Effective Date: January 1, 2020
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 Alfa Connect 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. When you activate, register for or otherwise access or use the 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 (INCLUDING DRIVING DATA AND GEOLOCATION DATA) as described in this Notice.
SCOPE AND PURPOSE
COVERED DATA WE COLLECT
We collect Covered Data from a Vehicle when Connected Services are activated. For information on how to stop our collection of Covered Data from a Vehicle, please see the Your Rights and Choices section below.
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 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 location information, including your vehicle’s GPS location, as well as your mobile device’s location information with your consent. Geolocation data may be associated with the other Covered Data we collect and access.
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 (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; 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; 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; 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.
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, 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 and support purposes.
· 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.
· 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.
· General Business Operations. Where necessary for 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, 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.
· Personalizing Content and Ads. We may use the information we collect about you 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 share personal information with our vendors and others who we work with to make certain services available, such as:
· Affiliates. We may disclose Covered Data 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. We may disclose Covered Data 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. Some of the Connected Services are provided or supported by third parties (“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. Third Party Providers include, 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 terms, and is not governed by this Notice.
· Third Party Offers. If you click an offer or otherwise choose to take advantage of a third-party offer, we may share Covered Data, including personal information, with that partner to facilitate your interaction with them.
Other Drivers. If you are an owner and you permit another driver to register your vehicle for a Alfa Connect account or to otherwise access and use your Alfa Connect account, then you acknowledge and agree that such individual(s) may have access to your account and associated Covered Data.
Dealers and Other Third Parties. 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.
Business and Operational Purposes. In addition, we may disclose Covered Data 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 Interests. We may disclose your information 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 our Terms of Service and other applicable agreements with you.
· Legal Compliance. 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 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-parties websites.
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.
Opting Out. In order to provide the Connected Services, we must collect use and disclose certain Covered Data. If you do not want FCA to collect any Covered Data going forward, please contact us at 844-796-4827 and ask to “Cancel for Privacy Reasons”. This request will result in the deactivation of your wireless transmission network service and will cease your access to most Alfa Connect features, including 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.
Opt Out of Certain Services. You may opt out of certain features and services, such as notifications, by logging in with your Alfa Connect account (https://www.alfaromeoconnect.com/en-us.html). 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.
Communications Preferences. To update your communications preferences, including phone, text, and email, please contact us using the contact information below.
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.
To contact us with any questions, concerns or requests related to this Notice or Covered Data, please email us at firstname.lastname@example.org or write to us at:
FCA US LLC
Attn: Data Protection Office
1000 Chrysler Drive
Auburn Hills, MI 48326