GENESIS MOTOR AMERICA PRIVACY POLICY
EFFECTIVE DATE: January 1, 2023

Genesis Motor America and its parent company and affiliates (“Genesis” “we,” “us” or “our”) are committed to privacy and transparency. This Genesis Motor America Privacy Policy (the “Privacy Policy” or “Policy”) describes how we collect, use, disclose and otherwise process the personal information described in this Privacy Policy, as well as the rights and choices individuals have regarding such personal information. If you are a California resident, please review our California Privacy Supplement for additional information about our information practices and your California privacy rights as required by California privacy law, including your right to opt-out of sales of personal information.

Genesis will access, collect, use, disclose and otherwise process your personal information, including sensitive personal information, as described in this Policy. Please read this Policy carefully, including the information about the privacy choices you have regarding your personal information.

Your access to and use of our websites, apps, products and services, and any dispute over privacy, is subject to this Privacy Policy and our applicable terms and agreements, including the Genesis Motor America Website and Webservice Terms of Use,⁠ and Connected Services Agreement Terms and Conditions⁠ (collectively and as applicable, the “Terms”). The Terms are incorporated by reference into this Privacy Policy.

SCOPE

This Privacy Policy applies to our collection, use and disclosure of personal information related to:

• Our websites (each a “Site”), online services and mobile applications (each as “App”) that link to or display this Privacy Policy and our Vehicle Technology and Services (as defined and further described here), as well as the services that Genesis makes available to through these (collectively, the “Services”)

• Current and former US owner(s) of Genesis vehicles, and Bluelink® subscribers and registered users  

• Purchasers and prospective purchasers of Genesis vehicles, products and services and other individuals who receive our marketing and promotional communications

• Registrants and participants in contests, promotions and surveys that we conduct or sponsor 

• Individuals that contact us or otherwise interact with us related to our vehicles, Services, or business operations

This Privacy Policy is intended to describe our overall privacy practices with regard to the personal information subject to this Policy. Our actual collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances.

Additional Privacy Notices and Terms.

We may also provide additional privacy notices that apply to specific services and supplement this Privacy Policy, including the 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 and is incorporated here by reference into this Privacy Policy.

These additional notices are intended to supplement the information in this Privacy Policy and to provide additional details about our information practices for specific services.

In addition, we may offer sweepstakes, contests, special events, incentives, and other promotional events and activities (“Programs”). The terms and conditions for these Programs may include information on our privacy and information practices; if there is a conflict between the Program terms and this Privacy Policy, the Program terms will govern with regard to the personal information collected related to the Program. Please review all of the information about a Program before you provide us (or our business partners) with any personal information.

Not Covered by this Privacy Policy.

This Privacy Policy does not apply to the collection, use, and disclosure of personal information by independently owned and operated Genesis dealerships or businesses.

In addition, this Privacy Policy does not generally apply to the personal information that we collect about (i) job applicants and candidates, (ii) employees, independent contractors and other workers, or (iii) owners and personnel of Genesis dealers. If you are a California resident, a different privacy policy (and not this one) applies to our use, disclosure and processing of such personal information about you.

Users Outside the U.S.

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 may collect personal information directly from individuals as well as from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third- party services that we use). In addition, we may automatically collect or derive information about your use of our Services or interactions with us.

The personal information we collect varies depending upon the circumstances. In some cases (such as where required by law), we ask for your consent, or give you certain privacy choices as described in this Policy, regarding our collection, use and disclosure of certain personal information.

Information Collected Directly.

We collect personal information when you engage with Genesis, its dealers, 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. This information may include:

• Account, registration, and subscriptions: when you register for Bluelink® connected services, create a MyGenesis account, or otherwise activate, subscribe to or register for our Services, we collect personal information such as your name, email address, phone number, address, and other contact information; VIN and associated vehicle data; date of purchase; billing information and subscription details and history. 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, and demographic information.
• Biometrics and credentials: you may be able to enroll a biometric identifier (e.g., fingerprint or facial recognition) to establish a biometric access credential for access certain features and Services, such as digital key and other Vehicle Technology and Services. (See our Vehicle Technologies and Services Privacy Notice for more information.)
• Purchases and payments: if you purchase products or services from us, such as branded merchandise or parts, whether online or over the phone, we collect information related to your order, which may include name, billing and shipping address, and payment details. We may work with external payment processors and fulfillment partners to process these payments.
• Surveys or research: if you respond to surveys or similar requests that we send or administer, we will your personal information, including name and contact information, vehicle data, and survey responses.
• Communications and requests: if you contact us by email, mail, phone, chat or otherwise regarding the Services, we collect and maintain a record of your contact details, communications and our responses. If you call us, we may also record calls and maintain logs and records of those calls. We also collect personal information when you request quotes or other information from us (such as request a quote, find a vehicle or locate a dealer) or sign up for news and offers from us. The information we may collect includes your name, contact information, location, vehicle of interest, current vehicle and other information.
• Promotions and events: we may sponsor or offer contests, sweepstakes, special events, incentives, and other promotions (collectively, “events”), online and offline. If you choose to participate in an Event, we may collect personal information, including your name, age, contact information, vehicle of interest or other information. Certain events may be co-branded with one of our partners or run on an external website, such as Facebook. In these instances, the collection of your personal information may occur directly or through an external website.
• User content: if you choose to engage in forums, blogs, or similar features offered by us, or submit content to us through the Services we may maintain records about the content you post, such as comments, reviews or questions, as well as data and time and other metadata associated with this content. Certain content may also be viewable by other visitors and users of the Services.  

Information Automatically Collected or Derived.

Genesis also may also derive or automatically collect information including personal information related to you and your use of the Services. This may include data collected via cookies and web beacons, web analytics and log files, vehicle, driver, behavior and usage data, such as:

• Vehicle Technologies and Services: as further set forth in the Vehicle Technologies and Services Privacy Notice, we collect and derive personal information through our Vehicle Technologies and Services, including information about you and your vehicle, as well as other users of your vehicle and the Services, such as vehicle usage and performance data, driving data, geolocation data, settings and presets, and features and services accessed and used (including third party provided), and other information related to your use of our Vehicle Technologies and Services.
• Browsing and usage data: if you use one of our Sites or Apps or interact with our content or online services, we may collect or derive information about your use of these Services, such as your device and browser information, activity and usage data (including links clicked, pages viewed and other activity information), and location information derived from your IP address or (with you permission) your mobile device.
• Other information: if you visit a physical Genesis location, we may use video and other security monitoring to secure our premises, which may lead to the collection of personal information about visitors to our premises. If you call or contact us, we may also maintain call records for quality, training and support purposes.

We may also derive information from the personal information that we collect about you in order analyze, develop and improve our Services, provide more relevant information or content, and for other similar purposes.

Other Sources of Information.

In addition, Genesis may also obtain personal information about you and your vehicle from third parties and other sources, such as:

• Vehicle sales records and other public sources, third party data providers we work with to update and enhance our customer records, and third parties that provide us leads including lists of potential vehicle purchasers or current or former owners.
• Affiliates and partners, including providers of certain Vehicle and Technology Services, such as satellite radio and roadside assistance providers, and platform providers and app stores through which we make our Apps and certain features (such as Digital Key) available.
• Genesis dealers (which are all independently owned and operated) who may provide us with purchase data, and information about services and repairs, warranty claims, and quality and customer support, as well as data about prospective buyers.
• If you log in through or integrate a third-party account (such as Google, Amazon, Apple) with our Services, we access and obtain certain information (as authorized by you and subject the applicable terms of the third-party platform). For information about sharing by a third-party platform and revoking access to your account or content, you should consult respective privacy notices and terms and review your privacy settings for such third-party account.
• If you post information about us or engage with us or our content on social media and other third-party platforms, we may obtain personal information about you from that third party platform. These third-party platforms and services control how your personal information is collected, shared and displayed through their respective platforms.

USES AND PROCESSING OF PERSONAL INFORMATION

While the purposes for which we may process personal information will vary depending upon the circumstances, in general Genesis collects, uses, discloses and otherwise processes personal information as set forth below or otherwise directed or authorized by you:

• Providing our Services: to provide and maintain our Services; to authenticate users; to perform technical operations, such as updating software; 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.
• Communicating with you: to communicate with you about your vehicle, our products, and the Services, such as to send you notices and alerts, conduct surveys, and respond to your requests.
• 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, participate in our events, or interact with us; for research and analytical purposes, such as to evaluate and improve our Services and business operations; to develop new features, products, or services; for quality and training purposes; 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 and improve our 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.
• Planning and implementing business transactions: in order to plan and implement an actual or contemplated merger, acquisition, financing, sale, bankruptcy or restructuring of all or part our business or assets.
• 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.

• Affiliates and subsidiaries: we 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.
• Vendors and service providers: we may disclose personal information to our vendors, service providers, suppliers, contractors or agents who process such data in order to provide services to us or to perform functions on our behalf.
• Payment services companies: 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.
• Third party services and providers: some of our Services are provided or supported by third party businesses who may collect and receive personal information about you as part of their provision of the particular feature, service or application. For example, cellular data carriers, navigation and traffic services, and emergency services. In addition, some of our Sites and other Services may enable you to make purchases from third-party businesses. Any time you order from a third-party business, that business will collect your personal information as part of your order. The use of your personal information by these third-party businesses will be subject to their respective privacy policies and terms and these third parties may contact you directly, for promotional and transactional purposes.
• Dealers: we may share personal information about users of Services, vehicle owners and prospective buyers/shoppers with our authorized dealers, and licensees, who may contact you directly for customer satisfaction, sales, marketing and similar purposes.
• Marketing and advertising partners: we may also make certain information that includes personal information available to third parties third parties (such as analytics providers and ad companies) in support of our marketing, analytics, advertising and campaign management (see “Cookies, Targeting and Analytics” below, for more information). We may also make available certain third party offers that we think may interest you. If you click or otherwise choose to take advantage of a third-party offer, we may share personal information with that third party to facilitate your interaction with them.
• Promotional Programs: we may invite you to participate in sweepstakes, contests, special events, incentives, and other promotional events, activities and programs (“Programs”), which are oftentimes co-sponsored or marketed with an unaffiliated business partner. If you interact directly with, or indicate your interest in receiving information or communications directly from, a third party as part of a Program, your personal information may be shared with that third party, who will use it in accordance with their respective privacy policy. Please review the Program terms and conditions before you provide us (or our business partners) with any personal information.
• Public postings: if you voluntarily disclose information, personal or otherwise, online in any community area (whether through Genesis’s 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’s websites or any other Service available online).
• Business transfers: we may disclose and transfer personal information as part of any actual or contemplated merger, acquisition, financing, sale, bankruptcy or restructuring of all or part our business or assets, including during negotiations and due diligence related to such business transactions.
• Protecting rights and interests: we may disclose personal 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 personal 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.

AGGREGATE AND NON-IDENTIFIABLE DATA

We may also collect, use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except as permitted by applicable privacy laws (such as to confirm whether our deidentification processes are reasonable and adequate).

COOKIES, TARGETING, AND ANALYTICS

We and our third-party providers use cookies, web beacons/pixel tags, JavaScript, local storage, log files, and other mechanisms that automatically collect and record information through our Services, including information about your device, browser, usage and activities. This data is used to operate, enable and improve our Services, analyze usage and performance, track bugs and errors, verify account credentials and enable logins, track sessions, prevent fraud, and protect and secure our Services, as well as to personalize and improve your experiences, improve and measure our advertising campaigns, and provide you with more relevant content, ads and offers within our Services and on third party sites and services.

Cookies. These are small files that are transferred to and stored on your web browser by a website. Some cookies are used to enable features, remember user preferences and settings, verify credentials, prevent fraud, secure our Services and optimize performance, while others are used to track activity and usage within Services (such as content viewed, links clicked, features accessed, searches, and date and time stamps) in order to personalize content, improve and measure our campaigns, and for targeted advertising and analytics purposes. Most browsers allow you to delete cookies and to set your browser to refuse all cookies or inform you when a cookie is set. However, some website features or services may not function properly without cookies.

Web beacons (also called pixel tags and clear GIFs). These are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. Some of our web pages, commercial email messages and/or newsletters may contain pixel tags. We may use these to enhance and personalize the Sites and Services, to provide product information and advertisements that are more relevant to your interests, compile 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 the Services, track users’ movement around our Sites and gather broad demographic information for aggregate use in improving the Sites and other 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 within our Sites and other 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 through 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 mobile 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 or make available certain customer list information (such as your name, email address and other contact information) with third parties with third parties so that we can better target ads and content to our customers, and others with similar interests, on third party sites, platforms and services. In some cases, these third parties may also help us to enhance our customer lists with additional demographic or other information. We do not permit them to use or share the data we submit on behalf of other third-party advertisers.

Cookies and targeting choices.

You can manage your preferences regarding targeting cookies, advertising, and personalization:

• Browser opt-out: you can opt-out of targeting and most other third-party cookies (other than those that are necessary) on one our Sites by clicking the “Cookie Settings” link in the footer of that Site and reviewing and adjusting your cookie settings. Your preferences are browser specific and website specific. So, you need to set your preferences for each of our Sites you visit, and if you come back to a Site from a different device or a different browser on the same device, you will need to apply your preferences for that browser or device as well.
• Submit a request through our portal: you can submit a request to opt-out of sales, sharing and targeting as defined under applicable privacy laws, by submitting a request through our Personal Information Request Portal.
• Industry ad choice programs: you can also control how participating companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt-out of receiving targeted ads from participating third-party ad networks go to: www.aboutads.info/choices; you can also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device

YOUR RIGHTS AND CHOICES

We also make available several privacy choices and methods for you to submit privacy requests as described in this section. For example, you may access 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.

If you are a resident of California, please review our California Privacy Supplement for additional information about our information practices and your rights under California privacy laws.

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. We will implement your opt-out request within ten (10) business days of receiving it. 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 Personal Information Request Portal⁠. 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.
• If you opted in to receive text messages from us, you may opt-out at any time by replying STOP to any of our texts.
• You may also opt-out of our sharing of your personal information with third parties for marketing purposes by submitting a request to opt-out of sharing and targeted advertising, through our Personal Information Request portal.

Cookies and Targeted Advertising. As noted above, you can manage your preferences for cookies (including targeting cookies) on a Site by clicking the “Cookie Preferences” link in the footer of that Site and adjusting your preferences for most cookies (other than those that are necessary to the proper functioning of a Site).

Accessing and Updating Your Account 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 Personal Information Request online. 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.

Additional Privacy Information for Certain States. Residents of certain U.S. states (including Virginia) may have additional rights under applicable privacy laws, subject to certain limitations and exceptions. These rights may include:

• Correction: to request that we correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information.
• Deletion: to request deletion of certain personal information.
• Access: to confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
• Opt-Out: to opt-out of certain types of processing, including:
  • to opt-out of the “sale” of their personal information.
  • to opt-out of “targeted advertising” by us.
  • to opt-out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

You may submit a request to exercise your privacy rights by:

• Submitting a request through of Personal Information Request Portal
• Contacting us at: (844) 340-9741 (toll free)

We will take steps to verify your request and will process your request by matching the information provided in your request with the information we have in our records. We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may have the right to appeal our decision by submitting an appeal through our Personal Information Request Portal. 

You may also opt-out of targeted advertising via on one of our Sites, by clicking the “Cookie Preferences” link in the footer of that Site and turning off targeting (advertising) cookies.

SECURITY

We have implemented safeguards which are intended to protect 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 website. In order to protect you and your data, we may suspend your use of any of the Sites, 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 LINKS AND SERVICES

We may offer links to or from our Sites to other websites or online services 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, disclosure or other processing 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). 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 personal information in accordance with the Privacy Policy in effect at the time such 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. 

HOW TO CONTACT US

Please visit our Contact Us page.

CALIFORNIA PRIVACY SUPPLEMENT

This California Privacy Supplement provides California residents with additional information regarding our information practice and their privacy rights, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information or other personal information that is exempt under the CCPA.

Categories of Personal Information Collected and Disclosed.

While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we collect and have collected in the prior 12 months about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.

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.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; dealers; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services companies; third-party services or providers; government entities; and others where required by law or directed or authorized by you.

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.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; dealers; service providers and suppliers; marketing partners; payment services companies; third-party services or providers; government entities; and others where required others where required by law or directed or authorized by you.

Commercial information

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

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; dealers; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services companies; third-party services or providers; and government entities; and others where required others where required by law or directed or authorized by you."

Internet and electronic network activity information

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.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; marketing partners; digital advertising and analytics providers; government entities; third-party services or providers; and others where required others where required by law or directed or authorized by you.

Characteristics of protected classifications under California or federal law

Under limited circumstances we may collect certain information that is considered a protected classification under California/ federal law, such as your gender, age, citizenship, marital status, and disability status.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; and others where required by law or directed or authorized by you.

Location data

Precise location information about a particular individual or device.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; third-party services or providers; and others where required by law or directed or authorized by you.

Audio, visual and other electronic data

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

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; and others where required by law or directed or authorized by you.

Employment history

Professional and employment-related information.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; and others where required by law or directed or authorized by you.

Education Information

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

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; and others where required by law or directed or authorized by you.

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.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; and others where required by law or directed or authorized by you.

Profiles and inferences

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

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; marketing partners; digital advertising and analytics providers; payment services companies; government entities; and others where required by law or directed or authorized by you.

Sensitive personal information

Precise geolocation information may be collected through our Apps and the Vehicle Technology and Services.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; third-party services or providers; and others where required by law or directed or authorized by you.

If you enroll in biometric authentication features, we may collect and process your biometric identifier. In limited circumstances, we may collect from you SSN, driver’s license and government identifiers, as well as log-in and financial account information.

Third Party Disclosures for Business or Commercial Purposes - Affiliates and subsidiaries; service providers and suppliers; government entities; and others where required by law or directed or authorized by you.

Sales and Sharing Personal Information. The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. As defined by the CCPA, we may “sell” or “share” identifiers, customer records, commercial information, internet or other electronic network usage data, and profiles and inferences to or with affiliates and subsidiaries, marketing partners, third party ad companies and other marketing and advertising partners; and analytics providers. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old. 

Sources of Personal Information. In general, we may collect personal information from the following categories of sources:

• Directly from the individual
• Dealers
• Advertising networks and marketing partners
• Data analytics providers
• Social networks
• Internet service providers
• Operating systems and platforms
• Government entities
• Data aggregators and brokers

• Providing our Services
• Communicating with you
• Safety, recall and warranty
• Analyzing and improving our Services and offerings
• Personalizing content and experiences
• Marketing and promotional purposes
• In support of our general business operations
• Planning and implementing business transactions (e.g., mergers, transfers, reorganizations)
• Securing and protecting our rights
• Complying with legal requests and obligations

As further described in the Disclosures of Personal Information section of our Privacy Policy, we disclose personal information to third parties for the above purposes. In accordance with these purposes, personal information may be disclosed to:

• Affiliates and subsidiaries
• Vendors and service providers
• Payment services companies
• Third-party services and providers (i.e., third parties who support or provide certain features, applications or services related to our Services)
• Dealers
• Marketing and advertising partners (including third party ad companies and analytics providers)
• Promotional Program partners or co-sponsors

We will also disclose personal information as directed by or consented to by you, or where otherwise necessary to respond to or fulfil your requests or orders.

For more information about our use and disclosure of personal information related to the Vehicle Technologies and Services, please review our Vehicle Technologies and Services Privacy Notice.

Retention. We will retain your personal information, including sensitive personal information, as long as reasonably necessary for purposes for which the personal information was collected and is used by us, as stated in this Notice., and for an additional period of time as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

Rights of California Residents.

In general, California residents have the following rights under the CCPA (subject to certain limitations):

• Opt-out of sales and sharing: to opt-out of our sale and sharing of their personal information.
• Limit uses and disclosures of sensitive personal information: to limit certain uses or disclosures of sensitive personal information to those uses authorized by the CCPA.
• Deletion: to request deletion of their personal information, subject to certain exceptions.
• To know/access: to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
• Correction: to request correction of inaccurate personal information.
• Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests. California residents may submit CCPA requests to regarding their personal information maintained by us, by submitting a request:

• Online at our Personal Information Request Portal⁠
• Contacting as 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, and we may send you a confirmation message to verify your contact information so that we can respond to and communicate with you regarding your request using that information.

To submit a request, we ask that you provide us with your name, email address, telephone number, and mailing address, as well as VIN (if applicable). We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we cannot verify your identity, we will be unable to process your request to know/access, correct or delete. There may also be certain personal information for which we will not be able to process 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.

Authorized agents may also submit requests to us at our Personal Information Request Portal⁠. We may 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 also contact consumers directly to confirm the authority of the authorized agent.

Your Right to Opt-Out of Sales/Sharing. As noted above, California residents can submit a request to opt-out of sales and sharing via our Personal Information Request Portal⁠ or by calling us at (800) 633-5151. We will apply your opt-out request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. 
In addition, our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on that Site. Note that if you come back to the Site from a different device or use a different browser on the same device, you will need to opt-out (or set GPC for) that browser and device as well. More information about GPC is available at https://globalprivacycontrols.org.

Financial Incentives. California residents have the right to understand the material terms of any “financial incentive” offered to them and to not be included in such without consent. If we provide any programs or offerings that are considered “financial incentives” under the CCPA, we will disclose the material details of such program to you so that you can choose whether to opt in. You also have the right to opt-out of a financial incentive program at any time.

California’s Shine the Light Law.

Pursuant to California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents may submit a request to opt-out of our sharing of their personal information with third parties for the third parties’ own direct marketing use, by submitting a request to “opt of sale of personal information” through our Personal Information Request Portal⁠.

For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.

How to Contact Us

Please visit our Contact Us page.