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Connectivity Privacy Policy

FCA CONNECTED SERVICES PRIVACY NOTICE
Last Updated: April 5, 2021

FCA US LLC (“FCA,” “Company,” “we,” or “us”) values your privacy. This FCA Connected Services Privacy Notice (the “Connect Services Privacy Notice” or “Notice”) explains FCA’s collection, use and disclosure of personal information related to the FCA “Connected Services,” which may include SiriusXM Guardian Services (separate subscription required), the Connected Services platform, mobile applications and features, and other services, features and technologies we make available via eligible vehicles (each a “Vehicle”).

PLEASE REVIEW THIS CONNECTED SERVICES PRIVACY NOTICE CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION REGARDING HOW FCA MAY ACCESS, RECEIVE, COLLECT, USE AND DISCLOSE PERSONAL INFORMATION (INCLUDING DRIVING DATA AND GEOLOCATION DATA) AS DESCRIBED IN THIS NOTICE. AS A USER OF CONNECTED SERVICES, YOU CONSENT TO OUR RETRIEVAL OF INFORMATION FROM YOUR VEHICLE, OUR INSTALLATION OF OVER-THE-AIR, AUTOMATIC FIRMARE AND SOFTWARE UPDATES TO YOUR VEHICLE, AND OUR COLLECTION, USE AND SHARING OF PERSONAL INFORMATION RELATED TO CONNECTED SERVICES.

SCOPE AND PURPOSE
Vehicles eligible for Connected Services are equipped with various software, sensors, features and other technologies that may generate, store, transmit or permit the retrieval of information from a Vehicle (“Vehicle Data”), which includes information related to the performance, location, operation and use of your Vehicle and the Connected Services. This Notice is intended to supplement the FCA US Privacy Policy, with respect to our collection, use and disclosure of Vehicle Data as well as personal information related to your registration, or subscription for Connected Services (“Covered Data”).

For additional information about our information practices and your rights regarding your personal information, please review the FCA US Privacy Policy . Your use of the Connected Services, and any dispute over privacy, is subject to the applicable terms of use (including those available at www.driveuconnect.com/sirius-xm-guardian/terms.html or Terms of Service ) which are incorporated by reference into this Notice, and include applicable limitations on damages and the resolution of disputes.

COVERED DATA WE COLLECT
We collect Covered Data from a Vehicle when Connected Services are activated. The information we collect varies depending upon the circumstances, and includes personal information, as well as other information that is linked or linkable to Vehicle and other drivers of a Vehicle or users of the Connected Services. Please see our FCA US Privacy Policy for additional information regarding the personal information we collect overall. For information on how to stop our collection of Covered Data from a Vehicle, please see the Your Rights and Choices section below.

Categories of Personal Information. Generally, we collect the following categories of personal information (as defined by the California Consumer Privacy Act or “CCPA”) related to the Connected Services:

(i) identifiers, such as first and last name, address, phone number, email address, account name, other contact information, IP address, VIN, or other similar identifiers; (ii) customer records, such as payment information, credit card account number and related information; (iii) commercial information, including records of products or services purchased or considered, records from usage of the Connected Services, or other purchase or usage histories; (iv) internet or mobile app activity, including, but not limited to, browsing history, search history, and your interaction with a website, application, or advertisement; (v) geolocation of your Vehicle or device; (vi) audio, visual and other electronic data related to your Vehicle usage or interactions with us; (vii) 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 FCA US Privacy Policy .

Sources of Personal Information. In general, we collect personal information directly from users of the Connected Services, from third parties, such as dealers, platform providers, telecom providers, marketing partners and others with whom we work with to make available certain of the Connected Services, and automatically related to your use of the Connected Services and your Vehicle.

Information Collected from You. We may collect personal information directly from you, such as when you register for an account or communicate with us, related to the Connected Services.

•   Account, registration and subscriptions. When you activate or register for the Connected Services, subscribe to certain features, or otherwise access or use the Connect Services, 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 may also certain optional information, such as your preferences, information about other drivers, demographic information and other information.
•   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, name and contact information, and information related to the resolution of the request.

Information Related to Features and Services. We make a number of features and services available to you as part of the Connected Services, such as remote start, locate a vehicle, roadside and emergency services, navigation, entertainment and voice commands, the ability to set alerts on certain vehicle usage and activities, vehicle health and maintenance reports, wallet services, and personalized offers and services. In some cases, these features are available through an integration by you of certain third-party accounts and services, such as Alexa®. We maintain information about your use of the Connected Services, including which features or services you activate, access and use. Additional information about certain features and the Connected Services is described below.

Geolocation Data. In providing the Connected Services, we collect precise and non-precise location information, including your Vehicle’s GPS location, as well as your mobile device’s location information (e.g., if you grant us access to your device’s location information in connection with one of our Apps). If Connected Services are enabled, geolocation data is transmitted from your Vehicle to FCA, and in some cases, to third parties, as described herein. If you use Connected Services, such as our mobile apps or in-vehicle apps, geolocation may also be collected through these apps. Certain of the Connected Services (such as Vehicle Finder) may allow you, or other individuals authorized to use the Connected Services for Your Vehicle, to access location information, such as last known location or real-time location for Your Vehicle, and to receive access to reports or alerts about the location and use of Your Vehicle, even when it is being used by others. It is your responsibility to ensure that all users (e.g., other drivers, guests, passengers and occupants) of Your Vehicle know that you and others may be able to access location information (and other information) from Your Vehicle and through the Connected Services. Please see Your Rights and Choices for information regarding your choices with regard to the collection of geolocation data.

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

Vehicle, Usage and Performance. We retrieve and collect Covered Data related to your Vehicle’s performance and usage, as well as diagnostic and service-related data. This includes information such as odometer, mileage, MPG and emissions 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; other performance, mechanical and operational data; Vehicle settings, commands and presets, points of interest, and other information about your use of certain features; and associated date/time stamps for such information.

App and Website Data. When you use or access the Connected Services via mobile apps, websites or 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, including IP address, app identifier, device ID, advertising ID, location information, browser type, device type, domain name, the referring and exiting URLs, the dates and times of access and use; device name and model; operating system type, name, and version; the length of time that you are logged into or using our Services, and the links you click and your other activities. Our servers do not recognize browser do-not-track requests.

Data from Third-Party Providers. Some of the Connected Services are provided or supported by non-affiliated entities and service providers (“Third-Party Providers”), 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 Connected Services (collectively “Third-Party Services”), including Sirius XM Connected Vehicle Services Inc. (“Sirius XM”)—see the SiriusXM Guardian Privacy Notice for more information about how Sirius XM uses your personal information. FCA may collect information that is related to the performance of the Third-Party Services in your Vehicle and the ways you use these Third-Party Services. The Third-Party Providers that provide these Third-Party Services will collect and receive personal information from you related to the services they provide, subject to their own privacy policies for other purposes as stated in their own privacy policy. FCA is not responsible for these third parties' collection, use and disclosure of your personal information.

Other Drivers. If you permit another driver to drive your Vehicle and/or access or use your Connected Services account, then you acknowledge and agree that we may collect Covered Data during their use.

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

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

•   Providing and improving products services: to provide, maintain, and improve the Connected Services and our other products and services; to make available certain features and services, such as personal Drive Ratings, Vehicle Health Reports, Roadside Assist, Remote Start and Vehicle Finder; to develop new features, products or services; for troubleshooting and maintenance; for warranty, safety, quality and product improvement purposes; to authenticate users; to process your payments; to perform technical operations, such as updating software; to notify emergency service providers; to send you messages relating to the Connected Services; and for other customer service.
•   Conducting research and analytics: to better understand how users access and use our Connected Services, and for other research and analytical purposes, such as to evaluate and improve our Connected Services and business operations and to develop additional products, services and features.
•   Protecting rights and interests: to protect the safety, rights, property or security of FCA, the Connected 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 the applicable terms of use.
•   Complying with legal obligations: 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.
•   Supporting our general business operations: related to the administration of our general business, accounting, recordkeeping and legal functions, or in connection with a business transfer. As part of our routine business administration, such as employee training, compliance auditing and similar internal activities.
•   Marketing and communications: to communicate with you about your account and use of our Connected Services via email and push notification, as well as SMS text (with your consent) 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.
•   Personalizing content and ads: 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.

DISCLOSURE OF COVERED DATA

We disclose Covered Data, in order to provide and improve our products and services, reach users with more relevant information and offers, for warranty and safety purposes, to make available third-party offers you may be interested in, and as otherwise set out below.

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

•   Affiliates: to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Notice.
•   Our vendors: to third-party vendors, service providers, contractors or agents who use such data in order to perform functions on our behalf.
•   Providers of third-party services: to Third-Party Providers, including, for example, roadside assistance providers, SiriusXM, providers of navigation and traffic services, and emergency service providers and responders. The use of your personal information by Third-Party Providers will be subject to their respective privacy policies and term, and is not governed by this Notice.

Other Drivers. If you are an owner and you permit another driver to register your Vehicle for a Connected Services account or to otherwise access and use your Connected Services account, then you acknowledge and agree that such individual(s) may have access to your account and associated Covered Data and may be able disclose or submit requests related to the Connected Services.

Dealers and Others. We may share Covered Data, including driving data and geolocation data, with authorized dealers and select third parties. For example, we may share certain Covered Data with dealers so that they and we may better respond to your requests, send your relevant and personalized offers and information, and respond to your requests. We may also disclose certain Covered Data to select third parties who may use this data for their own research, development and analytics purposes, such as to better understand aggregate driving and traffic patterns, update maps and route details, analyze road conditions, and identify offers you may be interested in. Please see the Your Rights and Choices section below for details on how to opt out of our sharing of your personal information with third parties.

Upon Your Request. We may share Covered Data with your consent or as directed by you. For example:
•   With your consent: we may share your Covered Data with a Third-Party Provider where you choose to take advantage of a third-party offer or opt-in to certain third-party programs or services through the Connected Services, or if you authorize certain third parties to access your Covered Data. For example, we may work with insurance companies that make available usage-based insurance programs; if you opt-in to receive usage-based insurance offers or quotes through the Connected Services or you provide an insurer or other third party with authorization to access your Covered Data from us, we may share Covered Data with them as authorized by you.
•   Upon your request: if you or another Vehicle user chooses to communicate with or send information to others through the Connected Services, such as to share your Vehicle location information with a contact, information will be shared as directed.

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

•   Business transfers: 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: to protect or defend the safety, rights, property or security of FCA, third parties or the general public, including to protect the Connected 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 Data as evidence in litigation in which we are involved, and as necessary to enforce this Notice or the applicable terms of use and other applicable agreements with you.
•   Complying with legal obligations: 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.

THIRD-PARTY SITES AND SERVICES
Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Notice, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

SAFEGUARDS
We have implemented a variety of safeguards designed to protect Covered Data from unauthorized access, use or disclosure. However, no method of electronic transmission or storage, is 100% secure. Therefore, we cannot guarantee its absolute security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

INFORMATION ABOUT CHILDREN
The Connected 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 may review and update much of the personal information that you have submitted by logging into your account and updating your profile information. 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, as permitted or required by applicable law. You may also access Vehicle Health Reports, personal Drive Rating, and Vehicle location through your Connected Services account.

Opting Out – Disclosures of Covered Data. In order to provide the Connected Services, we must collect use and disclose certain Covered Data. You can request that we do not share or disclose your Covered Data with third parties by submitting a request here . Please note that this opt out does not apply to disclosures to Third-Party Providers or others in order to make Connected Services available to you, or respond to your request or comply with our legal obligations or disclosures to our agents and service providers; it also doesn’t apply to prior disclosures of your Covered Data.

Disabling Certain Services. You may opt out of certain features and services, such as personal Drive Rating, Vehicle Health Reports, and notifications, by disabling them and logging into your Connected Services account here . Please note that this will not opt you out of disclosures of de-identified or aggregate data that do not identify you or your Vehicle, nor will it opt out of disclosures in order to provide the Connected Services to you.

Geolocation Data. You can turn off geolocation data for mobile apps, through your mobile device’s privacy settings. In addition, certain features may enable you to turn on/off sharing of geolocation for that feature. However, please note that certain Connected Services rely on geolocation data to function; so, turning off geolocation for your app, a feature or your Vehicle will not stop the use of your Vehicle’s geolocation data entirely. You can, however, turn off the transmission of Covered Data by your Vehicle by deactivating Connect Services (“Cancel for Privacy Reasons”) as noted below.

Deactivate Connected Services and Stop Collection of Covered Data. If you do not want your Vehicle to transmit any Covered Data to FCA or others going forward, please contact us at 800-800-2813 and ask to “Cancel for Privacy Reasons”. This will result in the deactivation of your wireless transmission network service and will cease your access to most Connected Services features, including (if applicable) the SiriusXM Guardian safety and convenience services. It will also prevent updates to your in-vehicle manual and the implementation of any Wi-Fi services through the Vehicle. Please note that cancelling your SiriusXM Guardian subscription does not stop all transmission and collection of Covered Data; to stop data transmission you must request to “Cancel for Privacy Reasons” as set out above.

Communications Preferences. To update your communications preferences, including phone, text, and email, please contact us using the contact information below.

California Residents. If you are a California resident, more information about your rights and choices regarding your personal information can be found here: FCA US Privacy Policy . In summary, you have the following rights:

•   Do-Not-Sell and other CCPA requests: to opt out of sales, requests to know (access), and requests to delete personal information through one of the following methods: online , or by phone at 1-866-221-6871 (toll free).
•   California Shine the Light law: under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at dprivacy@fcagroup.com , and include in your request a current California address and your attestation that you are a California resident.

UPDATING THIS POLICY
We may change this Notice at any time. If we make material changes to this Notice or how we handle your personal information, we will endeavor to provide notice to you, such as by changing the effective date of the Notice or notifying you at your email address of record. By continuing to use the Connected Services, you are deemed to consent to the then-current Notice. We recommend that you check back and review this Notice from time to time.

CONTACTING US
To contact us with any questions, concerns or requests related to this Notice or Covered Data, please email us at dprivacy@fcagroup.com or write to us at:

FCA US LLC
Attn: Data Protection Office
CIMS 485-14-07
1000 Chrysler Drive
Auburn Hills, MI 48326