GENESIS MOTOR AMERICA PRIVACY POLICY
EFFECTIVE DATE: NOVEMBER 5, 2021

Your privacy is important to Genesis Motor America and its parent company and affiliates (“Genesis” “we,” “us” or “our”), as is your trust in Genesis products and services. We strive to protect your privacy, while providing opportunities to receive desired information regarding Genesis products, services, and offers that are relevant and useful to you. This Genesis Motor America Privacy Policy (this “Privacy Policy”) describes how we collect, use, and share your personal information, including, as applicable, your rights regarding access, deletion, opting-out, and correction of your personal information. 

OVERVIEW
The bullets below provide a summary of the personal information we collect and how we use it, which is further explained in our Privacy Policy below. While the actual information we collect and our use of such personal information varies depending upon the nature of our relationship and interactions, the bullets below provide a general overview of the categories of personal information we collect and the purposes for which we use such information. 

CATEGORIES OF PERSONAL INFORMATION COLLECTED
Identifiers
Such as a real name, alias, address, VIN, IP address and online identifiers, email address, account name, SSN, driver’s license number and other government identifiers, or other unique personal identifiers.

Customer records
Paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, current employment, employment history, SSN, driver’s license number, and other government identifiers, insurance policy number, financial account number and other financial or payment information and medical information.

Commercial information
Including records of property, products or services purchased, obtained, or considered, vehicle ownership reports, or other purchasing or use histories.

Internet or other electronic network usage data
Including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other usage data related to your use of any company websites, applications or other online services.

Geolocation data
Precise location information about a particular individual or device.

Audio, video and other electronic data
Audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings).

Employment history
Professional or employment-related information.

Education information
Education information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act.

Biometric information
Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity. For example, if you enroll, we may collect and process biometrics (e.g., fingerprint or facial recognition) as part of certain features and services, such as digital key and other vehicle services that enable your access using your biometric access credentials, subject to your consent as required under applicable laws.

Profiles, inferences and trends
Including inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, behavior or attitudes.

USES OF PERSONAL INFORMATION 
Providing our Services. Safety, recall and warranty. Analyzing and improving our Services. Personalizing content and experiences. Marketing and promotional purposes. In support of our general business operations. Securing and protecting our rights. Complying with legal requests and obligations.

California Residents
If you are a California resident, please be sure to review the section Additional Information for California Residents below for important information, as required by California privacy laws, about the categories of personal information we collect and disclose and your rights under California privacy laws, including your right to submit a “Do Not Sell My Info” request (i.e., to opt out of the sale of your personal information.

SCOPE
This Privacy Policy applies to our collection, use and disclosure of personal information related to (a) current and former US owner(s) of Genesis vehicles, (b) users of our websites (each a “Site”) and mobile applications (each as “App”) that link to or display this Privacy Policy, (c) users of our vehicle technologies and services that we make available via the vehicles you own or operate, and (d) subscribers to Genesis Connected Services and other subscription services ((b), (c), and (d) collectively the “Services”), (e) individuals that contact us, interact with us or express interest in our vehicles or Services, and (f) our efforts to operate and expand our business.

Additional Privacy Notices
We may also provide additional privacy notices and terms that apply to specific services, which are incorporated here by reference, such as:

• Genesis Vehicle Technologies and Services Privacy Notice, which applies to and provides additional information about our collection, use and disclosure of personal information related to our vehicle technologies and services.   

• Genesis Terms of Use, which provide the applicable terms that apply to the use of our products and services

• Connected Services Terms and Conditions, which constitute the agreement for the provision of connected vehicle services

Personal Information
Personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual or household. Personal information includes information that can identify you, such as contact information, vehicle ownership information, geolocation data, web tracking information, payment card information, and demographic data.

Not Covered by this Policy
This Policy does not apply to job applicants and candidates who apply for employment with us, or to employees and non-employee workers. It does not apply to the collection, use, and disclosure of personal information by independently owned and operated retailers or businesses.

USER CONSENT
Your use of our Services is subject to the applicable terms of use, which may include our Terms of Use and Connected Services Terms and Conditions (collectively and as applicable, the “Terms”), including applicable limitations on liability and the resolution of disputes. Our terms are incorporated by reference into this Privacy Policy.

By disclosing your personal information to us or using our Services, you understand and agree that Genesis may collect, use and disclose your personal information in accordance with this Privacy Policy and the Terms. If required by applicable law, we will obtain your consent to our collection, use, transfer and disclosure of your personal information. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS, THEN PLEASE DO NOT DISCLOSE PERSONAL INFORMATION TO US OR USE THE SERVICES. 

Our Services are intended for use and access by U.S. residents only. Genesis does not knowingly collect, process, access or intend to access the personal information of persons residing outside of the U.S., including in Europe and China. If you do not reside in the U.S., you should visit the Genesis-affiliated website that is applicable to your country or region.

PERSONAL INFORMATION WE COLLECT
We collect information about you directly from you, from third parties, and automatically through your use of our Services or interactions with us. We may combine the information we collect from these various sources.

Sources of Personal Information 
The personal information we collect varies depending upon the circumstances. For example, we collect personal information when you engage with Genesis, its retailers, or its service providers directly, such as when buying a vehicle, registering for a service or creating an account, requesting information from us, making part or service requests; participating in promotional activities, such as surveys, sweepstakes, contests, special events, blogs and chats; or when you contact us or otherwise voluntarily provide information to us. 

Genesis also automatically collects usage data when you use Genesis Sites and Services. This may include data collected via cookies and web beacons; web analytics and log files; and vehicle, driver, and connected services usage data. Please see below for additional information regarding our collection of this type of information. Some of our Services may capture and record geolocation and general location data about your vehicle. If you visit a physical Genesis location, we may use CCTV and other security monitoring to secure our premises, which may lead to the collection of personal information about visitors to our premises. 

In addition, Genesis may also obtain information about you and your vehicle in a number of other ways. For example, we may obtain information about you or your vehicle from vehicle sales records and other public sources, from Genesis affiliates and business partners such as satellite radio and roadside assistance programs, Genesis dealers (which are all independently owned and operated), and other sources that provide us leads including lists of potential vehicle purchasers or current owners.

Categories of Personal Information
Certain privacy laws, such as the California Consumer Privacy Act (“CCPA”), require that we disclose the categories of personal information that we may collect about individuals. While the actual information we collect varies depending upon the circumstances, generally we may collect the following categories of personal information:

Identifiers
Such as a real name, alias, address, VIN, IP address and online identifiers, email address, account name, SSN, driver’s license number and other government identifiers, or other unique personal identifiers.

Customer records
Paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, current employment, employment history, SSN, driver’s license number, and other government identifiers, insurance policy number, financial account number and other financial or payment information and medical information.

Commercial information
Including records of property, products or services purchased, obtained, or considered, vehicle ownership reports, or other purchasing or use histories.

Internet or other electronic network usage data
Including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other usage data related to your use of any company websites, applications or other online services.

Geolocation data
Precise location information about a particular individual or device.

Audio, video and other electronic data
Audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings).

Employment history
Professional or employment-related information.

Biometric information
Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity. For example, if you enroll we may collect and process biometrics (e.g., fingerprint or facial recognition) as part of certain features and services, such as digital key and other vehicle services that enable your access using your biometric access credentials, subject to your consent as required under applicable laws.

Education information
Education information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act.

Profiles, inferences and trends
Including inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, behavior or attitudes.

USE OF PERSONAL INFORMATION
Genesis uses the information collected above in a number of ways. And we may use your information individually or combine it with other information to generate aggregate statistical information. The primary uses of your information include:

Running our business and providing our Services 
To provide and maintain our Services; to improve our Services; to authenticate users; to perform technical operations, such as updating software; to communicate with you about our Services, vehicles and other products and services; to respond to your requests; to administer Events that you participate in; to fulfill your orders and process your payments; to provide technical support; and for other customer service and support purposes. 

Safety, recall and warranty
For safety, recall and warranty purposes, such as to send recall notices, process recall and warranty claims, and for other purposes related to vehicle safety.

Analyzing and improving our Services and offerings
To better understand how users access and use our vehicles, other products, and the Services; for research and analytical purposes, such as to evaluate and improve our Services and business operations; to develop new features, products, or services; and to otherwise improve our Services and user experiences.

Personalizing content and experiences
To tailor content we send or display on the Services in order to offer location customization and personalized help and instructions and to otherwise personalize your experiences; to reach you with more relevant ads and to measure ad campaigns.

Marketing and promotional purposes
To send you newsletters, offers or other information we think may interest you; to contact you about our products, services or information we think may interest you; to administer promotions and contests; and to promote other services we offer.

In support of our general business operations
Where necessary to the administration of our general business, accounting, record keeping and legal functions, including to analyze operational and business results and risks, to collect outstanding amounts owed, and maintain business records.

Securing and protecting our rights
To protect our business operations, secure our network and information technology, assets and services; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements with you, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party.

Complying with legal requests and obligations
To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

Anonymous and De-identified Information
We also may de-identify information and create anonymous and aggregated data sets and reports in order to assess, improve, and develop our business, products, and services; prepare benchmarking reports; and for other research and analytics purposes.

DISCLOSURE OF PERSONAL INFORMATION
We disclose personal information to provide and improve our Services; to reach you with more relevant information and offers; to support recall, warranty and safety purposes; to provide you with information about third party offers you may be interested in; to honor your consent or authorization; and to achieve other purposes set out below:

Affiliates and Subsidiaries
Genesis may share your personal information with Hyundai Motor America, as well as Hyundai Motor Company, our parent company headquartered in South Korea and our subsidiaries. Genesis may also share your personal information with our finance affiliate Hyundai Capital America and our R&D affiliate Hyundai America Technical Center, Inc., both located in the United States.

Service providers and suppliers
We may disclose personal information to our vendors, service providers, suppliers, contractors or agents who use such data in order to perform functions on our behalf.

Marketing partners and third parties
Genesis may share personal information, including information about users of Services or vehicle owner information, with third parties including our affiliates and subsidiaries, authorized retailers, and licensees. In addition, personal information may be used by our business partners, including marketing and promotional partners, to conduct joint marketing programs with Genesis, show you advertisements about our products and services on third party sites, and to offer you other valuable products and services. We may share personal information, such as name, contact information and other data about your vehicles or interests, with our authorized retailers in your area so that they may contact you about your vehicle needs and purchase plans, or otherwise reach out to you for marketing purposes.

Programs
Genesis may invite you to participate in promotional activities, such as surveys, sweepstakes, contests, special events, blogs and chats (“Programs”). These Programs are oftentimes co-marketed with an unaffiliated Genesis business partner. If you participate in a Program, we may use personal information you provide. For example, we may send you email messages to invite you to join a contest. Your personal information may also be shared with our business partners and may also be used by our business partners if you indicate your interest in receiving communications directly from that company. If you elect to receive communications from our business partners, your information will be used by that company in accordance with its policies and this Privacy Policy will not apply to that company’s use of your information. Sometimes the rules, terms and conditions, or disclaimers that apply to a particular Program include information on how we may use the personal information that you provide to us through your participation in the Program. If there is a conflict between the rules, terms, and conditions that apply to a particular Program and this Privacy Policy, those applying to the particular Program will govern. Please review all of the information about a Program before you provide us (or our business partners) with any personal information.

Participating vendors
Some of our Services offer opportunities to make purchases online from special participating vendors. For Services with online purchase opportunities for products and merchandise, we may also give participating vendors the order information and authorization for the merchant bank. Any time you order from a participating vendor, that vendor will automatically have all the information related to the order. Participating vendors may use that information to advise you directly of other products and offerings that they provide.

Credit card companies and payment services
In some cases, we use third party payment and transaction services to facilitate your transactions and process your orders. In such cases, we will share your personal information and credit card information with third party payment services companies solely for the purpose of completing the transaction or processing your order.

Public postings
You should be aware that if you voluntarily disclose information, personal or otherwise, online in any community area (whether through Genesis websites or any other Service available online), that information can be collected and used by others. Accordingly, you should use caution when sharing any personal information or other sensitive information with others in any community area (whether through Genesis websites or any other Service available online).

Business transfers
We may disclose and transfer personal information as part of any merger, acquisition, financing, sale of company assets or interests in the respective company, or in the case of insolvency, bankruptcy, or receivership, including during negotiations related to such business transfers.

Protecting rights and interests
We may disclose your information to protect or defend the safety, rights, property, or security of Genesis, third parties or the general public, including to protect the Services, to detect, prevent, or otherwise address fraud, security, technical issues, or other activity which we, in our sole discretion, consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity. We may also use personal information as evidence in litigation in which we are involved, and as necessary to enforce this Privacy Policy, our Terms, and other applicable agreements with you.

Legal compliance and lawful requests
We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, in response to a subpoena, warrant, court order, or other legal process, or to cooperate with investigations or lawful requests, whether formal or informal, from law enforcement or government entities.

De-identified and Aggregated Data
We may share aggregate or de-identified information with third parties for research, marketing, analytics, and other purposes, provided such information does not reasonably identify you.

Categories of Personal Information Disclosed
Certain privacy laws, such as the CCPA, require that we tell you about the categories of personal information that we have disclosed for a business purpose as well as the categories that we have “sold”. Please review the section Categories of Personal Information Collected above for further descriptions of each category of personal information.

Disclosed for a business purpose
In general, we may disclose the following categories of personal information for the business purposes described above: identifiers; customer records; commercial information; internet or other electronic network usage data; geolocation data; audio, video and other electronic data; employment history; education information; and profiles and inferences.

CATEGORIES OF PERSONAL INFORMATION DISCLOSED FOR OUR BUSINESS PURPOSES & CATEGORIES OF THIRD PARTIES TO WHOM THIS INFORMATION WAS DISCLOSED

Identifiers
Affiliates and subsidiaries; retailers; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services companies; and government entities.

Customer records
Affiliates and subsidiaries; retailers; service providers and suppliers; marketing partners; payment services companies; and government entities.

Commercial information
Affiliates and subsidiaries; retailers; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services companies; and government entities.

Identifiable Internet or other electronic network activity information
Affiliates and subsidiaries; service providers and suppliers; marketing partners; digital advertising and analytics providers; and government entities.

Geolocation data
Affiliates and subsidiaries; service providers and suppliers; and government entities.

Audio, visual, and other electronic data
Affiliates and subsidiaries; service providers and suppliers; and government entities.

Employment history
Affiliates and subsidiaries; service providers and suppliers; and government entities.

Education information
Affiliates and subsidiaries; service providers and suppliers; and government entities.

Profiles and inferences
Affiliates and subsidiaries; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services companies; and government entities.

Disclosed with your consent. With your consent, we do disclose or make available certain personal information to third parties including retailers and other third party providers.

Sold
The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for direct monetary compensation from such third parties, we do disclose or make available personal information to third parties, in order to receive certain services or benefits from them—for example, when we allow third party tags to collect information such as browsing history on our Sites to improve and measure our ad campaigns. Under the CCPA, we may “sell” (as defined by the CCPA): identifiers, customer records, commercial information, internet or other electronic network usage data, and profiles and inferences to affiliates and subsidiaries, marketing partners, digital advertising and analytics providers.

CATEGORIES OF PERSONAL INFORMATION DISCLOSED OR MADE AVAILABLE & CATEGORIES OF THIRD PARTIES TO WHOM THIS INFORMATION WAS DISCLOSED OR MADE AVAILABLE 

Identifiers
Affiliates and subsidiaries; vendors; marketing partners; and digital advertising and analytics providers.

Customer records
Affiliates and subsidiaries; vendors; marketing partners; and digital advertising and analytics providers.

Commercial information
Affiliates and subsidiaries; vendors; marketing partners; and digital advertising and analytics providers.

Internet or other electronic network activity information
Affiliates and subsidiaries; vendors; marketing partners; and digital advertising and analytics providers.

Profiles and inferences
Affiliates and subsidiaries; vendors; marketing partners; and digital advertising and analytics providers.

COOKIES AND TRACKING 
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Sites and other Services. We may combine this data with other personal information we collect about you. This data is used to understand how our Sites and other Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Sites and other Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes. We provide additional information about tracking technologies below. You can learn about how to register your preferences regarding certain uses of the technologies by reading the Cookies and Tracking Choices section below. 

Cookies
We may collect certain information regarding website activities through the use of HTTP cookies which are small files stored on your web browser. Cookies enable us to track website usage so that we may better target the interests of our users and enhance their experience on our websites as well as to remember user preferences and optimize the design of our Sites and other Services. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. 

Web beacons
Some of our Sites and other Services, commercial email messages and/or newsletters may contain electronic images known as web beacons, which are also called single-pixel GIFs. Web beacons collect information including a cookie number, time and date of a page view and a description of the page on which the web beacon resides. Web beacons are a technique we may use to enhance and personalize the Sites and Services we offer, to provide product information and advertisements that are more relevant to your interests, compile aggregated statistics about the usage of our Sites and other Services, improve and personalize our advertising, and to track the number of users who have opened and acted upon our commercial email messages.

Log files
We collect log information to analyze trends, administer our Sites and Services, track users’ movement around our Sites and gather broad demographic information for aggregate use in improving the Sites and other Services.

Do Not Track
Our Sites and other Services do not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.

Third-Party Analytics
We may use third-party analytics companies, for example Google Analytics (see privacy policy and opt-out) to evaluate use of our Services.  We use these tools to help us understand use of, and to improve, our Sites and other Services, performance, ad campaigns, and user experiences.  These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.

Interest-Based Advertising
On some of our Sites and Services, we may work with third-party ad networks, analytics companies, measurement services and others (“third-party ad companies”) to display advertising on our vehicles and our Sites and Services and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Sites and other Services (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

Custom Audiences and Matching.
We may share certain hashed customer list information (such as your email address) with third parties—such as Facebook and Google—so that we can better target ads and content to our customers, and others with similar interests, within their services. These third parties use the personal information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers.

Cookies and Tracking Choices
If you would like to opt-out of third party collection of information on our Sites via cookies and similar tracking technologies, you can Manage Preferences. This tool provides you with information about the third parties that collect information via cookies and similar technologies and allows you to opt out of such collection. You will need to visit Manage Preferences on all of the browsers and devices you use to access our Sites. If you clear cookies on your browser, you will need to reset your preferences at Manage Preferences.

In addition, for more information or to opt out of third party advertising cookies and tags, you may visit http://www.privacyrights.info/. You may also obtain more information about targeted or “interest-based advertising” by visiting the Network Advertising Initiative or the Digital Advertising Alliance. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

YOUR RIGHTS AND CHOICES

You may access, delete and update certain of your personal information by accessing and adjusting your account settings, or by contacting us as specified below. Please note that we may maintain copies of information that you have updated, modified or deleted, as permitted, in our business records and in the normal course of our business operations.

Opting-Out of Certain Communications
Genesis offers you the opportunity to opt-out from marketing communications from Genesis, and to opt out of certain disclosures of personal information to third parties.

You may opt-out of marketing emails or manage your subscription preferences for emails from us at any time by using the unsubscribe mechanism within any marketing email we send to you. Even if you opt out, we may still send you non-commercial emails, such as registration confirmation, vehicle updates, and responses to direct requests.

If you wish to opt-out or request that we cease sending you commercial or other information via phone or postal mail, you may opt out by submitting a request at our Contact Us page.

You may also opt out of our sharing of your personal information (including Covered Information) with third parties for marketing purpose by submitting a request at our Contact Us page.

Accessing and Updating Your Information
If you register for an account, including accounts to access and use the Services, you can access and update certain information we have relating to your account within your account settings. For Bluelink Services, this can be done on the My Account page of MyGenesis.com. You may also update or delete your contact information by submitting a request at our Contact Us page. Please note that we may maintain copies of information that you have updated, modified or deleted, as permitted, in our business records and in the normal course of our business operations.

If you have opted out of receiving future emails from us, we will implement your opt-out request within ten (10) business days of receiving the opt-out request. If you have opted out of receiving future promotional materials by regular mail, we will implement your opt-out request within a commercially reasonable time. In those instances, we will retain your information in a “do not promote” file in our database, and you will receive no further communications from us except as required by law. 

California Residents. California residents have certain rights, under California privacy laws, regarding their personal information, which are set forth in the Additional Information for California Residents section below.

THE SECURITY OF YOUR INFORMATION
We use security policies, procedures, and tools which are designed to safeguard the personal information we collect. However, the security of information transmitted through the Internet can never be guaranteed regardless of the level of security. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. Users of our Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our Sites. In order to protect you and your data, we may suspend your use of any of the websites, without notice, pending an investigation, if any security issue arises. Access to and use of password protected and/or secure areas of any of the Sites are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution or civil action.

THIRD PARTY SITES
We may offer links to or from our Sites to other websites within the Genesis family as well as to websites, services, and resources operated by third parties. We offer links to third party websites so that you can conveniently visit our vendors and advertisers or locate other content likely to be of interest to you. We are not responsible for the privacy practices, content or policies of websites operated by third parties and urge you to inquire about their privacy and information sharing practices before providing any personal information. In the event that you provide personal information to any third party website or service, you understand that Genesis is not responsible for such third parties’ use or misuse of your personal information. You further acknowledge and agree that Genesis shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such third party website, service, or resource.

CHILDREN’S PRIVACY
We do not knowingly collect or maintain personal information from any person under the age of thirteen (13) as they are not of driving age. No parts of our products or services are directed to or designed to attract anyone under the age of thirteen (13).

CHANGES TO THIS PRIVACY POLICY
Genesis reserves the right to change this Privacy Policy at any time. Genesis will use, share, and disclose all personal and other user information in accordance with the Privacy Policy in effect at the time the information is collected. We will post any changes to this Privacy Policy on this page so check back frequently so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it. Continued interaction with us following changes to these terms will mean that you accept the changes.

HOW TO CONTACT US
Please visit our Contact Us page.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This section provides information for California residents about their rights regarding their personal information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”).

Notice at Collection
We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Do-Not-Sell
California residents have the right to opt-out of our sale of their personal information for all purposes, including direct marketing by third parties. Opt-out rights can be exercised by submitting a Do Not Sell request via our Personal Information Request portal. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent. To opt-out of the sharing, including sales, of personal information with third parties that collect information from our Sites via cookies or similar tracking technologies, you can Manage Preferences. You will need to visit Manage Preferences on all of the browsers and devices you use to access our websites. If you clear cookies on your browser, you will need to reset your preferences at Manage Preferences.

Verifiable Requests to Delete and Requests to Know
Subject to certain exceptions, California residents have the right to make the following requests:

Right of Deletion
California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes.

Right to Know – Specific Information
California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.

Right to Know – Categories of Personal Information
California residents have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

• categories of personal information collected;

• categories of sources of personal information;

• categories of personal information about them we have disclosed for a business purpose or sold;

• categories of third parties to whom we have sold or disclosed for a business purpose their personal information; 

• the business or commercial purposes for collecting or selling their personal information; and 

• a copy of the specific pieces of personal information we have collected about them. 

Right to Non-discrimination. California residents have the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting Requests
You may submit requests to us at our Personal Information Request Portal. In addition, you may make certain requests to us by contacting us at: (844)-340-9741 (toll free). If you choose to submit a request via our portal, you will be able to track the status of your request. In order to make a request, you will need to provide us with your name, email address, telephone number, and mailing address. If you provide this information via our portal, we will send you an email or text message to verify the information is correct.

Please note that we may require additional information from you in order to verify your request.

Authorized agents may submit requests to us at our Personal Information Request Portal. If you are submitting a request through an authorized agent, the authorized agent must confirm their relationship with you. We may also request that any authorized agents verify their identity, including by providing information about themselves, such as their name, email, phone number, and address. We may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.

There may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. However, we will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request. 

Discrimination and Incentives
The CCPA prohibits discrimination against those who exercise their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their Personal Information. A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent.

Shine the Light
You may exercise your rights under California’s \Shine the Light law (Civil Code Section 1798.83) by utilizing the Do Not Sell My Personal Information request on the CCPA portal. 

GENESIS MOTOR AMERICA VEHICLE TECHNOLOGIES AND SERVICES PRIVACY NOTICE

EFFECTIVE DATE: November 5, 2021

Your privacy is important to Genesis Motor America (“GMA”) and its parent company and affiliates (“Genesis” “we,” “us” or “our”), as is your trust in Genesis products and services. At Genesis, we are continually developing technologies and services to make our vehicles safer, more environmentally friendly, more convenient and more fun to drive, and to provide other useful features and services to owners and drivers of Genesis vehicles. Some of these technologies and services collect, use or share information related to your Genesis vehicle (your “Vehicle”). This includes information collected, generated, recorded or stored by in-vehicle (“onboard”) systems, sensors, and equipment and information generated by your interaction with the technologies and services, such as remote service requests from your owner portal or the Genesis Intelligent Assistant app. (“Vehicle Technologies and Services”).

PLEASE REVIEW THIS VEHICLE TECHNOLOGIES AND SERVICES PRIVACY NOTICE CAREFULLY. WHEN YOU ACTIVATE, REGISTER FOR OR OTHERWISE ACCESS OR USE THE VEHICLE TECHNOLOGIES AND SERVICES, YOU CONSENT TO OUR RETRIEVAL OF INFORMATION FROM YOUR VEHICLE, AND OUR COLLECTION, USE AND SHARING OF PERSONAL INFORMATION (INCLUDING DRIVING DATA, GEOLOCATION DATA, and BIOMETRIC INFORMATION) AS DESCRIBED IN THIS NOTICE.

SCOPE AND PURPOSE

In this Genesis Motor America Vehicle Technologies and Services Privacy Notice (the “Vehicle Technologies and Services Privacy Notice” or “Notice”), we describe how we collect, use and share the following types of information related to these Vehicle Technologies and Services (the “Covered Information”):

• Information retrieved from a Vehicle or the Vehicle Technologies and Services by us or on our behalf, which is linked or reasonably linkable to that Vehicle, the owner of that Vehicle, or any registered user of the Vehicle Technologies and Services; and,

• Information provided by you during the subscription or registration process for Vehicle Technologies and Services. 

This Notice is intended to supplement the Genesis Motor America Privacy Policy (“GMA Privacy Policy”), with respect to our collection, use and disclosure of Covered Information. For additional information about our information practices and your choices and rights regarding your personal information (including Covered Information), please review the GMA Privacy Policy. Your access to or use of the Vehicle Technologies and Services and any dispute over privacy, is subject to any applicable terms and conditions, including the Connected Services Agreement⁠ which is incorporated by reference into this Notice and includes applicable limitations on damages and the resolution of disputes.

Please note that this Notice is not intended to apply to mobile applications or websites that we may make available to consumers that are not related to the Vehicle Technologies and Services.

California Residents. If you are a California resident, please be sure to review the GMA Privacy Policy for important information about your rights under California privacy laws and how to submit a request to us pursuant to these rights.

Covered Information We Collect
The Covered Information we collect varies depending upon the circumstances.

Sources of Personal Information. In general, we collect personal information directly from users of the Vehicle Technologies and Services, from third parties (such as retailers, platform providers, and others with whom we work with to make available certain of the Vehicle Technologies and Services), and automatically related to your use of the Vehicle Technologies and Services and your Vehicle. We may also combine the Covered Information we collect with other personal information we collect about you. Notices related to the collection of that other personal information will be found in the applicable privacy notice.

Categories of Personal Information. Certain laws, such as the California Consumer Privacy Act (“CCPA”) require that we disclose the categories of personal information we collect. We may collect the following categories of personal information (as set forth by CCPA) related to the Vehicle Technologies and Services: identifiers, such as a real name, alias, address, VIN, IP address and online identifiers, email address, account name, SSN, driver’s license number and other government identifiers, or other unique personal identifiers; customer records, such as payment information, credit card account number and related information; commercial information, including records of products or services purchased or considered, records from usage of the Vehicle Technologies and Services, or other purchase or usage histories; internet and other electronic network usage data, including, but not limited to, browsing history, search history, and your interaction with a website, application, or advertisement; geolocation of your Vehicle or device; audio, visual and other electronic data related to your Vehicle usage or interactions with us; biometric information in the form of your fingerprint or facial template in order to allow you to enable and use this data to control access to your vehicle; profiles, inferences and trends derived from the personal information we collect. For more information about our collection, use and disclosure of these categories of personal information pursuant to the California Consumer Privacy Act (CCPA), please go to the Genesis Motor America Privacy Policy.

Information Collected from You. We may collect Covered Information directly from you, such as when you register for an account or communicate with us related to the Vehicle Technologies and Services.

• Account, Registration, and Subscriptions. When you register for Genesis Connected Services or otherwise activate, subscribe to or register for certain Vehicle Technologies and Services, including Digital Key, we collect information that you provide us such as your name, email address, phone number, home or work address, and other contact information; VIN and associated Vehicle data; date of purchase; billing information and subscription details and history, including for relevant third-party subscriptions. We also collect certain optional information you choose to provide to us, such as your user preferences, information about other approved drivers of your vehicle, demographic information, etc.

• Customer Service and Support and Other Data. When you email us, call us or otherwise contact us, we maintain records about our interactions and communications with you, including the nature of the request, your name and contact information, and information related to our resolution of your request.
  

  
  Information Related to Vehicle Technologies and Services. Your vehicle is equipped with various software, sensors, features and other technologies that may generate, store, transmit or permit the retrieval of information from a Vehicle, which includes information related to the performance, location, operation and use of your Vehicle and the Vehicle Technologies and Services. Please note that not all Vehicles include technology that enables remote access to this data. In addition, for Vehicles that do include connected vehicle technology, you may choose not to enable that remote collection and storage of the data if you do not register for Genesis Connected Services. However, temporary vehicle data collection may occur if you do not waive Vehicle Services at the time of purchase. When Vehicle Services are available and enabled, we maintain information about your use of your Vehicle and the Vehicle Technologies and Services, including which features or services you activate, access and use, as well as:

• Usage and Performance. Information related to the use of your Vehicle and the Vehicle Technologies and Services, as well as Vehicle performance, diagnostic codes and service-related data. This includes information such as odometer, mileage, MPG and emissions data; tire pressure data; trouble or error codes, and other diagnostic data; service and maintenance history; engine performance; tire pressure data; weather, temperature and other driving conditions; fuel levels and refueling activity; battery levels and status; images from exterior cameras (if available); Vehicle settings, commands and presets, points of interest, and other information about your use of certain features; and other performance, mechanical and operational data; as well as associated date/time stamps for such information.

• Geolocation Data. In providing the Vehicle Technologies and Services, we collect location information, including your Vehicle’s GPS location. When you engage remote services using your mobile device, we also collect your mobile device location information. Geolocation data may be associated with the other Covered Information we collect and access. 

• Driving Data. We collect driving data about your Vehicle such as speed, acceleration and braking data; direction of travel; trip data (mileage, date, length, conditions); ignition events; steering events; cruise control data; seatbelt status; information about Vehicle incidents or events; other information about how you drive a Vehicle; as well as associated date/time stamps for such information. 

• Biometric Data. If you enroll in certain services, we may collect and process biometrics (e.g., fingerprint or facial recognition) as part of certain features and services, such as digital key and other vehicle services that enable your access using your biometric access credentials, subject to your consent as required under applicable laws. By setting your fingerprint and using the system, you consent to the collection, use, and storage of your data for the disclosed activities. We will only use or share your data as needed for system use, maintenance, and storage. Your fingerprint will be stored by the system until you delete it. Stored data cannot be converted into a reconstruction of your biometric information.

App and Site Data. When you access the Vehicle Technologies and Services via mobile apps, websites, and or other online services that we make available to you, we and our third-party providers may use cookies, web beacons, log files, and other methods to collect information about your activities and use. Please refer to the applicable privacy notice and/or cookie policies for those apps and websites to learn more about the collection and usage for that particular app or website.

Third-Party Services. Information we obtain about you from non-affiliated entities and service providers that provide certain features, functionality, or other services as part of the Vehicle Technologies and Services, including information related to the performance and use of such third-party services.

WE MAY COLLECT, USE AND DISCLOSE COVERED INFORMATION, INCLUDING DRIVING DATA AND GEOLOCATION DATA, FOR THE PURPOSES IDENTIFIED BELOW, INCLUDING TO PERSONALIZE THE VEHICLE TECHNOLOGIES AND SERVICES AND SEND MORE RELEVANT INFORMATION, OFFERS, ALERTS AND UPDATES.

USE OF COVERED INFORMATION
Generally, we use the Covered Information (including personal information) for the following purposes:

• Services and Support. To provide, maintain and improve the Vehicle Technologies and Services and our other products and services; to make available certain features and services, such as roadside assistance, remote start, and Vehicle alerts; to authenticate users; to process your payments; to perform technical operations, such as updating software; respond to a possible emergency or other situation requiring urgent attention; to send you messages relating to the Vehicle Technologies and Services; and for other customer service and support purposes.

• Research and Analytics. To better understand how users access and use our Vehicle Technologies and Services; to evaluate and improve our Vehicle Technologies and Services; to develop new features, products, or services; for troubleshooting and maintenance; for warranty, safety, quality and product improvement purposes; and for other research and analytical purposes.

• Marketing. To communicate with you about your account and use of our Vehicle Technologies and Services via email and push notification, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you, including information about third-party products and services; and for other informational, marketing, or promotional purposes. Please see the Your Rights and Choices section for more information about how to change your communications preferences. We may also send you notifications by text message if you have opted in to receive them.

• Personalization. To personalize the information and content we display to you, including marketing, promotional and sponsored content, as well as providing you with more relevant ads (if applicable).

• Security and Protection. To protect the safety, rights, property, or security of Genesis, the Vehicle Technologies and Services, any third-party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we, in our sole discretion, consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Notice or our Terms of Use.

• Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority; to communicate with you about recalls.

• General Business Operations. Where necessary for the administration of our general business, accounting, recordkeeping and legal functions, in connection with a transfer of our business or assets, or as part of our routine business administration, such as employee training, compliance auditing and similar internal activities.

Disclosure of Covered Information
We disclose Covered Information as set out below. Other than the cases below, we won’t disclose your Covered Information unless you consent in some way, including by your continued use after notice.

Affiliates, Vendors and Providers. We share personal information with our vendors and others who we work with to make certain services available, such as:

• Affiliates. We may disclose Covered Information to our parent company (Hyundai Motor Company), affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Notice and applicable laws.

• Service Providers and Suppliers. We may disclose Covered Information to third-party vendors, service providers, suppliers, contractors or agents who use such data in order to perform functions on our behalf. 

• Third-Party Services. Some of the Vehicle Technologies and Services are provided or supported by third parties who may collect and receive personal information about you as part of their provision of the particular feature, service or application, or in order to respond to a request you make via the Vehicle Technologies and Services. Third-party services include, for example, cellular data carriers, navigation and traffic services, and emergency services. The use of your personal information by these third parties will be subject to their respective privacy policies and terms, and not this Notice.

Third Parties. We may share Covered Information, including driving data and geolocation data, with authorized retailers and select third parties. 

• Retailers. We may share certain Covered Information with retailers so that they and we may better respond to your requests, send your relevant and personalized offers and information, and respond to your requests.

• Third-Party Offers. If you click an offer or otherwise choose to take advantage of a third-party offer, we may share Covered Information, including personal information, with that partner to facilitate your interaction with them.

Other Drivers. If you are a Vehicle owner and you permit another person to register a Vehicle Technologies and Services account for your Vehicle or if you permit another person to access and use your Vehicle Technologies and Services account or registered Vehicle, then you acknowledge and agree that such individuals may have access to Covered Information and that we may collect, use and disclose Covered Information associated with such individuals’ use of your Vehicle and the Connected Services.

Business and Operational Purposes. In addition, we may disclose Covered Information in support of our business and operational purposes, including:

• Business Transfers. Your information may be disclosed and transferred by us to another company as part of any merger, acquisition, financing, sale of company assets or interests in the respective company, or in the case of insolvency, bankruptcy, or receivership, including during negotiations related to such business transfers.

• Protecting Rights and Interest. We may disclose your information to protect or defend the safety, rights, property, or security of Genesis, third parties or the general public, including to protect the Vehicle Technologies and Services, to detect, prevent, or otherwise address fraud, security, technical issues, or other activity which we, in our sole discretion, consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity. We may also use Covered Information as evidence in litigation in which we are involved, and as necessary to enforce this Notice or our Connected Services Terms and Conditions and other applicable agreements with you. 

• Legal Compliance. We may disclose or make available Covered Information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, in response to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

Aggregate and De-Identified Information. We also may use and disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes, including select third parties who may use this data to better understand aggregate driving and traffic patterns, update maps and route details, analyze road conditions, and for other own research, development and analytics purposes.

SAFEGUARDS
We have implemented safeguards to protect the Covered Information we collect. However, the security of information transmitted through the Internet over telecommunications networks cannot be guaranteed. We are not responsible for any interception or interruption of any communications through the Internet or telecommunication network or for changes to or losses of data as a result. Users of our Vehicle Technologies and Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to the Vehicle Technologies and Services and their account. In order to protect you and your data, we may suspend your use of any of the Vehicle Technologies and Services, without notice, pending an investigation, if any security issue arises. Access to and use of password protected and/or secure areas of any of the Vehicle Technologies and Services or your associated account are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution or civil action.

INFORMATION ABOUT CHILDREN
The Vehicle Technologies and Services are not directed at children and we do not knowingly collect any personal information from children under the age of 16.

YOUR RIGHTS AND CHOICES
You have certain rights and choices regarding your Covered Information, as well as how we communicated with you related to the Vehicle Technologies and Services and other Genesis products, services or offers. For more information about your rights and choices please review the GMA Privacy Policy.

Opting-Out of Certain Communications. Genesis offers you the opportunity to opt-out from marketing communications from Genesis, and to opt out of certain disclosures of personal information to third parties.

• You may opt-out of marketing emails or manage your subscription preferences for emails from us at any time by using the unsubscribe mechanism within any marketing email we send to you. Even if you opt out, we may still send you non-commercial emails, such as registration confirmation, Vehicle updates, and responses to direct requests.
  

• If you wish to opt-out or request that we cease sending you commercial or other information via phone or postal mail, you may opt out by submitting a request at our Contact Us page.

• You may also opt out of our sharing of your personal information (including Covered Information) with third-parties for marketing purpose by submitting a request at our Contact Us page. 

Reviewing, Updating and Deleting Your Information. If you register for an account to access and use the Vehicle Technologies and Services, you can access and update certain information we have relating to your account within your account settings. For Genesis Connected Services, this can be done on the My Account page of MyGenesis.com⁠. You may also update or delete your contact information by submitting a request at our Contact Us page. Please note that we may maintain copies of information that you have updated, modified or deleted, as permitted, in our business records and in the normal course of our business operations.

Canceling Subscriptions. You may cancel your subscription for Genesis Connected Services by calling Genesis Connected Services Customer Care at 844-340-9741. If you cancel your subscription, most Vehicle Technologies and Services will not be available to you and all remote transmission of vehicle data will be stopped. However, canceling your subscription does not “turn off” all collection of Covered Information by your Vehicle. The onboard safety, diagnostic and other tools and systems may continue to generate, collect and store information so that we, our affiliates, our independent retailers and others who service your Vehicle can access performance, safety or diagnostic data to provide appropriate repair, maintenance and other safety-related services. To cancel SiriusXM Radio, you must contact SiriusXM directly.

UPDATING THIS NOTICE
Genesis reserves the right to change this Notice at any time. Genesis will use, share, and disclose all personal and other user information in accordance with the Notice in effect at the time the information is collected. We will post any changes to this Notice on this page so check back frequently so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it. Continued interaction with us following changes to these terms will mean that you accept the changes.

HOW TO CONTACT US
Please visit our Contact Us page.