·         Registration and profile data: to access and use the Portal, we require you to create an account/SID by providing us with certain required information through the My Personnel application, including your full name, email address, home address or for owners work address, date of birth, user ID, Social Security Number (SSN)/Social Insurance Number (SIN), mother’s maiden name (for international Users), phone number and password. Certain applications in the Portal may require you to provide additional information.

 ·         Programs and promotions: if you participate in any contests, events, incentives, promotions, and other programs we make available to Users, we will collect personal information about your registration and participation, eligibility, and other personal information necessary to administer the program.

 ·         Communications and support: if you contact us by email, mail, phone chat or otherwise regarding the Portal, 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 these calls.

 ·         Inquiries and requests: we also collect personal information when you submit information to or request information from us (such as requesting a new password or account). The information we may collect includes your username, dealer code, contact information, location, and other similar information.

 ·         User content: if you provide any content to the Portal, we may maintain records about the content you upload or otherwise provide, such as date, time and other metadata associated with your content. User content may also be viewable by other Users of the Portal.

 Information We Automatically Collect or Derive. As you navigate DealerCONNECT, we may automatically collect information about how you use and interact with the Portal. Such information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Portal, includes:

 ·         Browsing and usage data: information about how you use and interact with the Portal, such as IP address, app identifier, browser type, device type, domain name, the website that led you to our Portal, the website to which you go after leaving our Portal, the dates and times you access our Portal, and the pages, links, or applications you click and your other activities within the Portal.

 ·         Location data: we may collect geolocation through the Portal and our applications. We may also collect general location data based upon the IP address of a device you use to access the Portal.

 Information we receive from third parties. We may receive certain information about Users from third parties, such as dealer personnel or employers of Users. In addition, third-party providers of certain features or portions of the Portal may provide us with information from that third party about your interaction with them.

 B. ACCPA Categories of Personal Information

The If you are a resident of California, please note the personal information that we collected about Users (as described above), includes the following categories of personal information as defined by the CCPA

 ·         Name, contact information and other identifiers: includes direct identifiers, such as name, alias, user ID, username, account number, unique personal identifier, online identifier, VINs, IP address and other online identifiers or unique identifiers, email address, phone number, address and other contact information, account name, as well as government identifiers.

 ·         Paper and electronic records: includes personal information such as name, account name, user ID, contact information, education and employment information, dealer, SSN, driver’s license number and government identifiers, insurance policy number, financial or payment information and other information you provide in to register to access the portal, apply for or participate in a program we make available to Users

 ·         Internet or other electronic network activity information: : includes browsing history, clickstream data, search history, access logs and other usage data and information regarding your use of the Portal and the other websites and online we make available to you.

 ·         Geolocation data: includes location information about a particular User or device.

 ·         Audio, video and other electronic data:includes audio, electronic, visual, or similar information, such as photographs and images (e.g., that you provide us or post to the Portal), call recordings (e.g., of customer support calls) and video recordings.

 ·         Professional or employment-related information: includes information about your current employer and the dealer(s) for whom you have worked, as well as educational background.

 ·         Education history: information about your educational history (that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

 ·         Sensitive personal information:such as SSN and government identifiers. These categories of personal information are (i) used and processed by us as described inSection 3. Purposes and Use of Processing, and (ii) may be disclosed to certain third parties as described in Sec . 4 Disclosures of Personal Information.

3. PURPOSES OF USE AND PROCESSING

In general, we collect, use, disclose, and otherwise process personal information through DealerCONNECT for the following purposes or otherwise directed or authorized by you for the following purposes:

 ·         Operating the Portal and providing related services and support: to provide and maintain our Portal, to authenticate users; to perform technical operations, such as updating software; to provide and communicate with you about our Portal;

 ·         Respond to your requests: to respond to your requests; to administer promotions and programs that you participate in (e.g., a survey); to provide technical support; and for other customer service and support purposes.

 ·         Administering accounts: to create user accounts and manage access by role (e.g., by country of residence, location, or job position)

 ·         Analyzing and improving our Portal: to better understand how Users access and use our Portal, for other research and analytical purposes, such as to evaluate and improve our Portal and business operations, develop new features, products, or services, and to otherwise improve our Portal and User experiences

 ·         Personalizing content and experiences: to tailor content, we send or display on the Portal in order to offer personalized help and instructions and to otherwise personalize your experiences based on your usage and preferences.

 ·         Sending news, updates, and marketing information: to send you business communications and notices, as well as to send you news and updates, newsletters, and other information we think may interest you; and to administer promotions and programs

 ·         In support of 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, and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

 ·         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.

4. DISCLOSURES OF PERSONAL INFORMATION

We may disclose personal information for the purposes set out above in Section 3. Purposes and Use of Processing, in order to reasonably necessary to provide, secure, and improve our Portal and related services, reach users with more relevant information and offers, for 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 or as set out below.

Affiliates, vendors, and providers. We may share personal information with our vendors and others who we work with to make certain services available, such as:

 ·         Affiliates and subsidiaries: to our affiliate and subsidiary companies; however, if we do so, their use and disclosure of your personal information will be in accordance with this Privacy Notice.

 ·         Vendors and service providers:to our third-party vendors, service providers, contractors or agents who use such data in order to perform functions on our behalf. When we provide location-based services enabled through a third party, we may share data with those services in order to provide the related location-based service or functionality.

 ·         Third party services and providers:certain parts or functions of the Portal we make available to you may be supported by third parties, who may collect and receive personal information about you as part of their provision of the particular service or application, or in order to respond to a request you make via the Portal. If you click an offer or otherwise choose to take advantage of a third-party offer in the Portal, we may share your personal information with that third party to facilitate your interaction. The use of your personal information by these third parties is subject to their respective privacy policies, not this Privacy Notice

Dealers and other third parties. We may share personal information with dealers and other third parties, related to the administration of the Portal and the services provided therein, including:

 ·         Dealers: such as name, contact information and other data with our authorized dealers, for instance, so that you can be contacted regarding your requests and inquiries.

 ·         Others: By using the Portal you acknowledge and agree that content you provide to the Portal may be viewable by other users of the Portal, including other FCA dealer personnel.

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, third parties or the general public, including to protect the Portal, 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 Notice or our Terms and other applicable agreements with you.

 ·         Legal compliance: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.

Aggregate and non-identifiable information. We may use and disclose aggregate, anonymous, and other nonidentifiable data about Users for marketing, advertising, research, compliance, or other purposes. Where we use, disclose, or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except as permitted by applicable privacy laws (such as to confirm whether our deidentification processes are reasonable and adequate).

5. COOKIES AND TRACKING

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Portal and the sites, applications and services provided therein. We may combine this “usage data” with other personal information we collect about you. We use this data to understand how our Portal is used, track bugs and errors, provide and improve our Portal, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Portal and services therein. For information about our use of cookies on our other websites and our targeted advertising, please review the FCA US Privacy Policy.

Do Not Track (DNT). Our Portal and websites that link to this Privacy Notice do not respond to “do not track” signals. You may, however, disable certain tracking mechanisms in the cookie preference settings of your web browser and opt out of certain third-party ad cookies on our websites.

6. SECURITY AND RETENTION

We have implemented safeguards that are intended to protect personal information we collect from unauthorized access, use, or disclosure. However, no method of electronic transmission or storage, is 100% secure. Therefore, we cannot guarantee its absolute security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity. In general, we will retain your personal information, including sensitive personal information, as long as reasonably necessary for purposes for which the personal information was collected and is used by us, as stated in this Privacy Notice

7. THIRD PARTY AND CO-BRANDED SITES AND OTHER SERVICES

Our Portal may contain links to third-party websites, mobile applications, or other services, operated by a third party and subject to a different privacy policy. You should review the privacy policy on any website, mobile application, or online service. Please be aware that FCA is not responsible for and cannot control the privacy practices of other websites or third parties. Our Portal may also contain links to co-branded websites that may display the FCA US logo and trademarks but are maintained by third parties, and do not display this Privacy Notice. Please read the privacy policies provided on these co-branded websites, which govern the privacy practices relating to personal information collected via that website.

8. RIGHTS AND CHOICES

Access and update information. Dealer personnel may access, correct, or remove certain information through the Portal by adjusting the SID User Management settings in the My Personnel application. For questions on how to change information in the My Personnel application, please contact your Dealership Administrator. Please note that we may maintain copies of information that you have updated, modified, or deleted, as permitted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. Please see theFCA US Privacy Policy for additional information about your privacy rights and choices.

Marketing Communications. You may opt out of receiving marketing communications from us by emailing us at dprivacy@stellantis.com . You may also opt out of email marketing by using the unsubscribe link in any such email we send to you. Please note that marketing opt-out requests will only remove you from our direct marketing lists. If you would like to opt out of marketing from a FCA dealer or other third party, you must contact them directly to opt out.

CCPA Rights. If you are a California resident, please review FCA’s California privacy supplement, which supplements this Privacy Notice and the FCA US Privacy Policy and provides additional information about your CCPA rights. You can obtain information about your right to opt out of sales and sharing (as defined by the CCPA) by FCA rights and submit a CCPA opt out or other privacy request to us using our privacy webform.

9. INTERNATIONAL TRANSFERS

FCA is a global company. As such, we may transfer your personal information to the United States and to other jurisdictions where we or our affiliates, suppliers, or service providers have operations. As such, your personal information may be accessed, stored, processed, or subject to law enforcement requests in these jurisdictions, which may not have equivalent privacy laws as in your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.

10. CHILDREN

The DealerCONNECT Portal or services therein are not targeted and directed at children or minors under the age of 16 and we do not knowingly collect any personal information from a child through the Portal. If you believe we have inadvertently collected personal information about a child, please contact us and we will take steps to delete this information.

11. CHANGES TO THIS NOTICE

We encourage you to periodically review this Privacy Notice, as we may change our Privacy Notice from time to time, in which case we will post the updated Privacy Notice (and effective data) on our Portal. If we make any changes to this Privacy Notice that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as posting notice through our Portal or notifying you within your Portal account or electronically.

12. CONTACT US

If you have any questions about this Privacy Notice, please contact us via email at dprivacy@stellantis.com