with your consent and/or as necessary to provide the Services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests. The purposes for which we collect and use data include:
- To respond to the request that you sent us such as your request for information, or your request to purchase or subscribe to a Service;
- To provide, manage, maintain, and secure the Services you request;
- To operate and improve our business, including to administer, protect, and improve our Services and our systems, to develop new products and services, and for other internal business purposes;
- To better understand the preferences of the users of our Services, compile aggregated statistics about usage of our Services, and help personalize your experience of our website and Services;
- To provide you with information about our technologies, Service releases, news, and other communications; and
- Any other use we describe in this Policy or at the point where we collect the data.
To achieve these purposes, and to the extent permitted by applicable law, we may combine the various types of data that we collect from different sources.
rDrive Website Analytics
A third-party analytics tool called Google Analytics uses analytics data sent to Google’s (or its wholly-owned subsidiaries’) servers from a Google Analytics software agent through cookies, pixel tags or other tools placed on the rDrive Website. Information collected through Google Analytics is used by Google to provide Pioneer with aggregated, non-identifiable reports on rDrive Website usage and viewing statistics for videos embedded through Google’s YouTube service. Pioneer uses these reports to understand how visitors use the rDrive Website, diagnose problems, and make improvements to the rDrive Website, products and services. In this regard, Pioneer is the controller for the processing of your information.
For information on Google’s practices on data privacy and security in connection with Google Analytics and the privacy controls offered by Google, please visit https://policies.google.com/technologies/partner-sites.
Where We Store and Process Data
We store and process data in the United States and on servers around the world, including, without limitation, the European Economic Area. Wherever we store or process personal data pursuant to this Policy, we take measures to ensure that the data is processed in accordance with this Policy and in compliance with applicable law.
Disclosures of Personal Data
We access your personal data within Pioneer and LoJack and share data with third party vendor or service providers that process the data on our behalf for the purposes set forth in this Policy. We may also offer training or other services to the employees and workers of our dealers. In such cases, we may share data relating to the use of our training and other services with the dealers for their business use. We may also share your data as required by law or in the interest of protecting or exercising our or others' legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Finally, we may also share your personal data where you have granted us permission.
- Opt-In/Out. We offer you the ability to opt-in or opt-out of data collection, use, or sharing. If you wish to opt-out, please contact us as described in the Contact Us section below. Please note that the Services cannot be used without the collection, use and sharing of certain data such as name, contact information, and vehicle data collected through the Pioneer telematics device. Any request to opt out of such collection, use or sharing will require that you discontinue using the Services and we delete your rDrive account.
- If you would like to access your personal data that we maintain, or the personal data you have submitted is no longer accurate, current, or complete, and you wish to update it, please contact us as described in the Contact Us section below. If you need to correct your personal data, we reserve the right to use data obtained previously to verify your identity.
- Do Not Track. We do not currently respond to "Do Not Track" ("DNT") signals sent by web browsers. A uniform standard has not yet been adopted to determine how DNT signals should be interpreted and what actions should be taken by websites and third parties that receive them. However, you may use a variety of other means of controlling data collection and use, including cookie controls in your browser settings and the personalized advertising controls described in the Cookies section above.
We retain personal data while your account is active, or as needed to provide you Services. We will delete personal data within a reasonable time after the data is no longer necessary for the business purpose for which it was collected. We will, however, retain and use personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Transmissions over the Internet are never 100% secure or error-free. However, we take reasonable steps to protect your data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. It is your responsibility to safeguard your passwords and User IDs and to notify us using one of the Contact methods listed below if you ever suspect that your password or User ID for one of our Services has been compromised. You are solely responsible for any unauthorized use of our Services conducted via your password and User ID.
We reserve the right to change, modify, add, or remove portions of this Policy at any time, but will alert you that changes have been made by indicating on the Policy the date it was last updated. If we change the Policy in a material way, we will provide appropriate online notice to you at least 30 days in advance and/or obtain your express consent as required by law. When you visit our websites or use our Services, you are accepting the current version of this Policy. We recommend that users revisit this Policy on occasion to learn of any changes.
Contact Us for More Information
To contact us, send us an email at email@example.com, call us at 1-800-421-1603, or write to us at Pioneer Electronics (USA) Inc., Attention: rDrive Team, 2050 W. 190th Street, Suite 100, Torrance, CA 90504.
Privacy Notice for California Residents
Effective Date: July 20, 2020
WHAT PERSONAL INFORMATION DOES PIONEER COLLECT?
We collect information, from both online and offline sources, which identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (the CCPA defines this as “personal information”). This definition of personal information is very broad and can encompass many different types or categories of information. During the 12 months preceding the Last Update of this Notice, Pioneer has collected the following categories of personal information:
- Personal Identifiers – such as your name, address, email addresses, telephone numbers or other similar identifiers. Pioneer does not collect social security, credit card or driver’s license numbers.
- Personal Information categories listed in the California Customer Records Act (Calif Civil Code Section 1798.80(e)) – such as your name, signature, address and telephone number. Some personal information in this category may overlap with other categories.
- Commercial Information – such as Pioneer products or services purchased and your car’s Vehicle Identification Number (VIN).
- Internet Activity – such as website usage data and user ID & password.
- Geolocation Data – such as your car’s location when connected to Pioneer’s rDrive service using a Pioneer Vehicle Telematics Device.
Note that personal information under the CCPA specifically excludes:
- Publicly available information obtained from government records
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act or clinical trial data.
- Information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act and the Drivers Privacy Act of 1994.
- De-identified or aggregated consumer information
Any personal information which is specifically excluded from the application of the CCPA will not be subject to this Notice. This means, for example, that Pioneer is not obligated to disclose personal information about California residents (i) which Pioneer obtained from publicly available government records, or (ii) if that information is otherwise protected from disclosure under HIPAA or FCRA. In addition, information which Pioneer may have that has been anonymized or aggregated such that it no longer can be classified as personal information is also not subject to this Notice.
Pioneer will not collect categories of personal information from you for any purpose other than what we have described in this Notice. In the event that we intend to collect additional categories of personal information in the future, or use existing categories for additional purposes, we will provide an updated Notice at or before the time of collection.
HOW DOES PIONEER COLLECT PERSONAL INFORMATION?
We obtain each of the categories of personal information listed above from the following categories of sources:
- Directly from you – such as when you set up an online account at Pioneerelectronics.com to register Pioneer products you have purchased, or to receive email news about Pioneer products and services, or when you contact our call center, or when you register for Pioneer rDrive™ Powered by LoJack®.
- Indirectly from you through automatic information – if you use rDrive, through your Pioneer Vehicle Telematics Device and the rDrive mobile app.
- Directly from a third-party provider of services to us – such as from our transaction processor when you purchase a Pioneer product online.
HOW DOES PIONEER USE PERSONAL INFORMATION?
We use or disclose the personal information from each of the categories we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided your personal information to us. For example, if you provide your name and telephone number to our call center, we will use that information to respond to your inquiry. If you provide your personal information to register your product with us, we will use that information to process your request. We may also save your personal information to facilitate new product purchases or to process product returns.
- To provide you with information, products and services that you may be interested in receiving.
- To provide you with customer support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court orders or governmental regulations.
- As described to you when collecting your personal information.
We will not use the personal information we have collected from you for any purpose other than what we have described in this Notice. If we intend to use your personal information for a purpose that is not described in this Notice, we will notify you of this new use and obtain your explicit consent to use it for the new purpose.
HOW DOES PIONEER SHARE PERSONAL INFORMATION?
Personal information is either shared by Pioneer with selected fulfillment companies or collected directly by those companies (“service providers”) solely to fulfill your requests – such as for product purchases/shipments and to provide consent-based marketing support. Each of these service providers is bound by a contract with us which describes the purpose of the agreement and requires the third party to (i) keep the personal information confidential, (ii) implement reasonable security measures relating to the personal information and (iii) not use the personal information for any purpose other than to fulfill the purpose of the agreement. No third parties with whom Pioneer shares personal information are entitled to sell that personal information.
The chart below illustrates the categories of personal information we collect (column A), the category of source from which that personal information was collected (column B), our business purposes for collecting that personal information (column C) and the category of third party with whom Pioneer shares personal information (column D).
Category of personal information collected by Pioneer
Category of source from which Pioneer collected that personal information
Business purpose(s) for which Pioneer collected that personal information
Categories of third parties with whom Pioneer shares that personal information
Personal Identifiers such as name, email address, home address, and phone number
directly from you, or indirectly from you, for example through authorized Pioneer dealers or authorized service companies
To fulfill consumer purchases, deliver communications about Pioneer and its products, record product registrations, respond to customer service inquiries, provide Pioneer services (including rDrive), administer rebates, handle consumer claims
Service providers that provide support or coverage to Pioneer for the listed business purposes
Emergency services agencies (rDrive only)
Personal Information Categories subject to Calif Customer Records Act
indirectly from you via Pioneer’s online shopping platform service provider
To fulfill your direct purchases from Pioneer
Service providers that provide support for purchase fulfillment
Commercial Information such as products purchased and Vehicle Identification Number (VIN)
directly from you, or indirectly from you through authorized Pioneer dealers, authorized service companies, or third-party service providers
To fulfill product orders, purchases and shipping/fulfillment/repair/ marketing, provide Pioneer services such as rDrive, communicate with you, and to improve our services
Service providers that support the listed business purposes, and business partners
Emergency services agencies (rDrive only)
Internet Activity such as website usage data and user ID and password
directly from you
To provide services, websites, and user accounts to you, improve them, understand user preferences, compile aggregated statistics about their usage, and enhance the user experience
Service providers that support the listed business purposes
Geolocation (rDrive only)
Indirectly from the Pioneer telematics device installed in your vehicle
To provide the rDrive services to you and compile aggregated statistics about usage of the rDrive services
Service providers that support the listed business purposes, including those to which you instruct us or our service provider to send this information
Emergency services agencies (rDrive only)
DOES PIONEER SELL PERSONAL INFORMATION?
No. Pioneer does not and will not sell the personal information we have already collected about you unless we obtain your explicit consent to do so.
WHAT ARE MY RIGHTS REGARDING ANY PERSONAL INFORMATION OF ME THAT PIONEER MAY HAVE?
The CCPA grants to California residents the following specific rights relating to their personal information:
- Right to Know About Personal Information Collected, Used, Disclosed or Sold
You have the right to request that we disclose to you certain information about our collection and use of your personal information over the last 12 months. Upon our receipt of a verifiable personal information request, we will disclose to you:
- The categories of personal information we collected about you
- The specific pieces of personal information we collected about you
- The categories of sources of the personal information we collected about you
- Our business use of the personal information we collected about you
- The categories of personal information we disclose for a business use
- The categories of third parties with whom we share your personal information
- Whether we have sold your personal information
- Deletion Request Rights
You have the right to request that we delete all personal information that we have collected from you and retained, subject to certain exceptions. Upon our receipt of a verifiable personal information request (on which you have checked the box indicating you wish to have your personal information deleted), and confirmation from you of that deletion request, Pioneer will permanently and completely erase (and direct our service providers to erase) your personal information from all of our records. Your personal information may reside in our backup systems for a limited period of time until overwritten as part of the backup process.
There are certain exceptions to our obligation to comply with deletion request rights. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected your personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise to perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity or prosecute those responsible for such activities
- Debug product to identify and repair errors that impair existing intended functionality
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law
- Comply with the California Electronic Communications Privacy Act
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
- Comply with a legal obligation
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it
Pioneer will retain copies of all deletion requests pursuant to California Civil Code section 1798.105(d).
- Personal Information Sales Opt-Out & Opt-In Rights
For those businesses that sell your personal information, you have the right to direct them not to sell that information. As noted above, Pioneer does not sell your personal information, so these Opt-Out and Opt-In rights do not apply to you.
- Non-Discrimination Rights
You have the right not to be discriminated against as a result of exercising any of your rights listed above. This means that Pioneer will not discriminate against you for exercising any of your CCPA rights, including:
- Denying you goods or services
- Charging you a different price for goods or services, including through granting discounts or other benefits, or imposing penalties on you
- Provide you a different level or quality of product or services.
- Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
HOW DO I EXERCISE MY RIGHTS UNDER THE CCPA?
Pioneer provides the following methods by which California residents can exercise their rights under the CCPA:
- If you have an existing account with Pioneer, log in using the “My Account” link on the Pioneer homepage. Begin a Personal Information Request (PIR) by following the prompts under “California Consumer Privacy Act Request.” If you do not already have an account, use one of the next methods.
- Go online to pioneerelectronics.com/privacy and follow the prompts for submitting a PIR; or
- Call our dedicated CCPA toll-free number: 1 (800) 421-1613
Only California residents, or a person authorized to act on behalf of a California resident, may submit a PIR related to their personal information. Guardians of California residents who are minors are also entitled to submit a PIR on behalf of their minor children. If you use an authorized agent to submit a PIR on your behalf, we will require (i) a valid, California power of attorney evidencing such agency or (ii)evidence of written permission from the California resident, certified under penalty of perjury, for you to act as agent.
You may submit a PIR to us not more than twice during any 12-month period. The PIR must provide sufficient information to allow us to verify that the person submitting the PIR (or an authorized agent) is the person for whom the personal information is requested. The PIR will ask for your name, mailing address, phone number and email address, together with a certification under penalty of perjury that the information submitted is true and is your own identifying information. Our verification process generally involves the matching of three pieces of identifying information provided in the PIR to the personal information of the consumer already maintained by us. If you submitted your PIR online and you indicated on your PIR form that you want your personal information deleted, we will ask you separately to confirm your decision to delete before we take any action.
We will be unable to respond to any PIR’s unless we can verify your identity or authority to make the request and confirm that the personal information relates to you. If we cannot verify your request from your PIR, we may request that you supply us with additional information that will allow us to verify your PIR. PIR’s for which we are ultimately unable to verify will be treated as if they request disclosure only of categories of personal information collected. If your PIR is denied/rejected, we will inform you in writing of the reason. We will use personal information provided in a verified PIR only to verify the requestor’s identity or authority to submit the PIR and for no other purpose.
BY WHEN WILL PIONEER RESPOND TO A PERSONAL INFORMATION REQUEST?
We will generally respond within 45 days following our receipt of a PIR. If we require more time to respond (up to 90 days in total following receipt), we will inform you in writing of the reason and the extension period. Any responses/disclosures made to you in response to a PIR will cover only the 12-month period preceding our receipt of your PIR. However, any action we take to delete your personal information will cover all records you have with us, regardless of when generated.
The format of our responses to your PIR will depend on the format in which you submit your PIR. PIR’s submitted to us via U.S. Mail will be responded to via U.S. Mail. PIR’s submitted electronically will be responded to electronically and in a format that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, including via email.
We will not you charge a fee to process or respond to PIR’s.
WHAT ABOUT CHANGES TO THIS NOTICE?
We reserve the right to amend this Privacy Notice to California Residents at any time. When we make changes, we will post the updated Notice on our Websites, together with its Last Update.
WHO DO I CONTACT FOR MORE INFORMATION?
- Via email to: Californiaprivacylaw@pioneerusa.com
- Via mail to: Pioneer Electronics (USA) Inc.., 2050 W. 190th Street, Ste. 100, Torrance, CA 90504, Attn: Privacy Officer