INEOS

Supplemental Privacy Notice for California Residents

Last Modified: 05/12/2023

 

This Supplemental Privacy Notice for California Residents (“California Notice”) is a part of, and supplements, the INEOS Automotive Americas, LLC Privacy Notice (the “Privacy Notice”), available here.

 

This California Notice applies solely to residents of California (who are referred to as “you” or “your” in this California Notice). This California Notice is being provided as required by the California Privacy Rights Act of 2020 (which amended and replaced the California Consumer Privacy Act of 2018, and is referred to as the “CPRA”). Any terms defined in the CPRA (such as “personal information,” “consumer,” “service provider,” “contractor,” “third party,” “sale/sell,” and “share”) will have the same meaning when used in this California Notice.

 

INEOS Automotive Americas, LLC is providing this California Notice to inform you about how we collect and process your personal information. INEOS Automotive Americas is part of the INEOS group of companies (the “INEOS Group”), details of which can be found at https://www.ineos.com/. References to “INEOS,” “us,” “we,” or “our” in this California Notice refer to each INEOS Group member that collects and processes your personal information.

 

This California Notice is made available through the INEOS-operated websites and applications in the United States, including the sites and applications that link to this California Notice such as https://ineosgrenadier.com/en/us/ (which we refer to collectively in this California Notice as the “site,” which also includes all associated content, functionality, and services offered on or through the site).

1. THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

For purposes of the CPRA, the table below describes the categories of personal information we collect, our business and/or commercial purpose for collecting and using that personal information, and our retention period for that personal information (or, the criteria used to determine the retention period).

Categories of Information We Collect	Examples of Information Collected in this Category	Business and/or Commercial Purpose	Retention Period
A.Identifiers	First name, last name, title, user name, similar identifiers, data of birth, gender, marital status, physical address, email address, telephone number, driver’s license number	Engaging in commercial transactions, such as sales of INEOS vehicles and related products Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, or providing similar services (referred to as “performing services” in the remainder of this table) Providing advertising and marketing services Helping ensure security and integrity of our site and business Internal research purposes Quality and safety maintenance and to improve, upgrade, and enhance our products and services	For the duration of our business or prospective business relationship, plus an additional 6 years.
B.Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code §1798.80(e))	Name, address, telephone number, bank account number, credit card number, debit card number, other financial information, insurance policy number, employment information	Engaging in commercial transactions, such as sales of INEOS vehicles and related products Performing services Providing advertising and marketing services Helping ensure security and integrity of our site and business Internal research purposes Quality and safety maintenance and to improve, upgrade, and enhance our products and services	Identification information is kept for the duration of our business or prospective business relationship, plus an additional 6 years. Financial information is kept only for so long as necessary to complete a transaction.
C.Protected classification characteristics under California or federal law	Age (40 years or older), national origin, citizenship, gender	Engaging in commercial transactions, such as sales of INEOS vehicles and related products Performing services Providing advertising and marketing services Internal research purposes Quality and safety maintenance and to improve, upgrade, and enhance our products and services	Identification information is kept for the duration of our business or prospective business relationship, plus an additional 6 years.
D.Commercial information	Records of products or services purchased or considered, including the VIN of purchased vehicles and other vehicle information such as the service record Details about payments to and from consumers	Engaging in commercial transactions, such as sales of INEOS vehicles and related products Performing services Providing advertising and marketing services Helping ensure security and integrity of our site and business Internal research purposes Quality and safety maintenance and to improve, upgrade, and enhance our products and services	Purchase information will be retained for so long as required for warranty and service purposes.
E.Internet or other similar network activity	Internet protocol (IP) address, login data, browser type and version, time and location settings, browser plug-in types and versions, operating system, platform, and other technology on device(s) used to access our site Site usage data, including how you interact with the site	Engaging in commercial transactions, such as sales of INEOS vehicles and related products Auditing (e.g. counting unique visitors, verifying positioning and quality of ad impressions) Helping to ensure security and integrity of our site Debugging to identify and repair errors Internal research purposes Quality and safety maintenance and to improve, upgrade, and enhance our products and	Information collected via third-party cookies will be retained in accordance with the data retention practices of the third party (for example, Google retains analytics data collected from cookies for a period of up to 2 months). Information collected by us through first-party cookies will be retained in accordance with our IT data retention policy.
F.Geolocation data (physical location or movements)	Physical location or movements, such as the GPS location of a vehicle	Performing services, specifically receiving and responding to roadside assistance requests Collection of data in this category is subject to the availability of certain services that may be activated/deactivated in certain vehicles	Geolocation data that may be linked to a particular individual and is related to particular services (i.e., roadside assistance) will be retained only for the transitory period as necessary to provide the service.
G.Sensory data (such as audio, electronic, visual, or similar information)	Audio, electronic, and visual information	Performing services, specifically responding to roadside assistance and other service requests (which may be recorded for quality assurance purposes) Safety and fraud/theft prevention	Sensory data that may be linked to a particular individual and is related to particular services (i.e., roadside assistance) will be retained only for the transitory period as necessary to provide the service. Telephone and other electronic recordings may be retained in accordance with our IT data retention policy.
H.Professional or employment-related information (such as current or past job history or performance evaluations)	Occupation and business title	Performing services	For the duration of our business or prospective business relationship, plus an additional 6 years.
I.Inferences drawn from other personal information – personal preferences and characteristics	Purchases and orders Interests and preferences Feedback and survey responses Communications and marketing preferences Social network data Market research data	Engaging in commercial transactions, such as sales of INEOS vehicles and related products Performing services Providing advertising and marketing services Internal research purposes Quality and safety maintenance and to improve, upgrade, and enhance our products and services	Identification information is kept for the duration of our business or prospective business relationship, plus an additional 6 years. Purchase information will be retained for so long as required for warranty and service purposes.

For purposes of the CPRA, we do not collect any categories of information defined as “Sensitive Personal Information,” because we do not use any information defined as sensitive personal information within the CPRA for the purposes of inferring characteristics about the person with respect to whom it was collected.

 

Regarding the retention periods set forth above, the above indicate our general practices with respect to document destruction. We maintain a document retention policy that provides for specific retention periods and document destruction practices in accordance with legal requirements and industry best practices.  

 

For more information about our business and commercial purposes for using personal information, see our main Privacy Notice, Section 6 (How We Use Your Personal Data).

2. THE SOURCES OF THE PERSONAL INFORMATION WE COLLECT

We obtain the personal information identified above from the following categories of sources:

 

• Direct Interactions
• Dealer Interactions
• Automated Technologies and Interactions
• Third Party and Publicly Available Sources

 

For more information about each of these sources, see our main Privacy Notice, Section 5 (How We Collect Personal Data; Sources of Personal Data).

 

3. OUR DISCLOSURE OF PERSONAL INFORMATION

As disclosed in our main Privacy Notice, Section 7 (When and Why We Disclose Personal Data To Others), we may disclose personal information to certain service providers, contractors, and third parties. For purposes of this California Notice, below are the categories of persons to whom we may disclose personal information:

 

 

• INEOS Group Members: We may disclose personal information within the INEOS Group for business and commercial purposes consistent with those identified above.
• INEOS Dealers: We may disclose personal information to and within our dealer network for business and commercial purposes consistent with those identified above.
• We disclose information to our service providers and contractors (neither of whom are considered third parties for purposes of the CPRA), in the ordinary course of our business relationships with those parties.
• We disclose information to analytics providers (such as Google Analytics) so they can help us evaluate our websites’ performance.

 

 

When we disclose personal information to service providers, contractors, and third parties in the circumstances noted above, we enter into agreements with those third parties that describe the purposes for which the personal information may be used and that require the third party to keep that personal information confidential.

We will also disclose information as necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. And, if we engage in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which personal information held by use about our website users is among the assets transferred, we will disclose information to the applicable counterparty in that transaction

4. INFORMATION ABOUT SELLING AND SHARING PERSONAL INFORMATION

For purposes of the CPRA:

 

• “Selling” personal information is defined as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for monetary or other valuable consideration; and
• “Sharing” is defined as sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating information with third parties for cross-context behavioral advertising, whether or not for monetary or other consideration. “Cross-context behavioral advertising” in turn is defined as targeting or advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than INEOS’s distinctly-branded website, application, or service with which you have intentionally interacted.

 

As noted in our Cookies Policy available here, INEOS places, and allows others to place, cookies on our site for purposes of targeted advertising. This practice may constitute a sale under the CPRA. Accordingly, you have the right to opt out of our using your personal information in this purpose, by following the “DO NOT SELL OR SHARE MY PERSONAL INFORMATION” link on our site. 

 

In addition, we note the following to help you better understand why some information disclosures are not considered sales or sharing of information, and accordingly will not be subject to any opt-out right provided by the CPRA.

• As noted above, we disclose information to our service providers and contractors who need the information in order to perform contracted services for us. As described above, we enter into agreements with each service provider that limit the purposes for which the personal information may be used and that require the third party to keep that personal information confidential. With these protections, these transfers are not considered “sales” under the CPRA.
• In addition, if a consumer uses or directs a business to intentionally disclose personal information to a third party, or uses a business to intentionally interact with a third party, then disclosing personal information to that third party is not considered a “sale” under the CPRA. This applies to many circumstances where we acquire or disclose personal information as among the INEOS Group and our INEOS dealers. For instance, if a prospective INEOS customer provides its contact information on the INEOS website and requests to be connected to an INEOS dealer for more information, we may disclose the consumer’s personal information to our dealers. Similarly, if a consumer requests more information about an INEOS event, we may transfer the consumer’s contact information to a third-party event planner to contact the consumer on our behalf with more information about the event. Neither transfer of information would be considered a “sale” pursuant to the CPRA.
• As a vehicle manufacturer, the CPRA also expressly permits us to disclose information in connection with effectuating a warranty-covered repair or a government-mandated recall, without such transfer of information constituting a “sale” under the CPRA.

 

Finally, you can disable certain personal information from being collected by targeting cookies on our website by updating your cookie preferences. For more information about our use of cookies and your options, see our Cookies Policy.

5. YOUR RIGHTS AND CHOICES UNDER THE CPRA

The CPRA provides California residents with certain specific rights regarding their personal information. This section describes your CPRA rights, and explains how to exercise them. Please note that your rights are subject to limitations and exceptions described in the CPRA.

 

• Right to Know – You have the right to ask us to provide you with information about our collection and use of your personal information over the past 12 months.
• Right to Access (Data Portability) – You have the right to ask us to provide you with copies of personal information that we have collected about you, in a portable and readily-usable format. Please note that access requests may be made free of charge up to twice in any 12-month period.
• Right to Request Deletion – You have right to ask us to delete personal information about you that we have collected and retained.
• Right to Correct – If you believe any personal information we have about you is incorrect, you have the right to request that we rectify any inaccuracies.
• Right to Non-Discrimination and Non-Retaliation – You have the right not to be discriminated or retaliated against for exercising any of your CPRA rights.
• Right to Opt Out of Sales or Sharing (for Cross-Context Behavioral Advertising) – You have the right to ask us not to sell or share (for cross-context behavioral advertising) your personal information.

 

To exercise any of the rights described above, you must submit a verifiable consumer request to us. You can do so by:

 

• Emailing us at dataprotection@ineosgrenadier.com
• Calling us at 1-833-494-4748
• To opt out of sales or sharing of your personal information, by following the “DO NOT SELL OR SHARE MY PERSONAL INFORMATION” link on our site

 

Only you, or a person registered with the California Secretary of State that you expressly authorize to act on your behalf, can make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

We cannot respond to your request or provide you with information if we cannot identify you or confirm your authority to make the request, so any request will require you to provide sufficient information to allow us to reasonably verify your identity and/or the identity and authorization of your agent (if applicable). We will only use any personal information provided in a verifiable consumer request to verify the requesting party’s identity or authority to make the request. The information requested to verify your identity, or the identity and authorization of your agent, is dependent on your relationship with INEOS and the type of information available to us.

 

We will respond to any verifiable consumer request in the manner and within the timeframes required by the CPRA.

6. OTHER CALIFORNIA RIGHTS

In addition to the CPRA, California’s “Shine the Light” law permits California residents to request certain details about our disclosure of their personal information to third parties for those third parties’ own direct marketing purposes. If you are aCalifornia residentand you would like to make such a request, please contact us at dataprotection@ineosgrenadier.com. Please note that there are legal limits on how often you can make such a request, and we are only obligated to respond to one information request per customer per year.

 

In addition, although users of our site are required to be at least 18 years old, if any California residentsunder the age of 18 have used the site, created an account, and posted content or information on the site, they can request removal by contacting us at dataprotection@ineosgrenadier.com, detailing where the content is posted and confirming that they posted it. Following such a request, we will terminate the unauthorized account, and will make reasonable good faith efforts to remove any post or information from public view, or anonymize it so that the minor cannot be individually identified. However, removal of public postings cannot ensure complete or comprehensive removal, as third parties may republish, archive, or cache web content in a manner that is out of our control.

7. CONTACT US

If you have any questions or comments about this Privacy Notice or our privacy practices, please contact us at dataprotection@ineosgrenadier.com.