The Company and its affiliates provides this Privacy Statement to let you know how we collect, use, and share your information when you use products, services, websites and mobile applications for connected vehicle services (products and services). This Privacy Statement applies to the products and services offered by the Company, its affiliates, distributors and resellers.
KEY POINTS ABOUT OUR INFORMATION PRACTICES
We may collect information about you and your accounts with us, such as your name and address. And when our connected vehicle products and services are active, we may collect information about your vehicle, including diagnostics, use, and vehicle location. We may also collect various types of information about you from dealers and others who provide information to us. See below to learn more.
We may use your information to improve the quality, safety, and security of our products and services, to develop new products and services, and for marketing. See below to learn more.
We may share your information to provide you with products and services, to improve the quality, safety, and security of products and services, to comply with applicable law, to respond to your requests, and to allow recipients to use for marketing or other purposes subject to your consent where required. See below to learn more.
You have choices regarding how we use and share your information for marketing and other purposes. See below to learn more.
Given the nature of our products and services, there may be times when someone other than you is using one of the products and services we provide to you (for example, you let someone else drive your
vehicle). We rely on you to inform such person about this Privacy Statement and the privacy choices you have made.
Cookies and Tracking
Third Party Products and Services
In connection with our products and services, you may be offered the opportunity to use third party products and services that are not owned or controlled by the Company and are governed by separate user terms and privacy statements. See below to learn more.
Access and Update
You may access your online accounts to update your information or you may contact us to learn about how to do so. See below to learn more.
California Privacy Rights
California residents have certain rights regarding the personal information we disclose to third parties for their own marketing purposes. See below to learn more.
We maintain reasonable and adequate security controls to protect your information and require our service providers by contract to do the same. See below to learn more.
We keep information for as long as necessary to provide our products and services, operate our business, and comply with legal obligations. See below to learn more.
We will notify you of any material changes by posting the updated version of this Privacy Statement and taking other steps as needed. See below to learn more. Contact Us Please contact us by email with any questions. See below to learn more.
INFORMATION WE MAY COLLECT
We may collect the following information through your use of the products and services, including when you operate or travel in a vehicle that has active products or services, and otherwise with your consent. We may also collect your information from dealers, licensees, partners, service providers, and independent third-party sources. The types of your information that we may collect include:
- • Information about you and your accounts with us: including but not limited to your name, address, telephone number, e-mail address, login information, demographic data, password, PIN.
- • Information about your vehicle: including but not limited license plate number, vehicle identification number (VIN), mileage, oil/battery status, fuel or charging history, electrical system function, and diagnostic trouble codes.
- • Information about the use of your vehicle, including operational and safety related information: including but not limited to GPS location, speed, crash detection alerts, impact data, braking and swerving/cornering events, vehicle direction (heading), camera image and sensor data, and security/theft alerts.
- • Information about your device and how you interact with our products and services, including apps and websites: including but not limited IP address, browser type, unique device identifier, cookie data, associated identifying and usage information from your mobile phone, laptop, or other device.
HOW WE MAY USE YOUR INFORMATION
We may use your information to provide the following:
- provide our products and services
- improve the quality, safety, and security of our products and services
- develop new products and services
- maintain customer relationships and communicate with you
- administer your account(s) and process your payments for products and services
- operate our websites and applications, including online registration processes
- provide customer and vehicle support and service (for example, recall information, servicing and maintenance or warranty service)
- for warranty administration and validation
- provide product and service updates
- evaluate the quality, safety, and security of our products and services
- for research, evaluation of use, and troubleshooting purposes
- protect the safety of you or others
- verify eligibility for vehicle purchase or incentive programs
- perform marketing, including interest based marketing and advertising (with necessary consents)
- comply with legal, regulatory or contractual requirements
Where required, we will anonymize your information in a way that it can’t reasonably be associated with you or your vehicle. We may use anonymized information or share it with third parties for any legitimate business purpose.
Communications with you in connection with these uses may be via mail, telephone, e-mail, text message and other electronic messages, our websites or other applications. See “Choices” below to learn how to manage your communication preferences.
HOW WE MAY SHARE YOUR INFORMATION
We may share your information as follows for the uses described below (and where required we will obtain additional consent or anonymize the information):
Emergency Service Providers: With emergency service providers, such as law enforcement to deliver related services (for example, Stolen Vehicle Recovery Services).
Business Partners and Independent Third Parties: With business partners, such as RepairPal to provide auto repair estimates with a network of certified repair shops for service or maintenance of your vehicle; dealers, fleet or rental companies. Research institutes, for research and development purposes (for example, improving highway safety).
Service Providers: With our product and service providers who work on our behalf in connection with the above uses, such as wireless service providers, companies that host and/or operate our website, send communications, perform data analytics, credit card processors, or system providers necessary to process, store, or manage credit card information (we will not otherwise share your credit card information).
Where Required or Permitted by Law: As required or permitted by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, to detect, investigate and prevent fraud, or to conduct screening to ensure you are not on any government list of restricted parties.
Business Transfers: With a prospective or completed sale, transfer, or financing of a part of a business or its assets.
You have certain choices regarding how we use and share your information, such as for marketing and related purposes. Please contact us to make choices about telephone, email, text message and other communications. See “How To Contact Us” below.
If you exercise choice regarding certain marketing communications, your information may still be used for the other purposes described in this Privacy Statement (for example, vehicle support and service), including marketing communications where you have not exercised choice, or communications we are required or permitted by law to send to you (for example, certain types of transactional or account-related messages).
In addition, some collection and sharing practices are tied to the products and services we offer. To stop the collection or sharing of some information, you may have to decline those products and services or be willing to accept limited functionality.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Similarly, we may also place cookies in our emails to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device,
operating system and browser used to deliver the email and any URL accessed through our email message.
Please also refer to your browser Help instructions to learn more about cookies and other technologies and how to manage their use. If you elect to refuse or delete cookies, you will need to repeat this process if you use another computer, or change browsers. If you choose to decline cookies, some of the functionality of a website may be impaired. Please contact us with further questions about how to opt-out of cookies and other technologies.
California Do-Not-Track. At this time, we do not honor website browsers’ “do not track” signals. However, you may refuse or delete cookies, and otherwise express your choices on marketing issues as described above.
THIRD PARTY SERVICES, APPLICATIONS AND WEBSITES
Our websites may contain links to independent sites outside of and not controlled by the Company, such as those belonging to dealers, licensees, or independent product review sites. The Company is not responsible for these sites, their omissions, policies, or content of the websites or for the personal information practices of such third parties. We recommend that you read the privacy policies of these third parties before making a decision to use the site or provide your personal information to the site operators.
ACCESS AND UPDATES TO YOUR INFORMATION
You can access your online account to view or update your information in that account. You may also contact us, as provided below, to learn about how to access, review, correct, update, or delete the information about you in our records. We may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law.
Please Note: We do not provide access to records of service events (for example, when you request service, or when we provide crash, or theft). We generally do not release those records unless we receive a subpoena or are otherwise required by applicable law.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident you have the right to request information from the Company regarding the manner in which the Company shares certain categories of your personal information with third parties, including affiliates, for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to the Company at its designated address and receive the following information:
- The categories of personal information the Company disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and
- The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. See “How To Contact Us” to make a request.
HOW WE SAFEGUARD YOUR INFORMATION
We maintain reasonable and adequate technical, administrative, and physical security and confidentiality measures designed to help protect your information from unauthorized access or acquisition. We also require by contract (other than in an emergency situations) that third party services providers acting on our behalf or with whom we share your information also undertake to provide such security and confidentiality measures in accordance with industry standards.
HOW LONG WE KEEP YOUR INFORMATION
We may keep the information we collect for as long as necessary to provide products or services to you, to operate our business, to enable us to communicate with you, for our safety, research, evaluation of use, or troubleshooting purposes, or to satisfy our legal or contractual obligations. Where required, we will anonymize or dispose of the information we collect when we no longer need it for the uses described above.
CHANGES TO THIS PRIVACY STATEMENT
We may need to update this Privacy Statement from time to time as our business and products or services expand or change, or as required to by law. If we do, we will post the updated version of the Privacy Statement on our website, and ask for your consent to the changes if legally required.
Company, as used throughout this Privacy Statement, means Connected Dealer Services, LLC, whose offices are located at 17361 Armstrong Avenue Irvine, CA 92614 USA, and each of their Dealers, Agents, successors and/or assigns.8
HOW TO CONTACT US
If you have concerns or questions regarding the Companies consumer privacy practices or this Privacy Statement, please visit our website. You may also contact the Company by email at firstname.lastname@example.org.