GENESIS MOTOR AMERICA VEHICLE TECHNOLOGIES AND SERVICES PRIVACY NOTICE
EFFECTIVE DATE: January 1, 2023

Your privacy is important to Genesis Motor America and our parent company and affiliates (“Genesis,” “we” or “us”), as is your trust in Genesis products and services. At Genesis, we are continually developing vehicle technologies and services to make Genesis vehicles safer and more environmentally friendly, convenient and fun to drive, and to provide other useful features and services as part of our vehicles. This Vehicle Technologies and Services Privacy Notice (the “Notice”) describes how we collect, use, disclose, and otherwise process the personal information related to the Genesis Connected Services and other vehicle technologies and services, which may include in-vehicle and onboard systems, sensors, software, features and equipment, as well as mobile applications and other features, technologies and services we make available for eligible Genesis connected vehicles (collectively, the “Vehicle Technologies and Services”).

Genesis vehicles equipped with Genesis Connected Services (each a “Vehicle”) include Vehicle Technologies and Services, through which information will be generated by and transmitted from your Vehicle and the Vehicle Technologies and Services to us and others. You can stop remote transmission and collection of information from and to your Vehicle by canceling Genesis Connected Services for your Vehicle, as set forth in the Your Rights and Choices section below. Please allow a reasonable amount of time for us to fully process your request.

ACKNOWLEDGEMENT AND AGREEMENT: As part of the Vehicle Technologies and Services: (i) personal information, including vehicle, performance and driving data, and precise geolocation, biometric data and other sensitive information may be generated, retrieved and collected from Vehicles and the Vehicle Technologies and Services and will be used, disclosed and otherwise processed as set forth in this Notice, including to operate, analyze and improve Vehicles and the Vehicle Technologies and Services and to reach users relevant information and personalized offers, alerts and updates; and (ii) over-the-air, automatic firmware and software updates may be made to Vehicles and the Vehicle Technologies and Services.

Please review this Notice carefully as it describes the collection, use, disclosure and processing of personal information related to the Vehicle Technology and Services, as well as your privacy choices regarding this personal information. California residents, please review our California Privacy Supplement for additional information about our information practices and your California privacy rights, including your right to opt out of sales and sharing of personal information pursuant to the California Consumer Privacy Act (“CCPA”).

SCOPE AND PURPOSE

This Notice applies to the personal information that Genesis collects, uses, discloses and otherwise processes related to the Vehicle Technologies and Services (“Covered Information”) and Vehicles, which includes:

• Information retrieved from a Vehicle or the Vehicle Technologies and Services by us or on our behalf, which is linked or reasonably linkable to that vehicle, the owner of that vehicle, or any registered user of the Vehicle Technologies and Services;
• Information provided during the subscription or registration process for Vehicle Technologies and Services; and
• Other identifiable information related to the performance, location, operation and use of a Vehicle and the Vehicle Technologies and Services.

This Notice supplements the Genesis Motor America Privacy Policy (“Genesis Privacy Policy”), with respect to our collection, use and disclosure of Covered Information. For additional information about our information practices and your choices and rights regarding your personal information (including Covered Information), please review the Genesis Privacy Policy. Please note that this Notice is not intended to address or apply to mobile applications or websites that we may make available to consumers that are not related to the Vehicle Technologies and Services.

Your access to or use of the Vehicle Technologies and Services and any dispute over privacy, is subject to the applicable terms and conditions, including the Connected Services Agreement Terms and Conditions⁠ which is incorporated by reference into this Notice and includes limitations on damages and the resolution of disputes.

Covered Information We Collect

As part of the Vehicle Technologies and Services, we collect Covered Information, which includes vehicle and driving data, precise geolocation data, biometrics, and other sensitive and personal information as described below. Some of this information is generated by Vehicles and the Vehicle Technologies and Services, and some is provided by owners and users of the Vehicle Technologies and Services and by third parties. For information about privacy choices regarding Covered Information, review Your Rights and Choices below.

Overview of Sources and Categories of Personal Information.

While the actual Covered Information that we collect may vary depending upon the circumstances (as further described below), generally, we collect the following categories of personal information (as defined by the CCPA) related to the Vehicle Technologies and Services:

• Identifiers: such as a name, username, address, VIN, IP address and online identifiers, email address, account name, SSN, driver’s license number and other government identifiers, and unique personal identifiers.
• Paper and electronic customer records: such as account registration and payment information.
• Commercial information: including records of products or services purchased or considered and or other subscription, purchase or usage data.
• Internet and other electronic network activity information: including related to your access to and use of the Vehicle Technologies and Services and your interactions with apps, online services and advertising or content provided through the Vehicle Technologies and Services.
• Location data: geolocation data for your Vehicle and mobile device.
• Audio, visual and other electronic data: including data related to your Vehicle and the Vehicle Technologies and Services, including error codes, diagnostic and performance data, and other sensor data generated by your Vehicle, images and event data generated in connection with certain features (such as autonomous driving features), and data from third party accounts services that you link you MyGenesis account (e.g., calendar integration).
• Biometric information: such as fingerprints or facial templates, if you enable and enroll in biometric authentication to access your Vehicle or certain Vehicle Technologies and Services.
• Profiles and inferences: including inferences and trends derived from Covered Information (e.g., for quality, safety, improvement, analytics and other purposes).

This Covered Information may also include certain sensitive personal information (as defined by the CCPA), including SSN, driver’s license number, precise geolocation data, and biometric information. We may share (as defined under the CCPA) identifiers, customer records, commercial information, internet or other electronic network usage data, and profiles and inferences, with dealers and other third parties as described in this Notice. We retain Covered Information for as long as reasonably necessary for purposes for which it was collected and is used by us, as stated in this Notice.

As further described below, we may collect Covered Information directly from users of Vehicles and the Vehicle Technologies and Services (e.g., as part of registration), as well as from service providers, third parties and others, such as Genesis dealers, Vehicle owners, platform providers, and others with whom we work with to make available certain of the Vehicle Technologies and Services, to conduct analytics, or to reach users with more relevant information and advertising. We also collect and derive Covered Information that is generated by Vehicles and the Vehicle Technologies and Services and related to your use of and interactions with these services.

Covered Information Collected Directly. We may collect Covered Information directly from you, such as:

• Account, registration, and subscriptions: When you register for Connected Services or otherwise activate, subscribe to or register for certain Vehicle Technologies and Services, including Digital Key, we collect information that you provide us such as your name, email address, phone number, home or work address, and other contact information; VIN and associated Vehicle data; date of purchase; billing information and subscription details and history, including for relevant third-party subscriptions. We may also collect certain optional information you choose to provide to us, such as your user preferences, information about other approved drivers of your Vehicle, and demographic information. We may also maintain records related to any devices or third-party accounts or services that you choose to connect or link with related to the Vehicle Technologies or Services, in order to enable certain features.
• Customer service, support and other Data: when you email us, call us, complete surveys we send or sponsor, or otherwise contact us, we maintain records about our interactions and communications with you, including the nature of the request, your name and contact information, and information related to our resolution of your request, and any other information that you provide to us.

Information Collected and Derived from Vehicle Technologies and Services. We may collect or derive Covered Information from Vehicles and the Vehicle Technologies and Services, including:

• Usage and performance: information related to the use of your Vehicle and the Vehicle Technologies and Services, as well as Vehicle performance, diagnostic codes and service-related data. This includes information such as odometer, mileage, MPG and emissions data; tire pressure data; trouble or error codes, and other diagnostic data; service and maintenance history; engine performance; tire pressure data; weather, temperature and other driving conditions; fuel levels and refueling activity; battery levels and status; images from exterior cameras (if available); Vehicle settings, commands and presets, points of interest, and other information about your use of certain features, including which features you activate, access or use; and other performance, mechanical and operational data; as well as associated date/time stamps for such information.
• Geolocation data: location information, including your Vehicle’s GPS location, and, when you engage remote services using your mobile device, your mobile device location information.
• Driving data: including driving data about the operation of a Vehicle, such as speed, acceleration and braking data; direction of travel; trip data (mileage, date, length, conditions); ignition events; steering events; cruise control data; seatbelt status; information about Vehicle incidents or events; other information about how you drive a Vehicle; as well as associated date/time stamps for such information.
• Biometric data: If you enroll in certain services, we may collect and process biometrics (e.g., fingerprint or facial recognition) as part of certain features and services, such as digital key and other vehicle services that enable your access using your biometric access credentials, subject to applicable laws. When you enroll your fingerprint, face, or other biometric, you must consent to the collection, use, and storage of your data for the disclosed activities. We will only use or share your biometric data as needed for system use, maintenance, and storage. Your fingerprint will be stored by the system until you delete it. Stored data cannot be converted into a reconstruction of your biometric information
• Browsing and activity data: When you access the Vehicle Technologies and Services via mobile apps, websites, and or other online services that we make available to you, we and our third-party providers may use cookies, web beacons, log files, and other methods to collect information about your browser, device activities, such as IP addresses, device ID and other online identifiers, browser information, activity and usage data (including links clicked, pages viewed and other activity information) and location information.

See the Your Rights and Choices section below, for information about how to stop remote transmission and collection or exercise certain privacy choices regarding your Covered Information.

Information Collected from Third Party Services and Other Sources. We may obtain Covered Information about you from dealers and other non-affiliated entities and service providers, such as those that provide certain features, functionality or other services as part of the Vehicle Technologies and Services, including information related to the performance and use of such third-party services, such as:

• Affiliates and partners, including providers of certain Vehicle and Technology Services, such as satellite radio and roadside assistance providers, and platform providers and app stores through which we make our Apps and certain features (such as Digital Key) available.
• Genesis dealers (which are all independently owned and operated) who may provide us with data and records related to vehicle sales, service, repair, scheduling, warranty claims, and quality and customer support.
• If you log in through or integrate a third-party account (such as Google, Amazon, Apple) with our Services, we access and obtain certain information from that third-party platform (subject the applicable terms of the third-party platform). For information about sharing by a third-party platform and revoking access to your account or content, you should consult the respective privacy notices and terms and review your privacy settings for such third-party account.

Use of Covered Information

Generally, we use Covered Information for the following purposes:

• Providing our Services and related support: to provide, maintain and improve the Vehicle Technologies and Services and our other products and services; to make available certain features and services, such as roadside assistance, remote start, calendar integration, in-vehicle camera record, and Vehicle alerts; to authenticate users; to process your payments; to perform technical operations, such as updating software; respond to a possible emergency or other situation requiring urgent attention; to send you messages relating to the Vehicle Technologies and Services; and for other customer service and support purposes.
• Communicating with you: to communicate with you about your Vehicle and the Vehicle Technologies and Services, including to send you notices and alerts and to respond to your requests.
• Analyzing and improving our vehicles, services and offerings: to better understand how users access and use our Vehicle Technologies and Services; to evaluate and improve our Vehicle Technologies and Services; to develop new features, products, or services; for troubleshooting and maintenance; for warranty, safety, quality and product improvement purposes; and for other research and analytical 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.
• Marketing and promotional purposes: to communicate with you about your account and use of our Vehicle Technologies and Services via email and push notification, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you, including information about third party products and services; and for other informational, marketing, or promotional purposes. Please see the Your Rights and Choices section for more information about how to change your communications preferences. We may also send you notifications by text message if you have opted in to receive them.
• Personalizing content and experiences: to personalize the information and content we display to you, including marketing, promotional and sponsored content, as well as providing you with more relevant ads (if applicable).
• Security and protection of rights: to protect the safety, rights, property, or security of Genesis, the Vehicle Technologies and Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we, in our sole discretion, consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Notice or our Terms of Use.
• Complying with legal requests and obligations: to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
• In support of our general business operations: where necessary for the administration of our general business, accounting, recordkeeping and legal functions, in connection with planning or implementing transfers, restructuring or reorganization of our business or assets and similar business transactions, or as part of our routine business administration, such as employee training, compliance auditing and similar internal activities.

Disclosure of Covered Information

We may disclose Covered Information as set out below and where otherwise authorized or requested by you.

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

• Affiliates and subsidiaries: We may disclose Covered Information to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Notice.
• Vendors and service providers: We may disclose Covered Information to third-party vendors, service providers, suppliers, contractors or agents who use such data in order to perform functions on our behalf, including digital advertising and analytics providers.
• Third party services and providers: Some of the Vehicle Technologies and Services are provided or supported by third parties 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 Vehicle Technologies and Services. Third party services include, for example, cellular data carriers, navigation and traffic services, and emergency services. The use of your personal information by these third parties will be subject to their respective privacy policies and terms, and not this Notice.

Dealers and Other Third Parties. We may share Covered Information, including vehicle, performance and driving data, as well as geolocation data, with authorized dealers and select third parties.

• Dealers: we may share certain Covered Information with dealers so that they and we may better respond to your requests, send your relevant and personalized offers and information, and respond to your requests.
• Marketing and advertising partners: we may make certain Covered Information available to third parties (such as analytics providers and ad companies) in support of our marketing, analytics, advertising and campaign management. We may also make available certain third party offers that we think may interest you. If you click an offer or otherwise choose to take advantage of a third-party offer, we may share Covered Information, including personal information, with that third party to facilitate your interaction with them.
• Promotional Program: we may invite you to participate in sweepstakes, contests, special events, incentives, and other promotional events, activities and programs, which are oftentimes co-sponsored or marketed with an unaffiliated business partner. If you interact directly with, or indicate your interest in receiving information or communications directly from, a third party as part of a Program, your personal information may be shared with that third party, who will use it in accordance with their respective privacy policy. As set forth in the “Your Rights and Choices” section below, you have certain choices regarding the collection, sharing and disclosure of your Covered Information.

Other Drivers. If you are a Vehicle owner and you permit another person to register a Vehicle Technologies and Services account for your Vehicle or if you permit another person to access and use your Vehicle Technologies and Services account or registered Vehicle, then you acknowledge and agree that such individuals may have access to certain Covered Information and that we may collect, use and disclose Covered Information associated with such individuals’ use of your Vehicle and the Connected Services. You should inform any such individuals of this Notice and the applicable settings and privacy choices you have made for the Vehicle and the Vehicle Technologies and Services.

Other Business and Operational Purposes. In addition, we may disclose Covered Information in support of our business and operational purposes, including:

• Business transfers: Covered Information may be disclosed and transferred by us to another company 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: we may disclose your information to protect or defend the safety, rights, property, or security of Genesis, third parties or the general public, including to protect the Vehicle Technologies and 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 Covered Information as evidence in litigation in which we are involved, and as necessary to enforce this Notice or our Connected Services Terms and Conditions and other applicable agreements with you.
• Legal compliance and lawful requests: Covered Information may be disclosed in order 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 or request, whether formal or informal, from law enforcement or a government official.

Aggregate and De-Identified Information

We also may collect, use and disclose aggregate, anonymous, and other non-identifiable information about users for marketing, advertising, research, compliance, or other purposes. For example, we may disclose aggregate and non-identifiable trip data to select third parties who may use this data to better understand aggregate driving and traffic patterns, update maps and route details, analyze road conditions, and for other own research, development and analytics 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).

Safeguards

We have implemented safeguards which are intended to protect the Covered Information we collect. However, the security of information transmitted through the Internet cannot be guaranteed regardless of level of security. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. Users of our Vehicle Technologies and Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to the Vehicle Technologies and Services and their account. In order to protect you and your data, we may suspend your use of any of the Vehicle Technologies and Services, without notice, pending an investigation, if any security issue arises. Access to and use of password protected and/or secure areas of any of the Vehicle Technologies and Services or your associated account are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution or civil action.

Information About Children

The Vehicle Technologies and Services are not directed at children and we do not knowingly collect any personal information from children under the age of 16.

Your Rights and Choices

You have certain rights and choices regarding your Covered Information and the Vehicle Technologies and Services, as described in this section. For additional information about the rights and choices you have regarding Genesis’s information practices, including your rights to opt out of marketing and targeting, generally, please review our Privacy Policy.

Reviewing, Updating and Deleting Your Information. If you register for a MyGenesis account to access and use the Vehicle Technologies and Services, you can access and update certain information we have relating to your account within your account settings. For Connected Services, this can be done on the My Account page of MyGenesis.com.⁠ You may also update or delete your contact information by submitting a request at our Contact Us page. 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.

Genesis Connected Services Cancelation. For Vehicles equipped with Genesis Connected Services, certain Vehicle Technologies and Services may be enabled prior to purchase, and information including personal information will be transmitted from your Vehicle and the Vehicle Technologies and Services to us and others as set forth in this Notice. To stop remote transmission and collection from your Vehicle you must cancel Connected Services for your Vehicle, which you may do by (i) expressly waiving Connected Services at the point of purchase of a new Vehicle, or (ii) cancelling your Vehicle’s Connected Services subscription. You may cancel your Vehicle’s subscription for Connected Services by calling Genesis Connected Services Customer Care at 844-340-9741. If you cancel Genesis Connected Services, most Vehicle Technologies and Services will not be available to you and remote transmission of Covered Information from your Vehicle will be stopped once your request has been processed, which may take up to several business days. Further, canceling your subscription does not stop your Vehicle and in-vehicle systems from generating or storing information all together. The in-vehicle safety, diagnostic and other tools and systems may continue to generate and store information, which may be accessed by independent dealers and others who service your Vehicle, and shared with Genesis, for performance, safety or diagnostic data to provide appropriate repair, maintenance and other safety-related services.

Canceling Third Party Subscriptions. Your Vehicle may include free trial for and access to certain third-party subscription-based services, including SiriusXM Radio and Wi-Fi hotspot. If you subscribe to these third-party services at the end of your free trial, you must contact these third parties directly if you would like to subsequently cancel your subscription.

Submitting Privacy Requests. Residents of certain states may have specific privacy rights under applicable privacy laws, as described in our Privacy Policy. You may submit a privacy request, including to access, correct, or delete personal information, to opt out of targeting and sales, and to limit or object to certain uses and disclosures of your personal information, including Covered Information by:

• Submitting an online request through our Personal Information Request Portal
• Contacting us at (844) 340-9741 (toll free)

Your California Privacy Choices. If you are a California resident, please review our California Privacy Supplement for additional information about your California privacy rights, including your rights to opt out of sales and sharing of your personal information and to limit certain uses and disclosures of your sensitive personal information.

Sale or Transfer of Vehicle. If you sell or otherwise transfer your Vehicle, it is your responsibility to: (i) contact us to cancel or transfer your Genesis Connected Services subscription; and (ii) delete all stored information (such as contacts and saved locations) from your Vehicle. If you do not delete this information, it may remain in the Vehicle and may be accessible to future users of the Vehicle. For instructions on how to delete information from your Vehicle, please refer to your Vehicle owner’s manual.

Updating this Notice

Genesis reserves the right to change this Notice at any time. Genesis will use, share, and disclose Covered Information in accordance with this Notice in effect at the time the information is collected. We will post any changes to this Notice on this page so check back frequently so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it.

How to Contact Us

Please visit our Contact Us page.