INEOS AUTOMOTIVE PRIVACY NOTICE

INEOS

Privacy Notice (USA)

Last Modified: October 17, 2023

INEOS Automotive Americas, LLC respects your privacy and is committed to protecting your personal data. This Privacy Notice (this “Notice”) provides United States persons with information about our personal data collection, use, and disclosure practices, as well as information about your privacy rights and choices.

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

This Notice is a part of our Website Terms of Use and is incorporated therein by reference.

This Notice is provided in a layered format so you can click through to the specific areas set out below.

1. PURPOSE AND APPLICABILITY OF THIS NOTICE
2. ACCEPTANCE OF THIS NOTICE
3. CHANGES TO THIS NOTICE
4. THE PERSONAL DATA WE COLLECT
5. HOW WE COLLECT PERSONAL DATA; SOURCES OF PERSONAL DATA
6. HOW WE USE YOUR PERSONAL DATA
7. WHEN AND WHY WE DISCLOSE PERSONAL DATA TO OTHERS
8. COOKIES; INTEREST-BASED ADS; DO NOT TRACK
9. HOW LONG WE RETAIN PERSONAL DATA
10. DATA SECURITY
11. THIRD PARTY SITES AND SOCIAL SHARING FEATURES
12. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

1. PURPOSE AND APPLICABILITY OF THIS NOTICE

INEOS Automotive Americas, LLC is providing this Notice to inform you about how we collect and process your personal data. 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 Notice refer to each INEOS Group member that collects and processes your personal data.

We may provide you with supplemental or additional privacy notices on specific occasions when we collect or process personal data about you. On those occasions, it is important that you read this Notice together with all such other notices, so that you can be fully aware of how and why we are using your personal data. This Notice supplements all other and additional privacy notices, and is not intended to override any of them (and vice versa).

Neither our site nor our products and services are targeted to, and we have no interest in collecting information from, children under the age of 13. We do not knowingly gather any personal data from children. If you are a parent or legal guardian who believes that your child has provided us with any personal data, please contact us at dataprotection@ineosgrenadier.com.

2. ACCEPTANCE OF THIS NOTICE

Your use of the site, and all communications between you and us, are subject to this Notice. YOU SHOULD READ THIS NOTICE COMPLETELY AND CAREFULLY BEFORE USING THE SITE AND/OR PROVIDING US WITH ANY INFORMATION, PARTICULARLY PERSONAL DATA. By using the site in any way, including browsing, creating an account, expressing an interest in any products, and/or using any interactive site tools, or by otherwise providing us with any personal data, you acknowledge that you have read, understood, and agreed to be bound by this Notice.

3. CHANGES TO THIS NOTICE

Because of changes in technology and practices, this Notice may change from time to time. We will post any changes we make to this Notice on this page, and we will provide you notice of such changes if and when required by applicable law. Any changes will be effective when the updated Notice is posted.

It is your responsibility to check this Notice for updates. You will be able to determine when the Notice was last updated by referring to the “Last Modified” date at the top. By using the site and/or providing us with any personal data after we post any changes to this Notice, you agree to accept those changes, whether or not you have taken the time to review them.

4. THE PERSONAL DATA WE COLLECT

Personal data, or personal information, means any information about an individual that can be used to identify that individual. Personal data does not include anonymous or anonymized data that cannot be used to identify a specific person.

INEOS may collect, use, store, and transfer different categories of personal data, as follows:

• Identity Data, which includes first name, last name, title, user name, or similar identifiers, date of birth, gender, marital status, and driver’s license number.
• Contact Data, which includes physical address, email address, and telephone numbers.
• Financial Data, which includes bank account and payment card details.
• Transaction Data, which includes details about payments to and from you and products and services you have purchased from us or our dealers, as well as insurance information.
• Technical Data, which includes 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 the device(s) you use to access our site.
• Profile Data, which includes your user name and password, purchases or orders made by you, your interests and preferences, and feedback and survey responses.
• Usage Data, which includes information about how you use our site, products, and services.
• Geolocation Data, which (depending on vehicle features and service availability) includes your vehicle’s location.
• Marketing and Communications Data, which includes your preferences in receiving marketing communications from us and our third-party service providers, and your other communications preferences.
• Social Network Data, which includes information that you share publicly or that is a part of your public profile on a third party social network, such as user name, location, profile picture, friends lists, photos, videos, posts and stories, and similar media and content.
• Market Research Data, which includes information about how you use our site, products, and services, as well as survey responses and other feedback you provide.

We do not collect or use data that is or may be considered “Sensitive Data”, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or information about criminal convictions and offenses.

We also collect, use, and disclose “Aggregated Data,” such as statistical or demographic data. Aggregated Data may be derived from personal data, but it is not considered personal data because it does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of website users accessing a specific site feature. However, if we ever do combine or connect Aggregated Data with other personal data such that it could directly or indirectly identify you, we will treat the combined data as personal data in accordance with this Notice.

5. HOW WE COLLECT PERSONAL DATA; SOURCES OF PERSONAL DATA

We use different methods to collect personal data from and about you, including as follows:

• Direct Interactions. From time to time, you may provide us with your personal data by filling in forms or by corresponding with us by mail, telephone, email, social media, or otherwise. This includes personal data you provide when you:
  
  • Reserve or purchase our products or services, or express an interest in our products or services;
  • Create an account on our site;
  • Subscribe to services, promotions, or publications;
  • Request that marketing or other materials be sent to you;
  • Enter a competition, promotion, or survey;
  • Sign up for, register for, pay for, and/or attend any event that we sponsor or co-sponsor;
  • Create and share content with us through third-party social networks, such as by commenting on our social media pages;
  • Provide information in connection with our “Careers” web pages;
  • Provide us with feedback; and
  • Otherwise contact or communicate with us for any reason.
• Dealer Interactions. You may provide personal data to our authorized dealers that is then shared with us through our dealer and/or customer relationship management system. This includes personal data you provide to dealers:
  • When creating a customer account;
  • In connection with your interest in, purchase of, or servicing of an INEOS vehicle from or at the dealer; and
  • In connection with test drives, dealer vehicle loans, and dealer-operated events.
  Please note that this Notice only applies to information that is collected by our dealers and then shared with INEOS, and only applies to INEOS’s use of that information. Our dealers may collect, use, and share your personal data in other ways, and we do not and cannot control their collection, use, and sharing of information. For more information about our dealers’ privacy practices, you should review the privacy notice(s) provided by the applicable dealer, or ask that dealer for more information.
• Automated Technologies and Interactions. As you interact with our site, we may automatically collect data including Technical Data, Usage Data, and Market Research Data, such as information about the equipment used to access the site and your browsing actions and patterns. We collect this information using cookies, server logs, and other similar technologies. We may also receive this data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
• Third Party and Publicly Available Sources. We may receive personal data, including Technical Data, Usage Data, and Market Research Data, from third parties and public sources, such as:
  • Analytics providers such as Google Analytics;
  • Search information providers;
  • Providers of technical, payment, delivery, and other services;
  • Data brokers or aggregators; and
  • Third party social media sites and applications.

6. HOW WE USE YOUR PERSONAL DATA

We use the personal data we collect for the following business and commercial purposes:

• To register new customers and prospects;
• To create, maintain, customize, and secure site user accounts;
• To process and deliver orders, which includes managing payments, fees, and charges as well as collecting and recovering amounts owed to us;
• To manage our relationship with vehicle owners;
• To communicate with and provide services to our customers and prospects;
• To respond to questions and requests;
• To coordinate and record warranty service;
• To provide notice of recalls or service actions;
• To coordinate participation in events, competitions, promotions, and surveys;
• To understand site usage patterns and behavior;
• To provide, support, personalize, and develop our site, products, and services;
• To evaluate and improve our customer and user experiences, including delivering relevant site content and advertisements to you;
• To engage in research and development and run technical campaigns;
• For data enrichment and to understand our customer and prospect base;
• To engage in promotional or marketing effects (subject to any consent or opt-out rights required by law); and
• To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance and support, and reporting and hosting of data).

In addition, we may use any of the personal data we collect for the following purposes:

• To prevent transaction or user fraud, and to help maintain the safety, security, and integrity of our site and our business;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which personal data is among the assets transferred or is otherwise material to the transaction.

We will only use your personal data for the purposes disclosed in this Notice or in any supplemental notice provided to you at or prior to our collection of that personal data, or for any reasonably compatible purpose, and subject to limitations and requirements of applicable law. If we need to use your personal data for any unrelated purpose, we will notify you and, if required by law to do so, will obtain your consent.

7. WHEN AND WHY WE DISCLOSE PERSONAL DATA TO OTHERS

We may disclose personal data as described below:

• We may disclose personal data within and among the INEOS Group to manage customer and prospect relationships and for other business and commercial purposes consistent with those disclosed above.
• We and our authorized dealers may disclose personal data to one another for sales and customer service purposes and for other business and commercial purposes consistent with those set forth above.
• We may disclose personal data to our service providers and contractors in the ordinary course of our business relationship with those parties. This may include parties who provide us with IT and system administration services, process credit cards and payments, manage shipping and deliveries, manage and service our site and/or data, assist with email distribution, provide research and analysis services, manage brand and product promotions, and/or administer certain site or product features.
• For vehicles equipped with connected services, we will share personal information with the service providers providing those services. For example, if you purchase a vehicle equipped with Sirius XM, we will share your information with Sirius XM in order to be able to provide the Sirius XM service.
• We may disclose personal data to other service providers who act as professional advisors to us, including lawyers, bankers, accountants, insurers, and others who provide similar services.

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

We may 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 corporate transaction as described above, we will disclose information with the applicable counterparty in connection with that transaction.

We will not disclose your personal data other than as described in this Notice without providing you notice and, if required by law, obtaining your consent. We do not sell personal data to third parties.

8. COOKIES; INTEREST-BASED ADS; DO NOT TRACK

Our site uses and allows certain third parties to use cookies and similar tracking technologies. We notify you of our use of cookies when you first visit our site. For more information about our use of cookies, see our Cookies Policy.

We use third party advertising companies to deliver and display ads tailored to you based on how you interact with our site, a practice known as interest-based advertising or behavioral advertising. In connection with this practice and as disclosed in our Cookie Policy, we allow these third parties to collect certain information about you when you visit our site, through the placement of cookies or other tracking technologies. To learn more about interest-based/behavioral advertising, please visit the DAA Website or the Network Advertising Initiative Website. If you wish to opt-out of these types of cookies, you can do so here.

Currently, certain browsers, including Firefox, Google Chrome, Safari, and Internet Edge, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by a user about the user’s DNT preference, if any, set on the browser. If you activate DNT, we cannot currently commit to responding to your browser’s DNT signals, because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.

9. HOW LONG WE RETAIN PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfil the purpose(s) for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

We retain contact, identity, financial, and transaction data about our customers for six years after they cease being customers for tax purposes.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research, analytic, or statistical purposes, in which case we may retain such information indefinitely, as such information will cease to be personal data.

10. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, or used, disclosed, or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, service providers, contractors, and other third parties who have a business need to know that information, who are only authorized to process your personal data on our instruction, and are subject to confidentiality obligations.

We have put in place procedures to address any suspected or actual personal data breach, and will comply with applicable laws relating to notification of and response to any personal data breaches or other security incidents.

It is your responsibility to keep all information associated with your account with us secure and confidential. We will never ask for any password from you, except as required to create your account (in which case, your password may be stored by your device, but will not be accessible to us).

11. THIRD PARTY SITES AND SOCIAL SHARING FEATURES

Our site may include links to other websites. We do not control the privacy practices of any third parties, and if you submit personal data to any of those sites, their collection and use of your information is governed by their privacy policies, which differ from ours. We encourage you to carefully read the privacy policy of any website you visit.

Our site may offer social network and similar sharing features, such as Facebook, Twitter, YouTube, Instagram, and similar buttons, which let you share information related to the site through your preferred social media platforms. If you permit a connection between our site and your social network page(s), we (and the social network) may be able to identify you, and associate the information we (and they) receive with information we (and they) already have about you. In addition, depending on how you use those features and your settings with the social network provider(s), the information you share to your social network pages will be available to others, including your friends and/or the public. For more information about how your information may be shared through those social networks once it is provided to them, you should review the privacy policies of those social networks.

12. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

A. Rights Applicable to United States Persons

If you are located in the United States, you have the rights described below regarding our collection and use of your personal data. These rights are subject to certain limitations and exceptions under applicable law.

Providing Personal Data is Your Choice. You can browse our site without providing us with any personal data, other than browsing data (which we will not attempt to link with other personal data). However, if you choose to use our site to engage with us, such as by creating an account, or if you choose to conduct business with or otherwise interact with us, you will be required to provide us with the personal data necessary to facilitate that interaction or transaction. If you do not want to provide us with personal data, we may not be able to conduct business with you or provide you with requested information.

You Have the Right to Opt Out of Certain Communications. You can ask us to stop sending you marketing and other promotional materials at any time by following the opt-out links in the applicable messages, or by contacting us at any time at dataprotection@ineosgrenadier.com. Please note that when you opt out of marketing messages, we may still need to contact you regarding outstanding orders, product purchases or services, warranty registration, your product or service experience, as required by law, or regarding legal matters. However, we will not send you marketing communications after you have opted out of receiving them.

You Have the Right to Access Your Personal Data. You have the right to confirm whether we are processing your personal data and, if so, to access information about the specific items of personal data we have collected about you. If you request a copy of your personal data, you have the right to receive it in a portable and, to the extent technically feasible, readily-usable format that allows you to transmit the data to another party without undue difficulty.

You Have the Right to Correct Your Personal Data.If you believe any personal data we have about you is incorrect, you can contact us at any time at dataprotection@ineosgrenadier.com to request that we make the appropriate edits to correct that information. In addition, if you have an account on our site, you may be able to update certain of your account details directly through the site.

You Have the Right to Request Deletion of Your Personal Data. As noted above, we have standard retention practices with respect to the personal data we collect. If you would like to request any earlier deletion of your personal data, you may contact us at dataprotection@ineosgrenadier.com with this request. Please note that we may not be able to completely remove personal data in certain circumstances. This will be true if the data is not in a searchable format, or if it is retained in backup systems or in cached or archived pages. We also may not be able to delete personal data to the extent it is necessary to conduct active and ongoing business with you, if we are required by law to retain it, or keeping the information it is necessary to comply with our legal obligations, resolve disputes, prevent fraud or future abuse, or otherwise enforce our rights.

You Have the Right to Opt Out of Targeted Advertising. As noted above, we use third party advertising companies to deliver and display ads tailored to you based on how you interact with our site, a practice known as interest-based advertising or behavioral advertising. You have the right to opt out of having your personal data used for this purpose. To exercise this right, you can set your cookies preferences here.

You Have the Right to Opt Out of Certain Disclosures of Your Personal Data. As noted above, we may disclose Personal Data to certain service providers who provide connected services in our vehicles. If you would like to opt out of such disclosure, please contact us at dataprotection@ineosgrenadier.com. Please note that if information has already been disclosed to the connected service provider, that information will be subject to the third party’s information collection, processing, use, and disclosure practices, and you may need to contact the third party service provider directly to make any changes with respect to such practices.

Limitations. Each of the rights set forth above may be subject to certain limitations as set forth in applicable law. Your rights may depend on your state of residence, as different states have adopted privacy laws that provide for specific rights and remedies applicable solely to residents of such states.

Exercising Your Rights. To exercise any of the above rights, or if you have any questions regarding our practices regarding personal data, please contact us at dataprotection@ineosgrenadier.com. Please note that we may be required to request information from you to verify your identity in connection with any such request, as a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it. If you make any request to exercise your rights, we will respond within the time period required by law (or if no time period is required, within a reasonable period of time). If we are unable to comply with your request, we will inform you of this. If you do not agree with any action we have taken following a request to exercise your rights, or otherwise object to our handing of your personal data, you may have the right to appeal or to raise your objection with your state’s regulatory authority. We would, however, appreciate the opportunity to address your concerns directly before you approach a regulatory authority, so please contact us in the first instance, at dataprotection@ineosgrenadier.com.