Harley-Davidson Europe Ltd & Harley-Davidson, Inc. as of August 2020
Our primary goal in collecting your personal information is to enable us to provide our products and services to you and to help personalize your interactions and experiences with us. This Notice explains what personal information we may collect from you, when we may collect it, how we may use and disclose it, and your rights regarding our use of it. By using our websites, our mobile app and any products or services purchased or subscribed to via our websites and mobile app (including the H-D™ Connect and Vehicle Integration Services), and by submitting your personal information, you agree to the terms of this Privacy Notice.
Who is responsible for the collection and use of my personal information?
What kind of personal information does Harley-Davidson collect and why?
The entity responsible for the data processing described in this Notice (excluding data processing relating to the H-D™ Connect and Vehicle Integration Services) is Harley-Davidson Europe Ltd, 6000 Garsington Road, Oxford, Oxfordshire, OX4 2DQ, United Kingdom ("Harley-Davidson Europe"), which is the data controller of such data processing for the purposes of data protection laws.
The entity responsible for the personal data processed in the context of the H-D™ Connect and Vehicle Integration Services is Harley-Davidson, Inc., 3700 West Juneau Avenue, Milwaukee, WI 53208, United States ("Harley-Davidson, Inc."), which is the data controller of such data processing for the purposes of data protection laws.
The contact details of both of these controllers can be found in the “How do I contact Harley-Davidson?” section below.
In this Notice, "Harley-Davidson" is used to refer to both Harley-Davidson Europe and Harley-Davidson, Inc. where the information provided in the Notice is equally applicable to both controllers.
Please note that this Notice does not apply to Harley-Davidson Financial Services, which has its own privacy practices and privacy notice. Please visit: www.myhdfs.com to learn more about its privacy practices.
Our independent Harley-Davidson dealers may share certain information with us in connection with your purchase of a Harley-Davidson vehicle. However, this Notice does not apply to them or your communications with them. Please contact the dealer or visit the dealer website to learn more about its privacy practices.
We may collect personal information from you when you visit one of our websites, save your information with us online, contact us with a question or concern, want to organize a test ride or organize a rental, process your information for warranty purposes or participate in a contest, promotion, or survey. If we do not collect this personal information, we may not be able to provide you with the products and service you have requested.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.
Category of Data |
Description
|
Identity Information |
Information about you including your first name, last name, title, date of birth, gender, Driver's Licence information, VIN. |
Contact Data |
Contact details including billing address, delivery address, email address and telephone numbers. |
Payment Data |
Credit card/payment details, issuing bank, expiry date and security code and billing address. |
Transaction Data |
Details about payments to and from you and other details of products and services you have purchased from us and from which of our stores. |
Technical Data |
Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or app. |
Profile Data |
Information about your profile including your username and password, purchases or orders made by you, your interests, preferences, clothing sizes, feedback and survey responses. |
Usage Data |
Information about how you use our website, mobile app, products and services. |
Marketing and Communications Data |
Your preferences in receiving marketing from us and our third parties and your communication preferences. |
Mobile App Data |
Your device type, operating system, IP address, the unique identification number, the type of browser, the Internet service provider, information about your use of the app, and location of your device (assuming you have agreed in your device settings to the location of your device). |
We process your personal information in order to |
We use the following categories of personal information |
We rely on the following legal grounds to carry this processing |
Render a service that you requested such as facilitating rentals or test rides, answering your queries relating to our products, dealers or events, enrolling you for rallies, tours or Harley Owner Group events or managing your HOG membership |
|
Necessity for the performance of your contract/subscription with us |
Liaise with you regarding warranty or recall information |
|
Necessity for the performance of your contract/subscription with us Compliance with our legal obligations, such as product safety laws |
| Personalize and enhance your experiences when you interact with Harley-Davidson |
|
Our legitimate interests in improving user experience and our products and services |
Help us learn more about your motorcycle and retail preferences |
|
Our legitimate interests in improving user experience and our products and services |
Communicate with you and send you information by email, telephone (including autodialed or pre-recorded call), text message, or other means about our products, services, contests, and promotions, until you direct us to no longer contact you with promotional communications |
|
Your consent, which you are allowed to withdraw at any time (without this affecting the lawfulness of the processing carried out before your withdrawal). (please see the "How do I opt-in or opt-out of promotional communications?” section below for more information on this topic) Our legitimate interests in keeping you informed of interesting information about our services and improving user experience (where consent is not required by law) |
| Update you on membership programs, benefits and services, and to enhance your membership experience |
|
Necessity for the performance of your contract/subscription with us Our legitimate interests in keeping you informed of interesting information about our services and improving user experience |
Administer contests and promotions, and to respond to your corresponding requests |
|
Our legitimate interests in conducting legitimate promotional activities and raising brand awareness |
Enable us to provide you with the highest quality experiences, products, services and motorcycles |
|
Our legitimate interests in better understanding your use of our products and services and in improving them. |
| Investigate, prevent, or respond to suspected illegal activities or fraud, or to protect the safety, rights, or property of you, us, or a third party |
|
Our legitimate interests in maintaining the integrity and safety of our business and users. Compliance with relevant legal obligations. |
| Establish or exercise our legal rights or defend against any legal claims |
|
Our legitimate interests in protecting such legal interests. |
| Manage and improve our websites, mobile app, events, experience, products and services |
|
Our legitimate interests in updating and improving our website and other customer-facing platforms to ensure the best overall customer experience. |
| Perform marketing and demographic research and analysis |
|
Our legitimate interests in understanding our customers and target markets in order to increase business efficiency and devise short and long term improvement strategies. |
The H-D™ Connect and Vehicle Integration Services may not be available in your country, in which case this section will not apply to you.
If you subscribe to the H-D™ Connect and Vehicle Integration Services, we will collect and process certain personal data about you and your vehicle for the purposes of providing the H-D™ Connect and Vehicle Integration Services, as follows (together, the "H-D™ Connect Data"). Providing your H-D™ Connect Data to us is voluntary, however, if we do not collect these H-D™ Connect Data, we may not be able to provide you with the H-D™ Connect and Vehicle Integration Services or some of its features that you have requested.
| Category of H-D™ Connect Data | Description |
| User Information | Information about you, including your name, occupation, gender, age, date of birth, contact information (email, postal address, phone number and mobile phone number), account information (Customer Profile ID, password, alternate contact information (for 2-factor authentication)), driving license details, Harley Owner Group (HOG) membership ID (if any), Museum membership ID (if any), and marketing preferences. |
| Service Data | Information regarding your service package, including start and end dates, subscription and features activated/deactivated status, auto renewal status, and subscription history. |
| Vehicle Data | Data concerning your vehicle including the Vehicle Identification Number, model, model year, TCU number, selling dealer, and Home/Garage location address. |
| Vehicle Health Data | Diagnostic data relating to your vehicle. The data points will differ depending on whether the bike is an Electric Vehicle (EV), or Internal Combustion Engine (ICE) vehicle, but could include data such as odometer, fuel range, battery status, tire pressure, ride mode, charging status, and maintenance schedule. You can manage and set notification alerts in respect of these data points via the mobile app |
| Location Data | To support the H-D™ Connect and Vehicle Integration Services, we will periodically obtain location data from your vehicle. You should not subscribe to H-D™ Connect if you do not agree to have this location data collected. If you place your vehicle into Stolen Vehicle mode, our systems will collect the location of your vehicle more frequently. You should not place your vehicle into Stolen Vehicle mode if you do not agree to have this location data collected. |
| Firmware over the Air (FOTA) Updates | Information about software updates that are sent to your vehicle, including whether the update is successful. |
| Mobile App Data | Your device type, operating system, IP address, the unique identification number, the type of browser, the Internet service provider, information about your use of the app, and location of your device (assuming you have agreed in your device settings to the location of your device). |
| User feedback | Feedback from you about the services. |
We may collect and process (and permit our third party service providers to collect and process) the H-D™ Connect Data for the following purposes in accordance with this Notice and as otherwise permitted or required by law.
We use your personal data in order to |
We use the following categories of personal data |
We rely on the following legal grounds to carry this processing |
Authenticate you as a subscriber to the H-D™ Connect and Vehicle Integration Services and manage your H-D™ Connect and Vehicle Integration Services account and subscription; Manage your user preferences for the H-D™ Connect and Vehicle Integration Services in terms of the types of notifications you receive and the methods for receiving those notifications. |
|
Necessity for the performance of the contract/subscription you have with us for provision of the H-D™ Connect and Vehicle Integration Services Our legitimate interests in better engaging with you |
| Provide the H-D™ Connect and Vehicle Integration Services to you, including the Stolen Vehicle Tracking, Vehicle Health Data, Firmware Over the Air software updates and User Preferences services as detailed in the H-D™ Connect and Vehicle Integration Services Terms of Use. |
|
Necessity for the performance of the contract/subscription you have with us for provision of the H-D™ Connect and Vehicle Integration Services Processing your Location Data is based on your consent. |
Help us learn more about your motorcycle and service preferences (including profiling); Personalize and enhance your experience of the H-D™ Connect and Vehicle Integration Services. |
|
Our legitimate interests in improving user experience and our products and services. Processing your Location Data is based on your consent. |
Communicate with you and send you information by email, postal mail, telephone (including autodialed or pre-recorded call), text message, or other means about H-D™ Connect and Vehicle Integration Services and any related or other HD news, products, services, contests, discounts, events and promotions, including personalized marketing materials that may be of interest to you (subject to appropriate consent); Share your data with carefully selected partners and third parties who will communicate with you and send you information by email, postal mail, telephone (including autodialed or pre-recorded call), text message, or other means about relevant products, services, contests, discounts, events and promotions that may be of interest to you (subject to appropriate consent);
|
|
Your consent (please see the "How do I opt-in or opt-out of promotional communications?” section below for more information on this topic) Our legitimate interests in keeping you informed of interesting information about our services and improving user experience (where consent is not required by law). Processing your Location Data is based on your consent. |
| Manage our product warranties. |
|
Necessity for the performance of your contract/subscription with us Compliance with our legal obligations, such as product safety laws. |
| Handle any customer enquiries or complaints we receive from you in connection with the H-D™ Connect and Vehicle Integration Services. |
|
Necessity for the performance of your contract/subscription with us; to respond to your specific requests Our legitimate interests in better engaging with you and offering the highest level of customer service; our legitimate interests in defending ourselves against legal claims. |
| Enable us to provide the highest quality experience in respect of the H-D™ Connect and Vehicle Integration Services, including through customer service quality controls. |
|
Our legitimate interests in better understanding your use of our products and services and in improving them. |
| Improve our products and services, including through business data analytics, review of health, safety and performance of H-D products, product development research in conjunction with warranty claim information, market and demographic research, etc. |
|
Our legitimate interests in better understanding your use of our products and services and in improving them. Processing of Location Data is based on your consent. |
| Investigate, prevent, or respond to suspected illegal activities or fraud, or to protect the safety, rights, or property of you, us, or a third party |
|
Our legitimate interests in maintaining the integrity and safety of our business and users. Compliance with relevant legal obligations. |
| Establish or exercise our legal rights or defend against any legal claims. |
|
Our legitimate interests in protecting such legal and business interests. |
The recipients above may be established in countries other than your own, including outside the EEA, which do not offer the same level of privacy protection.
Some recipients in the US may be certified under the EU-U.S. Privacy Shield and thereby deemed to provide an adequate level of data protection from an EU law perspective. To the extent we transfer your personal data to countries not providing an adequate level of data protection according to an adequacy decision of the EU Commission, Harley-Davidson takes all steps that are reasonably necessary to ensure that your personal data is protected in accordance with applicable laws, including, where relevant, by entering into EU standard contractual clauses adopted by the European Commission or other appropriate safeguards with the party outside the EU/EEA.
Specifically, transfers of personal data to Harley-Davidson Inc, and its US subsidiaries listed in the previous section are covered by an intra-group data transfer agreement conforming to such EU standard contractual clauses.
You may ask for a copy of such appropriate safeguards by contacting us as set out in the "How do I contact Harley-Davidson?" section below.
Harley-Davidson maintains physical, electronic, contractual, procedural and managerial safeguards to protect the confidentiality, integrity, security, and privacy of your personal information.
We use Secure Sockets Layer (SSL) technology to protect your information as it is transmitted to us. We also employ user authentication procedures and other preventative technologies designed to keep your data secure and protected. Access to personal information is limited to authorized Harley-Davidson personnel who require access to perform their job functions, and to authorized third parties that are contractually required to keep your information confidential and secure. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.
You are responsible for taking all reasonable steps to protect your Customer Account ID and password. Please store these in a safe location and do not share them with any third party.
The amount of time Harley-Davidson will retain personal information varies, depending on the services Harley-Davidson has provided and the nature of the personal information that Harley-Davidson holds. Harley-Davidson only retains personal information for such period of time as is necessary for the legitimate purposes for which the personal data are processed.
With respect to the H-D™ Connect and Vehicle Integration Services, Harley-Davidson, Inc. may retain your H-D™ Connect Data for up to 10 years, or, in the case of Vehicle Data, Vehicle Health Data, and Location Data, for up to 15 years from the date the personal data has been collected.
Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold.
When personal information is no longer required by Harley-Davidson or by law, Harley-Davidson will either convert it into an aggregated non-identifying form or Harley-Davidson will appropriately destroy or erase the personal information.
Pursuant to applicable data protection laws you have certain rights with respect to the personal information that we process about you. Please note that these rights might be limited under applicable local data protection law.
Right to withdraw consent: If you have consented to a personal information processing activity, you can withdraw this consent at any time for future processing. Such withdrawal will not affect the lawfulness of the processing prior to consent being withdrawn. If you have provided your consent to receiving direct marketing from us or any third parties and would like to withdraw such consent, please consult the following section for detailed information on how to do so.
Right of access: You may have the right to obtain from us confirmation as to whether or not personal information concerning you is processed, and, where that is the case, to request access to the personal information. The access information includes, among others, the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipients to whom the personal information have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may also have the right to obtain a copy of the personal information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectification: You may have the right to obtain from us the rectification of inaccurate personal information about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
Right to erasure (“right to be forgotten”): Under certain circumstances, you may have the right to obtain from us the erasure of personal information about you and we may be obliged to erase such personal information.
Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information by us and we can be required to no longer process your personal information. In particular, you have the right to object at any time to the processing of personal information for direct marketing, which includes profiling to the extent that it is related to such direct marketing.
Right to restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your personal information. In this case, the respective information will be marked and may only be processed by us for certain purposes.
Right to data portability: Under certain circumstances, you may have the right to receive personal information about you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those information to another entity without hindrance from us.
To exercise any of these rights, please contact us as stated in the "How do I contact Harley-Davidson?" section below. Note that you can also review and change certain personal information directly on our online sites (such as on harley-davidson.com), by simply signing in to your account using your email address and password and accessing your account profile where you will be able to edit certain personal information.
If you are not satisfied with the way that we are handling your request, you have the right to file a complaint with your local data protection authority.
Harley-Davidson wants to communicate with you only if you want to hear from us. At the time when we collect your personal information you will generally be offered a choice, in compliance with local law, of whether you wish to receive promotional communications.
If you change your mind about your current communication preferences with Harley-Davidson, you can use the unsubscribe feature in a marketing email or log into your online profile account to change your preferences. You can also contact our customer service team via phone or mail as described in the section "How do I contact Harley-Davidson?" below.
Note that even if you opt-out from receiving promotional communications, Harley-Davidson may still contact you, including by email, for matters related to your purchase or subscription with us, such as for warranty and recall information or information about your order status and shipment. We may also need to contact you via telephone, email or postal mail with questions or information regarding your order.
Opt outs are entity specific. Opting out with respect to one Harley-Davidson entity is not automatically effective with respect to other entities.
For your convenience, our websites may contain links to other companies' sites such as authorized Harley-Davidson dealers, which may have privacy notices that differ from our own. We do not endorse and are not responsible for the content or practices of any linked sites. We recommend that you review the privacy notice of any site that you access through a link from our sites or our mobile app.
As Harley-Davidson business or outside business conditions change, we may update our Privacy Notice to reflect changes in our practices. We will post a revised Privacy Notice on our website as needed due to changes in our practices or as otherwise legally required.
For questions or concerns specific to our Privacy Notice and its application, or to withdraw your consent or exercise your rights under applicable data protection law, please contact our privacy offices:
For privacy inquiries not related to the H-D™ Connect and Vehicle Integration Services, contact Harley-Davidson Europe at:
Email: [email protected]
Post: Harley-Davidson Europe Ltd., Attn: Data Privacy, 6000 Garsington Road, Oxford, Oxfordshire, OX4 2DQ, United Kingdom.
For privacy inquiries related to the H-D™ Connect and Vehicle Integration Services, contact Harley-Davidson, Inc. at:
Email: [email protected]
Post: Attn: Chief Privacy Officer
3700 W. Juneau Avenue
Milwaukee, WI 53208