Sirius XM Connected Services Privacy Policy for Model Year 2024 and Later Alfa Connect, Chrysler Connect, Dodge Connect, Jeep Connect, and Ram Connect Vehicles

Effective Date: August 22, 2023

This Sirius XM Connected Services Privacy Policy (the “Policy”) describes how FCA US LLC and its Canadian affiliate, FCA Canada Inc. (together, “FCA”) and SXM CVS Canada Inc. and its affiliate, Sirius XM Connected Vehicle Services Inc. (together, “SXMCV”), may collect, access, use, and disclose your personal information, vehicle information, and information related to your use of Alfa Connect, Chrysler Connect, Dodge Connect, Jeep Connect, or Ram Connect services (the “Connected Services”), whether in part or in whole. As used in this Policy, “we”, “our” or “us” refers to FCA and SXMCV collectively. The Connected Services governed by this Policy include the Connected services website operated by FCA, the Connected Services website operated by SXMCV (individually a “Site” or together, the “Sites”), and any mobile application related to the Connected Services (the “App(s)”). The Services are operated and performed from the United States. This Policy applies only to information that we collect about you or your vehicle (including information from or about any of the occupants in your vehicle) through the Services or as described herein, and does not govern other information independently collected by FCA or SXMCV or other information independently collected by service providers other than FCA or SXMCV. This Policy does not restrict our use or sharing of information which is anonymized or in an aggregated form, (i.e. information that cannot be used to directly identify you or your vehicle). Use of the Connected Services including the Sites and the App are also subject to the Connected Services Terms of Service (the “Terms of Service”) as well as the terms of use for each Site or App, respectively. Additionally, the provisions set forth in the “PRIVACY DISCLOSURE” AND “PRIVACY” sections of the Terms of Service are incorporated into and made a part of this Policy.

This Policy does NOT apply to vehicles receiving connected services under the name SiriusXM Guardian^TM. For vehicles receiving SiriusXM Guardian connected services, the SiriusXM Guardian Privacy Policy is available at http://www.driveuconnect.ca/privacy-sxmguardian/

TO WHAT ARE YOU CONSENTING? By enrolling in the Connected Services, you agree to the practices and procedures described in this Policy. You agree and consent that we may collect, use and disclose the information described below, including personal information, in accordance with this Policy. You also consent to allow us to contact you about the Connected Services through the in-vehicle messaging such as on your infotainment screen, App notification, via your address, email or phone number including via text messages that you have provided to us.

INFORMATION WE COLLECT FROM YOU OR YOUR VEHICLE. Information that may identify you or your vehicle may be collected, used, disclosed, and shared by us in accordance with this Policy and applicable national and provincial laws, rules, and regulations of Canada (“Collected Data”). We collect personal information you provide when you register for the Connected Services or call one of our customer care centres for assistance, such as your name, mailing address, email address, telephone number, and credit card and other payment account information. We may also collect information from you or your vehicle in the course of your use of the Connected Services. Some of this information may be collected even after the ignition is turned off.

For model year 2024 and later model year Connected Vehicles, prior to the enrollment in or activation of all available Connected Services, emergency services will remain active in your Connected Vehicle for a period of 10 years from the time the Connected Vehicle was originally purchased or leased, subject to applicable system and service requirements and limitations. Data from the emergency services consists of Vehicle Data and Location Data (each as defined elsewhere in this Policy) as well as data you provide to us, which will only be transmitted upon the occurrence of an emergency event such as an impact or the pressing of the in-vehicle SOS button. If the owner of the Connected Vehicle does not want data from the pre-enrollment, active emergency services data to be collected or used, the owner must contact us directly at 1‑833‑648‑1611 and ask to cancel your Connected Services for privacy reasons.

Collected Data transmission begins with the activation of the Connected Services in a vehicle. In the event of a subsequent purchase, the Connected Services may have been activated prior to the purchase. Cancellation of the Connected Services alone does not stop the transmission of all Collected Data to us. If you do not want Collected Data collected, retained, or used, you must follow the steps listed below in the Privacy Choices section to deactivate the Connected Services in your vehicle in their entirety.

Collected Data may include the following:

• Vehicle Data. Information related to your vehicle (“Vehicle Data”) is transmitted from your vehicle to us whenever you turn off your vehicle. Vehicle Data includes but is not limited to vehicle sensor data, diagnostic data, odometer readings, collision information, speed, direction of travel, time of travel, service data, mechanical condition or incidents involving your vehicle and tire pressure data.
  
  
• Location Data. Collection and use of your vehicle’s GPS location (“Location Data”) is required for us to provide the Connected Services. We may record, monitor or collect the location of your vehicle regardless of who is driving it a) in order to perform the Connected Services as requested by you, other occupants, or another driver of the vehicle; b) when Vehicle Data is transmitted as described above; c) when we are required to do so by applicable local, provincial or federal laws, rules or regulations; or d) in connection with our efforts to communicate with the vehicle purchaser or recover the vehicle pursuant to agreements governing the lease or financing of such vehicle.
  
  
• Customer Experience Data. We may collect information about the way you use the Connected Services that helps us troubleshoot, improve, customize or communicate about services which are offered to you.
• Monitoring and Recording. We or our service providers may monitor and record conversations between our and their respective service centers and your vehicle’s occupants, as well as any conversations between our and their service centers and you or others contacting the service centers to discuss your account outside of the vehicle. Call recordings may be shared with third parties.
  
  
• Site and Application Usage Data. We may use systems or tools to follow your use of the Sites or the Apps, including using cookies, web beacons, log files, or other technologies. When you use the Sites or the App, we or a third party acting on our behalf may collect and use or record site click-stream and cookie data regarding use and performance of the Sites or Apps during your visit (“Application Usage Data”). Application Usage Data may include without limitation the pages you view, the search terms you enter, your IP address, your operating systems and browser client, and your geographic location. We sometimes use cookies and similar technologies to enable features on our Sites, to develop products and services, and to personalize your experience. Neither the Sites nor the Apps respond to “do not track” beacons or other such signals. You may have received a tracking mechanism prior to your visit to the Sites or the Apps from other parties that will continue to track your activity while on the Site or the App. These third party cookies and technologies are governed by the privacy policies of the entities placing those mechanisms and are not subject to this Policy. For more information on how to opt-out of advertiser tracking mechanisms, please visit https://optout.networkadvertising.org/?c=1.
  
  

HOW WE USE YOUR INFORMATION. In addition to any uses set forth above, we use Collected Data for a variety of purposes including without limitation:

• to provide the Connected Services to you;
• for troubleshooting and maintenance of the Connected Services;
• to communicate with you about your account;
• to prevent fraud and misuse of the Connected Services;
• to allow us and FCA dealers to evaluate and improve products or services and present you with promotional offers, new or additional products or services;
• to perform market research;
• to protect your safety and the safety of others;
• to comply with laws, regulations, court orders, and subpoenas or similar requests for information by authorities;
• to analyze vehicle information and vehicle use information for quality and product improvement purposes, and
• to enforce the Service.

Location Data is also used for quality or research and development purposes; to notify emergency service providers; to send you Connected Services–related messages; to assist law enforcement as part of a request for stolen vehicle assistance; and to protect your safety or the safety of others in our sole discretion (e.g., to locate a missing person).

We use Application Usage Data to provide the Connected Services you request through the Sites or the Apps, and to administer, troubleshoot and improve the Sites and the Apps.

HOW INFORMATION IS SHARED. We may disclose Collected Data to any of the third parties described below, for any of the uses described in How We Use Your Information. For example, we may share Collected Data with roadside assistance providers, third-party applications or service providers, law enforcement, regulatory agencies, courts, administrative agencies, or other government tribunal, emergency service providers, or to someone you have designated as an emergency contact. Where applicable, your choice to use third party applications through the Connected Services or otherwise may result in these third parties collecting your personal information. You may also choose to give personal information directly to third parties when using the Connected Services. In each case, personal information you give a third party will be subject to that third party’s terms, conditions, and policies and is not governed by this Policy. You should review a third party’s privacy policy and terms of service before providing your information or prior to using the third-party service.

Business Transfers. Collected Data may be disclosed and transferred by us as part of any merger, acquisition, financing, sale of company assets or interests in the respective company, or the transition of service to another provider. In the unlikely event of insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. Our assignees or successors of our business or assets may use and disclose Collected Data for similar purposes as those described in here.

SAFEGUARDS AND RETENTION OF INFORMATION. We retain your information in order to fulfill our respective business purposes and use a variety of procedural, physical, and technological safeguards in our efforts to protect your information from unauthorized access, use, or disclosure. NEITHER FCA NOR SXMCV ASSUMES ANY RESPONSIBILITY OR LIABILITY WITH REGARD TO ANY THEFT, LOSS, ALTERATION OR MISUSE OF COLLECTED DATA WHICH WE LAWFULLY PROVIDE TO THIRD PARTIES, OR WITH REGARD TO ANY FAILURE OF ANY THIRD PARTY TO ABIDE BY THIS POLICY.

Collected Data, including personal information, may be transferred, stored, or processed outside of Canada, including in the United States. While outside of Canada, Collected Data will be subject to applicable foreign laws, which may allow foreign government and national security authorities to access your personal information under certain circumstances.

We require you to have a Connected Services user ID and password, and it is important that you maintain the confidentiality of this information at all times and update the password regularly. We also require that you establish a Connected Services personal identification number (“PIN”) which is required to use certain Connected Services features such as remote door lock and unlock. It is important that you do not provide your PIN to anyone who is not authorized to use or incur charges on your Connected Services account. WE ARE NOT RESPONSIBLE FOR UNAUTHORIZED USE OF THE CONNECTED SERVICES OR FOR CHARGES TO YOUR ACCOUNT WHEN THE APPROPRIATE AUTHENTICATION HAS BEEN PROVIDED.

No method of electronic transmission, or method of electronic storage, is 100% secure, and it may be possible for third parties not under our control to intercept or access information unlawfully. Therefore, we cannot guarantee its absolute security.

PROTECTING CHILDREN. The Connected Services are not directed at children and we do not knowingly allow anyone under the age of majority as determined by the laws of the province or territory of their residence, to use any Connected Services of the Site or the App which transmit Collected Data. If you are under the age of majority, you should not send any information about yourself to us.

CONTACTING US. If you have any questions about, or complaints that concern, this Policy, please write to SXMCV at: Privacy Officer, SXMCV, 8550 Freeport Parkway, Irving, TX 75063, or email SXMCV at privacy@siriusxm.com; and, to FCA at: Privacy Officer, FCA Canada Inc., P.O. Box 1621, Windsor, Ontario, N9A 4H6, or email FCA at privacyofficer.ca@fcagroup.com. Do not include any sensitive or personal information in an email.

PRIVACY CHOICES. The collection, use, and sharing of Collected Data is essential to providing the Connected Services. If you do not want this information to be collected, used, or shared, you must contact us at 1‑833‑648‑1611 and ask to cancel the Connected Services for privacy reasons. This request will result in the deactivation of your’ wireless transmission network service and will cease your access to the Connected Services safety and convenience services and other connected 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 Connected Services subscription without the request to deactivate for privacy reasons will not cancel the transmission of all Collected Data to us.

If you wish to opt out of receiving promotional communications related to the Connected Services by email or telephone, you may do so at any time by calling customer care at 1-833-648-1611. You may also follow the links to unsubscribe from promotional email communications in the footer of our marketing communications with you. Even if you opt out of promotional communications, you may continue to receive service or account-related communications from time to time as required to provide the Connected Services and/or to maintain your account.

UPDATING THIS POLICY. We may change this Policy at any time. If we make material changes to this Policy or how we handle your personal information, we will provide notice by changing the Effective Date of the Policy or as required by law. By using the Connected Services after the Effective Date, you are deemed to consent to the then-current Policy. We recommend that you check back and review this Policy from time to time.