FCA CANADA INC. PRIVACY POLICY

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.

1. INTRODUCTION
2. WHEN DOES THIS PRIVACY POLICY APPLY?
3. YOUR AGREEMENT TO THIS PRIVACY POLICY
4. HOW WE COLLECT AND USE PERSONAL INFORMATION
5. HOW WE USE PERSONAL INFORMATION
6. DISCLOSURE OF PERSONAL INFORMATION
7. HOW YOU CAN ADJUST YOUR PREFERENCES
8. CHILDREN'S PERSONAL INFORMATION
9. HOW WE PROTECT PERSONAL INFORMATION
10. HOW LONG WE KEEP PERSONAL INFORMATION
11. LINKS TO THIRD PARTIES AND CO-BRANDED WEBSITE
12. HOW YOU CAN ACCESS AND CORRECT YOUR PERSONAL INFORMATION
13. INTERNATIONAL TRANSFERS OF INFORMATION
14. YOUR RECOURSES
15. CHANGES TO THIS PRIVACY POLICY
16. HOW TO CONTACT FCA CANADA

1. 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:
   • How FCA Canada collects your personal information and what we learn about you because of our relationship.
   • How FCA Canada uses the personal information you share with us.
   • When FCA Canada may share personal information with third parties, and the reasons we may share personal information.
   • What kind of security measures FCA Canada takes to help protect your information from accidental loss or disclosure.
   • How FCA Canada will inform you in the event of a security breach.
   • The process through which you can access personal information you share with FCA Canada and ask to have that Personal Information corrected, restricted or removed from our records.
   • Other things you should know about FCA Canada and privacy.
2. 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 you (e.g., name, address, telephone number, email address, and precise location information).
3. 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.
4. HOW WE COLLECT AND USE PERSONAL INFORMATION
   We may collect personal information directly from individuals, such as when an individual registers for a Connected Services or MOPAR account, contacts us, or inquires with us about an FCA vehicle. We may also collect personal information from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third-party services that we use), as well as automatically collect or derive personal information about your use related to the use of our Websites, Apps, Connected Services, and other Services.
   
   The information we collect varies depending upon the circumstances and the Services you use. In some cases (such as where required by law), we ask for your consent, or give you certain privacy choices as described in this Policy, regarding our collection, use, and disclosure of certain personal information.
   
   Information We Collect Directly. We may collect personal information directly from you, including:
   • Registration, profile, and subscription information: to access and use certain of our Services (such as a Connected Services or MOPAR^® account), you must activate, subscribe to, and/or register for an account by providing us with certain required information, which may include your name, a username, password, email, and other contact information. We may collect personal information such as your name, email address, phone number, address, and other contact information; VIN and associated vehicle data; date of purchase; billing information and subscription details and history. We may also ask you or allow you to submit certain additional optional information, which may include your phone number, location, preferences, information about other approved drivers of your vehicle, demographic information, and other profile information.
   • Biometric and credentials: you may able to enroll a biometric identifier (e.g., fingerprint or facial recognition) to establish a biometric access credential for access certain features and Services, such as digital key and other Connected Services. (See our SiriusXM Guardian and Brand Connect Privacy Policies for more information.)
   • Communications and support: if you contact us by email, mail, phone, chat or otherwise regarding the Services, we collect and maintain a record of your contact details, communications, and our responses. If you call us, we may also record calls and maintain logs and records of those calls.
   • Inquiries and requests: we also collect personal information when you submit information to or request information from us (such as request a quote, find a vehicle, or locate a dealer) or sign up for marketing and communications from us (such as related to FCA Canada product launches, special offers, and upcoming FCA vehicle and product releases). The information we may collect includes your name, contact information, location, vehicle of interest, current vehicle, and other information.
   • Survey, events, and promotions: we may also run contests, sweepstakes, or other promotions or participate in certain events (collectively, “Events”), online, and offline. If you choose to participate in an Event, we may ask you for personal information, including your name, age, contact information, vehicle of interest, or other information. Certain Events may be co-branded with one of our partners or run on an external website, such as Facebook. In these instances, the collection of your personal information may occur directly or through an external website. If you respond to surveys or similar requests that we send or sponsor, we will collect and use your survey responses and other information.
   • User content: if you choose to engage in forums, blogs, or similar features offered by us as part of the Services, we may maintain records about the content you post, such as comments, reviews or questions, as well as date and time and other metadata associated with your user content. User content may also be viewable by other visitors and users of the Services.
   Information We Collect from Third Parties. We may also collect personal information about you and your vehicle from third parties and other sources, such as:
   
   • FCA dealers: FCA authorized dealers (independently owned and operated businesses) may provide us with purchase, payment, and finance information (when you purchase or lease one of our vehicles from them), information about vehicle maintenance, services, repairs, warranty claims, quality, and customer support, as well as data about prospective buyers.
   • Third-party data: such as vehicle sales records and motor vehicle records, as well as third-party data providers that provide us with information to update and enhance our customer records and provide us with leads including lists of potential vehicle purchasers, current, or former owners.
   • Affiliates and partners: including third-party providers of certain features or portions of the Services or Connected Services. Also, if you take advantage of a third party or affiliate offer through the Services, we may receive information from that third party about your interaction with them.
   • Third-party platforms: such as platform providers and app stores (e.g., through which our Apps are available) and social media platforms. For example, if you post information about us or engage with us or our content on social media and other third-party platforms, we may obtain personal information about you from that third-party platform. These third-party platforms and services control how your personal information is collected, shared, and displayed through their respective platforms. Also, if you log in through or integrate a third-party account (such as Google, Amazon, Apple) with our Services, we may access and obtain certain information from your account (as authorized by you and subject the applicable terms of the third-party platform).
   Information Derived or Collected Automatically. We may derive or automatically collect information, including personal information related to you or your use of our Services.
   
   • Connected Services: as further set forth in the FCA Connected Services Privacy Notice, we collect and derive personal information through our Connected Services, including information about you and your vehicle, as well as other users of your vehicle and the Services, such as vehicle usage and performance data, driving data, geolocation data, settings and presets, and features and services accessed and used (including third party provided), and other information related to your use of our Connected Services.
   • Browsing and usage data: as more described in our Cookie Notice, we may collect personal information automatically (e.g., via cookies and pixel tags) about how you use and interact with our Services, such as IP address, app identifier, advertising ID, location information, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, and the links you click and your other activities within the Services. We may also use pixels in HTML emails to understand if individuals read the emails we send to them. We also may collect geolocation information through our Apps and the Connected Services, or derive your location based upon your device IP address. In addition, we may derive certain insights about you based on this and other personal information we have collected about you.
   • Other information: we may collect personal information if you call or contact us, we may also maintain call records for quality, training, and support purposes.
   We may link this personal information with the other information we have collected about you. For more information, see our Cookie Notice.
5. HOW WE USE PERSONAL INFORMATION
   While the purposes for which we may process personal information will vary depending upon the circumstances, in general, FCA Canada collects, uses, discloses, and otherwise processes personal information we collect as set forth below or otherwise directed or authorized by you:
   • Providing our Services and related support: to provide and maintain our Services; to authenticate users; to perform technical operations, such as updating software; to provide and communicate with you about our Websites, Services, vehicles and other products; to respond to your requests; to administer events that you participate in; to fulfill your orders and process your payments; to provide technical support; and for other customer service and support purposes.
   • Safety, recall, and warranty: for safety, recall, and warranty purposes, such as to send recall notices, process recall and warranty claims, and for other purposes related to vehicle safety.
   • Research and analytics: to better understand how users access and use our vehicles and other products and the Services, for other research and analytical purposes, such as to evaluate and improve our Services and business operations, develop new features, products, or services, for quality and training purposes, and to otherwise improve our Services and user experiences.
   • Communicating with you: to provide you with the information or services that you have requested (e.g., to provide a quote or to contact you to book a test drive); to communicate with you about your use of our Services; to respond to your inquiries; to administer surveys and questionnaires, such as for market research or user satisfaction purposes; and for other customer service purposes.
   • Personalizing content and experiences: to personalize content for you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
   • Advertising, marketing and promotional purposes: to contact you about our products or services or send you newsletters, offers, or other information we think may interest you; to administer promotions and contests; to reach you with more relevant ads; and to measure and improve our advertising and marketing campaigns. 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 (like Facebook) to create customer audiences and deliver 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.
   • Supporting our general business operations: relating to audits and assessments of our business operations, security controls, financial controls, compliance with legal obligation, and otherwise relating to the administration of our general business, accounting, record keeping, and legal functions.
   • Planning and implementing business transactions: to plan and implement an actual or contemplated merger, acquisition, financing, sale, bankruptcy, or restructuring of all or part of our business or assets.
   • Securing and protecting our assets and rights: to protect our business operations, secure our network and information technology, assets, and services; to prevent and detect fraud, unauthorized activities, access, and other misconduct; where we believe necessary to investigate, prevent, or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities, and other situations involving potential threats to the rights or safety of any person or third party.
   • Complying with legal obligations: to comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
6. DISCLOSURE OF PERSONAL INFORMATION
   We may disclose personal information for the purposes set out above, in Section 5: How We Use Personal Information, such as where reasonably necessary to provide, secure, and improve our products and Services, to reach users with more relevant information and offers, for warranty and safety purposes, to protect our rights and the rights of others, to comply with our legal and regulatory options, to make available third-party offers you may be interested in, to carry out your requests, and as otherwise authorized or directed by you. In accordance with these purposes, personal information may be disclosed to the following type of third parties:
   
   Affiliates, Vendors, and Providers. We may share or disclose personal information to our vendors and others who we work with to make certain services available, such as:
   • Affiliates and subsidiaries: we may share your personal information with our affiliate and subsidiary companies, who may use and disclose your personal information in accordance with this Privacy Policy.
   • Vendors and service providers: we may disclose personal information to our third-party vendors, service providers, contractors, or agents who process such data in order to provide services to us or to perform functions on our behalf.
   • Third-party services and providers: some of the Services we make available to you may be provided or supported by third parties (e.g., cellular data carriers, navigation and traffic services), 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 Services. In addition, some of our Websites and other Services may enable you to make purchases from third-party businesses. Any time you order from a third-party business, that business will collect your personal information as part of your order. The use of your personal information by these third-party businesses will be subject to their respective privacy policies and terms, and these third parties may contact you directly, for promotional and transactional purposes.
   Dealers and Other Third Parties. We may share personal information with dealers and other select third parties, for marketing, research, and analytics purposes.
   • Dealers: we may share personal information, such as name, contact information, and other data about your vehicles or interests, with our authorized dealers in your area so that they may contact you about your vehicle needs and purchase plans, or otherwise reach out to you for marketing purposes.
   • Marketing and advertising partners: we may share your personal information with third parties that provide advertising, campaign measurement, analytics, and related services to us. These third parties may receive or access usage data, and other personal information to help us better reach individuals with relevant ads and measure our ad campaigns, or to better understand how individuals interact with our Websites and Services.
   • Programs and offers: we may invite you to participate in co-sponsored or third-party promotional offers and programs. If you choose to participate in one of these programs or third-party offers or indicate your interest in receiving information about the third-party offer, we may share your personal information with that third party to facilitate your request. For example, if you enter a co-sponsored contest and choose to receive marketing communications from a third party, we will share your personal information with that third party to facilitate your request. The use of your personal information by these third parties is subject to their respective privacy policies.
   • Others: we may disclose certain information to select third parties who may use this information to support features of your vehicle, or for research, surveys, development, analytics, and marketing purposes, such as to better understand aggregate driving and traffic patterns, update maps and route details, and analyze road conditions, analyze vehicle usage data, driving data, and trip data. We also may share your personal information with certain third parties so that they may send you offers and other information we think you may be interested in. For example, we may disclose certain information to providers of satellite radio, navigation systems, or charging services.
   Please see Section 7: How You Can Adjust Your Preferences for details on how to opt out of our sharing of your personal information with third parties.
   
   Other Individuals. If you are an owner and you permit another driver to register your vehicle for Connected Services or to otherwise access and use your account, then you acknowledge and agree that such individual(s) may have access to your account and associated personal information about your vehicle(s). Further, if you post user content, this may be viewable by other users of the Services.
   
   Business and Operational Purposes. In addition, we may disclose personal information 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 Canada, third parties or the general public, including to protect the 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 personal information as evidence in litigation in which we are involved, and as necessary to enforce this Privacy Policy or our Terms 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 of or request by law enforcement or a government official.
   • Recruitment and job applications: Personal Information like that 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.
7. HOW YOU CAN ADJUST YOUR PREFERENCES
   You may withdraw your consent to certain uses of your personal information by FCA Canada, subject to legal or contractual restrictions, by sending an email to privacyofficer.ca@stellantis.com.
8. 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 14 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 14, we do not use or disclose such information to third parties.
9. 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.
   
   Data Governance. FCA Canada maintains policies and practices to ensure the protection of your Personal Information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:
   • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access on a “need-to-know” basis;
   • Designated Privacy Officer to monitor FCA Canada compliance with applicable data protection laws;
   • Regular employee privacy and data security training;
   • Procedures for receiving, investigating and responding to complaints or inquiries regarding our information handling practices, including any security incidents involving personal information;
   • Framework governing the retention and destruction of personal information;
   • Contractual protections and other measures to ensure that service providers, vendors, and suppliers with whom we share personal information maintain adequate privacy protections and standards. For example, we generally require them to limit their use and retention of personal information to what is necessary to provide their services and to notify us in case of any actual or suspected security breach. We also try to monitor and audit their compliance with these requirements in various ways (e.g., on-site inspections (if feasible), surveys and interviews, proof of certification).
10. HOW LONG WE KEEP PERSONAL INFORMATION
    FCA Canada retains Personal Information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, Personal Information will be securely destroyed or anonymized (so the information no longer identifies an individual either directly or indirectly).
11. LINKS TO THIRD PARTIES 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.
12. HOW YOU CAN ACCESS AND CORRECT YOUR PERSONAL INFORMATION
    You may 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@stellantis.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.
13. 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. 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.
14. 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@stellantis.com.
15. 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. If we make any changes to the Privacy Policy, we will post a notice on our Websites and/or Applications and we may seek your consent where required by law. 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.
16. 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 or by mail.
    
    MAIL:
    FCA Canada Privacy Officer
    Customer Care Centre
    P.O. Box 1621
    Windsor, ON
    N9A 4H6