FCA CANADA INC. PRIVACY POLICY

Last Updated: August 15th 2019

The FCA Canada Inc. Privacy Policy is divided into the following sections. Please click one of the links below to go directly to the section of our Privacy Policy you would like to review. We encourage you to review our entire Privacy Policy as it contains important information about how we collect, use and disclose personal information.

INTRODUCTION
WHEN DOES THIS PRIVACY POLICY APPLY?
YOUR AGREEMENT TO THIS PRIVACY POLICY
HOW WE COLLECT AND USE PERSONAL INFORMATION
HOW YOU CAN ADJUST YOUR PREFERENCES
HOW WE COLLECT NON-PERSONAL INFORMATION, USE COOKIES, AND RELATED TECHNOLOGIES
CHILDREN'S PERSONAL INFORMATION
WHEN FCA CANADA MAY SHARE COLLECTED INFORMATION
HOW WE PROTECT PERSONAL INFORMATION
LINKS TO THIRD-PARTY WEBSITES AND CO-BRANDED WEBSITES
HOW YOU CAN ACCESS AND CORRECT YOUR PERSONAL INFORMATION
INTERNATIONAL TRANSFERS OF INFORMATION
YOUR RECOURSES
CHANGES TO THIS PRIVACY POLICY
HOW TO CONTACT FCA CANADA

INTRODUCTION
At FCA Canada Inc. ("FCA Canada"), we believe it is important to protect the privacy of our customers and guests and to explain our privacy practices. We know that you care about how your personal information is collected, used, and shared and we want to help you make knowledgeable choices about the information you provide to us. This Privacy Policy ("Privacy Policy") explains and summarizes how FCA Canada collects, uses, discloses, and protects your information, including the personal information that you may provide to us or that we may collect as you interact with us.

We may update this Privacy Policy from time to time, so please check back with us periodically.

This Privacy Policy explains the information practices of FCA Canada, including:
WHEN DOES THIS PRIVACY POLICY APPLY?
This Privacy Policy applies when FCA Canada collects Personal Information from customers, potential customers, and outside sources, for example, through FCA Canada branded or controlled websites or applications (including, but not limited to, FCA Canada brand websites, dealer advertising association websites, and certain dealer websites), and FCA Canada controlled applications accessed and/or used on a mobile, handheld or other connected device (a "Website" or "Application"). "Personal Information" includes information that alone or when in combination with other information may be used to identify, contact, or locate you (e.g., name, address, telephone number, email address, and location).
YOUR AGREEMENT TO THIS PRIVACY POLICY
By providing your Personal Information to us or by using our Websites or Applications, you consent to the collection, use and disclosure of your information by FCA Canada as explained in this Privacy Policy.
HOW WE COLLECT AND USE PERSONAL INFORMATION
We may collect and use Personal Information and data to serve our customers and potential customers, for safety, security and regulatory reasons, and to provide customers and potential customers with relevant information about our products and services. We may collect and use your Personal Information, including your Website or Application Usage Information, Location Data, device identifier information, and Product Registration and Support Information (as defined below):
- for advertising and marketing purposes
- where it is necessary for us to complete a transaction or do something that you have asked us to do. This may include collecting and using your information when you interact with our customer care department , use a "find a dealer" tool or ask us to send you product or vehicle information
- to notify you about important things like an update to an Application, Website or service, a change to our Privacy Policy, new FCA Canada products and services, and special offers, information, and promotions that may interest you;
- for our internal research purposes as we develop and improve our Websites, Applications, products and services;
- to carry out other purposes which are disclosed to you and to which you have consented; and
- to carry out any other purpose permitted or required by law.
WE COLLECT AND USE INFORMATION FROM YOU AND USE IT IN THE FOLLOWING WAYS:
Website or Application Usage Information. We (or our service providers) may collect your activities, preferences, and transactional data (such as your Internet Protocol (IP) address and browser type) as well as pages you have viewed during your use of our Websites or Applications. We may use this data for any purpose described in this Privacy Policy, otherwise disclosed to you, or permitted by law. This data will not be used to identify you unless we inform you or we believe doing so will help us better respond to a request you have made such as locating a local dealer or similar request. Where such non-Personal Information is linked to your Personal Information we treat such information as Personal Information.

We may share data collected on our Websites and Applications, including Personal Information and information such as your online behavior, search activities on our sites and on other third party sites, email address, demographic information and/or information relevant to your general location, with our third party partners or suppliers, or our third party dealers or advertising associations, to advertise or market to you (including on other sites and social media sites as you browse the web). For example, after you visit one of our Websites, use one of our Applications, or provide us with information such as your email address, you may see advertisements for our products on third party websites.

We may also use this information to advertise to people who may share interests or characteristics we think are similar to you. For example, we may share hashed information with social media advertising partners for the purpose of creating customer audiences and delivering advertisements on our behalf to their members. Members are identifiable when the social media partner matches our hashed data to its hashed data of its members.

Location Data. FCA Canada Websites or Applications may capture and record location-data about your use of that Website or Application in order to provide location-related functionality ("Location Data"). We may link that Location Data to other information that you provide to us or that we access in connection with your use of the FCA Canada Website or Application. Your use of, and our ability to offer location based functionality is enabled through our use and disclosure to third parties of Location Data and associated information.

Product Registration and Support Information. FCA Canada may allow customers to register online for certain updates and services. This information may be used to carry out the registration and/or for the purposes of the request, service, or agreement for which the information was submitted. For example, we may use your Personal Information to:
- Assist with your purchase and the maintenance of your motor vehicle(s) and accessories, including customizing your vehicle or the products and services you receive, administering warranty programs and facilitating you obtaining financing;
- Allow you to participate in customer loyalty or other marketing programs;
- conduct our internal research and analytical purposes as we develop our Websites, Applications, products and services;
- conduct advertising or marketing purposes;
- Train our staff
Events and Promotions. You may be given the opportunity to provide contact information or other Personal Information at an event or for entry into a particular promotion (including sweepstakes and contests). The specific rules and regulations governing promotions will vary and your participation constitutes your agreement to abide by those rules and regulations.

Certain promotions may be run by a FCA Canada service provider or vendor or be co-branded with one of our partners or run on a third party site like Facebook. In these instances, the collection of your Personal Information may occur directly by the service provider or vendor or by a third-party partner on their website. The promotion will state the policies governing the collection of such information if they differ from this Privacy Policy.
HOW YOU CAN ADJUST YOUR PREFERENCES
You may opt out of certain uses of your personal information by sending an email to privacyofficer.ca@fcagroup.com.
HOW WE COLLECT INFORMATION, USE COOKIES, AND RELATED TECHNOLOGIES
Cookies and Related Technologies. Cookies and similar technologies are small lines of text/data that are written onto your device a website or application. FCA Canada or others acting for us may use cookies, pixel tags, web beacons or other similar technologies in the operation of our Websites or Applications. These technologies may collect and store information to research and improve how our Websites and Applications are used, to develop our products and services, to personalize your online experience with FCA Canada, and for general advertising and marketing purposes as described in this section. For example, we may collect information about your interactions with us and our Websites, Applications and advertising, on our websites, other websites, and through other means you use to communicate with us such as email or direct mail. We may count the number of clicks and views that our advertisements receive, learn whether you found our Website by searching for it or if you were directed to it by an advertisement, learn whether you open any emails we send you, and determine which of our promotions or offers you participate in or redeem.

We may use cookies or similar technologies in the operation of our Websites and Applications, including temporary cookies or similar technologies that remain on your device until you close your browser or, in some instances, cookies or similar technologies that may persist. For example, if you register on one of our Websites or Applications, we may use persistent cookies to recognize your device and save your previously selected settings or vehicle options and personalize your experience. It is possible that cookies placed by FCA Canada or its vendors or suppliers (as applicable) in connection with the operation of the Website or Application may remain stored on your computer until you remove them or until they expire.

You may set your browser to notify you when you receive a cookie or to refuse receiving it. You should be aware that this may interfere with or make you unable to use certain functionality on websites using cookies. Disabling or removing cookies may require you to manually log on each time you wish to visit that website.

Do Not Track (DNT). Because there is no common understanding about how websites should handle "do not track" signals (DNT), FCA Canada currently does not respond to these requests. However, please see "How You Can Adjust Your Preferences" above and "Behavioural Advertising" below for more information on how you can adjust your preferences and opt-out of our behavioural advertising.

Online Analytics. FCA Canada uses third party service providers to collect analytical data about the use of our Websites, Applications, other digital content (such as advertising) and across devices used by you. We use this information to monitor use of our Websites and Applications, improve performance, better understand how visitors use and interact with our Websites and Applications, and to improve our Websites, Applications, and the content they display, including personalizing them to your perceived interests and preferences.

Social Media. The information we receive from social media sites may depend on your privacy settings on those sites. Your interactions with these sites are governed by their privacy statements. You should always review, and if necessary, change, your privacy settings on third-party websites and services. Our Websites and Applications may allow you to "like" or "share" content to a third-party social media sites. We may collect aggregated data with respect to the number of "likes" or items on our Websites or Applications that are shared with the third-party social media sites.

Behavioral Advertising. FCA Canada (and/or our Affiliates, vendors and suppliers) may use data collected on our Websites and Applications to personalize advertisements to you on our Websites, Applications and other sites as you browse the web. You may opt-out of receiving certain third-party behavioral ads by visiting the Digital Advertising Alliance, at http://www.aboutads.info/choices. We are not responsible for effectiveness of, or compliance with, any third-parties' opt-out options or programs.

Please note that even if you opt-out, or set your browser to reject cookies, you may still see FCA Canada advertisements; however such advertisements are not displayed to you based on cookies.
CHILDREN'S PERSONAL INFORMATION.
FCA Canada Websites or Applications are not directed at children. If you are under the age of majority where you live or otherwise would be required to have parent or guardian consent to share information with FCA Canada, you should not send any information about yourself to us. If a person under 13 submits information to us, and we learn the person submitting the information is a child, we will attempt to delete this information as soon as possible. Because we do not knowingly collect any Personal Information from persons under 13, we do not use or disclose such information to third parties.
WHEN FCA CANADA MAY SHARE COLLECTED INFORMATION
FCA Canada may share your Personal Information within our enterprise to fulfill our obligations to you and operate our business consistent with this Privacy Policy and applicable data protection laws. We may also share your Personal Information with third parties in certain situations, including:

FCA Canada Affiliates, Vendors and Suppliers. "Affiliates" include FCA Canada independently owner dealers, companies that are part of the FCA family of companies, FCA Canada partners or their respective subsidiaries, employees, and supplemental workers. Vendors and suppliers are companies who perform services for FCA Canada or our dealers. Some of these are located outside of Canada, and we specifically use service providers in the United States, including our parent company FCA US LLC, to store and process your personal information for the purposes described in this policy. By agreeing to this Privacy Policy and by using our products or services or providing information to us, you consent to the transfer of your Personal Information to countries outside Canada, including the United States.

To the extent it is necessary for these groups to provide their products and services to us or to provide products and services you have requested, these third parties may have access to or process your Personal Information. For example, if you ask us for product information, we might need to provide your name, address, or email to one of our dealers or a service provider so that they can help us respond to you. FCA Canada vendors and suppliers may process your personal information under the direction of FCA Canada and in accordance with our policies.

To improve our products and services, we may also share your Personal Information with vendors who may contact you to conduct market research. As a condition of providing these services, the vendors are contractually bound to only use your personal information for that purpose.

FCA Canada may also permit our Affiliates, vendors and suppliers to have access to aggregate, unidentified, statistics about our customers, sales, traffic patterns, and related Website or Application information.

Recruitment and Job Applications. Personal information such as that contained on a resume or curriculum vitae may be submitted in connection with a job application or inquiry. We may use this information throughout FCA Canada and its Affiliates worldwide for the purpose of evaluating you for employment or otherwise responding to your inquiry. We may keep your information on file for future consideration for other positions that become available.

Providing Services. FCA Canada offers a variety of services and functions through its Websites and Applications. Personal Information that is collected through a Website or Application may be used and/or disclosed to third parties in order to enable us to provide functionality or services to you. For example, some FCA Canada Websites and Applications may allow you to interface with third party websites or applications. To facilitate that connection, we may use your Personal Information and/or disclose your Personal Information to third parties. When we provide location based services enabled through a third party, we may share data about you and your use of those services with the third party in order to provide the related location based service or functionality.

Public Areas. Any information disclosed in public areas of a FCA Canada Website or Application or a third party website (for example, through Facebook, YouTube, Twitter or other sites, social media platforms, blogs, forums, wikis, chat rooms, and networking functions of mobile-device applications) will be available to the public. We cannot control the use of information disclosed in a public area. You should exercise caution when disclosing information in these public areas, especially your Location Data, financial information, or other sensitive information, and be careful how you disclose your Personal Information.

Content posted in public areas of FCA Canada Websites or Applications, including advice and opinions, represent the views of the poster and is their responsibility. FCA Canada may not endorse, support, verify, or agree with the content posted. If you have any questions or comments about any content on a FCA Canada Website or Application please send an email to: privacyofficer.ca@fcagroup.com.

Mergers, Acquisitions, and Insolvency. If FCA Canada should ever file for bankruptcy or merge with another company, or if FCA Canada should decide to buy, sell, or reorganize some part or all of its business, FCA Canada may disclose your Personal Information, including to prospective or actual purchasers in connection with one of these transactions.

As Required by Law and Other Extraordinary Disclosures. FCA Canada may disclose your Personal Information if it: (i) believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) may reduce our liability in an actual or potential lawsuit or investigation, (iii) is otherwise advisable to protect our rights or property, or (iv) is advisable to protect the legal rights or property of others.
HOW WE PROTECT PERSONAL INFORMATION
Data transmissions over the Internet cannot be guaranteed to be secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your information we make reasonable efforts to ensure security on our systems. FCA Canada uses technological, organizational, and procedural safeguards, which may include secure server software (e.g. SSL) or firewalls to help protect your information from unauthorized access, disclosure, alteration, or destruction. Personal Information may be accessed by persons within our organization or third parties identified in this Policy who require such access to carry out the purposes indicated in this Privacy Policy, or such other purposes as may be permitted or required by the applicable law. Personal Information we collect is managed from our offices in Windsor, Ontario.

However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.

If FCA Canada learns of a security system's breach that results in a real risk of significant harm to any individual, we will attempt to notify you as required by the applicable laws so that you can take appropriate protective steps. By providing Personal Information to us or using our Websites or Applications, you agree that we can communicate with you regarding security, privacy, and administrative issues. FCA Canada may post a notice on our Website or through an Application if a security breach occurs. FCA Canada may also send an email or other communication to you at the contact information we have for you in these circumstances.
LINKS TO THIRD-PARTY WEBSITES AND CO-BRANDED WEBSITES
Our Websites and Applications may contain links to third party websites or may be co-branded. Please be aware that FCA Canada is not responsible for and cannot control the privacy practices of other websites or third parties. We encourage you to read the privacy policies for these other websites, as they may differ from ours. Our Websites and Applications may also be created and maintained by service providers or may contain links to co-branded websites that may display the FCA Canada logo and trademarks but which are maintained by third parties. In some cases, such websites may be identified by the fact that they do not display a FCA Canada (or FCA Canada brand) URL or they may have information identifying a third party as the host of the particular Website or Application. Please read the privacy policy on any website you visit for the applicable privacy practices relating to personal information collected via that website, as it may differ from this Privacy Policy. This Privacy Policy applies solely to Personal Information collected by FCA Canada.
HOW YOU CAN ACCESS AND CORRECT YOUR PERSONAL INFORMATION
You may withdraw your consent for FCA Canada to use your personal information, subject to legal or contractual restrictions and reasonable notice. You may also request access to, correction of, or deletion of your personal information. Your request is subject to FCA Canada's compliance with applicable laws, for example, in some cases we may be under a legal obligation to retain certain information. For instructions on changing any of your privacy preferences, accessing your information, updating your information or for any privacy or data-protection-related question please send an email to privacyofficer.ca@fcagroup.com. We may be required to verify your identity before we allow you access to your Personal Information.

We will use reasonable efforts to comply with your request; however, in some cases we may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons. In such cases, we will provide you with an explanation of why it is not possible to grant access to your Personal Information.
INTERNATIONAL TRANSFERS OF INFORMATION
Some or all of the Personal Information we collect may be stored or processed outside your jurisdiction of residence, including in the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
YOUR RECOURSES
FCA Canada will investigate and will attempt to resolve complaints about your privacy and the collection or use of your personal information. Inquiries or complaints regarding this Privacy Policy should first contact our Privacy Office by sending an email to privacyofficer.ca@fcagroup.com.

It should be noted that FCA Canada is subject to the investigatory and enforcement powers of the Office of the Privacy Commissioner of Canada.
CHANGES TO THIS PRIVACY POLICY
In the future we may change our Privacy Policy and we will post a new or updated Privacy Policy on our Websites or Applications. Your continued use of a Website or Application will link to the new Privacy Policy, or your provision of personal information to us following a change in the Privacy Policy represents consent to the new Privacy Policy to the fullest extent permitted by law. Therefore, we encourage you to periodically review this Privacy Policy.
HOW TO CONTACT FCA CANADA
If you have any questions, comments, or concerns about this Privacy Policy, please contact the Privacy Officer at 1 (877) 639-8629 or send an email to privacyofficer.ca@fcagroup.com.