Updated July 24, 2023
What Information is Covered and Not Covered by This Policy
Not Covered: This Policy does not govern information collected, accessed, used or stored by FCA US LLC (“FCA”) either as collected through Uconnect or Alfa Connect devices or services or as shared with FCA or Alfa Romeo by Sirius XM. The FCA Uconnect and Alfa Connect Privacy Policies are in addition to this Policy and may be found at www.driveuconnect.com/connectedservices/privacy and www.alfaromeoconnect.com/en-us/FCA-connected-services/privacy.html. Please read these policies for additional information on collection and use of data through SiriusXM Guardian.
Emergency services may be temporarily active at the time of the purchase or lease of the certain equipped vehicle prior to the activation of all available Services by enrollment of SiriusXM Guardian. These temporary emergency services will automatically deactivate approximately 30 days after the purchase or lease of that Vehicle. Data from the temporary emergency services consists of Vehicle Data and Location Data (each as defined elsewhere in this Policy) as well as data you provide to us, which will only be transmitted upon the occurrence of an emergency event such as an impact or the pressing of the in-vehicle SOS button. With the exception of the temporary emergency services, upon activation of the Services by enrollment in SiriusXM Guardian, vehicle data including location data is transmitted from your Vehicle at regular intervals and passes through Sirius XM CV systems to FCA (“Transmitted Vehicle Data”). Sirius XM CV does not access, use or store Transmitted Vehicle Data, and this Policy does not apply to Transmitted Vehicle Data. Cancellation of SiriusXM Guardian Services alone does not stop the transmission of Transmitted Vehicle Data from your vehicle. If you want to stop the collection of Transmitted Vehicle Data, you must follow the steps listed below in the Privacy Choices section.
The telematics device embedded in your Vehicle or other devices or applications connected to your Vehicle by you may allow information to be transmitted to or collected by connected services providers other than Sirius XM CV. Sirius XM CV has no control over such other connected services, and this Policy does not cover information you provide to or that is collected, used or disclosed by connected service providers other than Sirius XM CV. Excluding pre-enrollment emergency services data transmitted as described above, Sirius XM CV does not share your personal information with other such connected vehicle service providers without your consent. Please see your Vehicle’s owner manual or the privacy policies of the respective service provider or application for more information about their data collection and use practices.
This Policy does not restrict our use or sharing of information which is anonymized or in an aggregated form, (i.e. information that cannot be used to directly identify you or your Vehicle).
Information We Receive or Collect From You or Your Vehicle.
We collect information about you or your Vehicle (“Collected Data”) in accordance with this Policy, such as information you provide to us, information generated by devices in your Vehicle in conjunction with the Services, service and marketing interactions with us as well as information from your use of the Services and of Satellite Services (as defined below), when applicable. Collected Data transmission begins with the activation of the Services in a Vehicle. In the event of a purchase of a pre-owned Vehicle, the Services may have been activated prior to the purchase.
Collected Data may include the following:
- Account Information. We collect
- Contact information you provide when you register for the Services or call one of our customer care centers for assistance, such as your name, mailing address, email address, telephone number.
- Purchase and payment information, such as your choice of service package and duration, price and credit card or other payment account number and expiration date. We do not provide your financial information to any third party, except as necessary to process and service a payment transaction for the Services.
- Recordings of your calls with our customer care specialists to provide service or account management.
- Service Usage Data. We collect information about your Vehicle, your Vehicle’s location and the nature of the request when your Vehicle initiates a service command or when you use the Services through the in-vehicle button or the FCA mobile app or other means. We use this information to perform the Services you request, to monitor and troubleshoot the performance of the Services and our systems, to customize our communications with you, and to research, analyze, enhance and improve product and service offerings. We also collect information you submit when you use the Services from your Vehicle, your phone, or through the Sites, such as points of interest, drive alert settings, or other information required to perform Services you request.
- Vehicle Data. We collect information related to your Vehicle (“Vehicle Data”) to set up and service your account, such as VIN, make, model, and year of your Vehicle; the telematics device type and associated capabilities for your Vehicle. Additional Vehicle Data collected by us includes collision information and speed. After your Vehicle’s ignition is turned off, the Vehicle transmits the location of the Vehicle and the time it was turned off.
- Location Data. Our collection and use of your Vehicle’s GPS location (“Location Data”) is required in order for us to perform the Services. We record, monitor or collect the location of your Vehicle regardless of who is driving it a) in order to perform the Services as requested by you, other occupants, or another driver of the Vehicle; b) when Service Usage Data is collected as described above, c) when certain Vehicle Data is transmitted upon ignition off; d) when we are required to do so by applicable local, state or federal laws, rules or regulations; or e) in connection with our efforts to communicate with the Vehicle purchaser or recover the Vehicle pursuant to agreements governing the lease or financing of such Vehicle. We do not have the ability to locate a Vehicle on demand unless the Stolen Vehicle Locator function has been activated by an active subscriber to the Services, or we are directed to do so pursuant to a valid court order, or as otherwise expressly stated herein and in the Uconnect and SiriusXM Guardian Terms of Service or Alfa Connect and SiriusXM Guardian Terms of Service, respectively.
- Customer Experience Data. We may collect survey information about the way you use the Services that helps in troubleshooting, improving, customizing or communicating about and understanding how and when you utilize the Services which are offered to you.
- Satellite Services Data. Satellite radio and other satellite delivered services such as Traffic and Travelink (collectively “Satellite Services”) provided by Sirius XM Radio in connection with your Vehicle’s satellite radio device are separate and distinct from the Services. We may collect information that is related to the satellite radio in your Vehicle and the ways you use your satellite radio and the Satellite Services. This information is used by us to help identify signal outages, to improve Sirius XM Radio’s Satellite Services product and content offerings, and to customize or communicate with you to enhance your Sirius XM audio listener experience.
- Sensitive Personal Information. Sirius XM CV collects information that may reveal the precise geolocation of a vehicle in order to perform the Services. Sirius XM CV uses this data only to deliver the Services and other uses authorized under state laws including CCPA, such as for security purposes, and does not infer characteristics about the vehicle or any consumer associated with the account.
How We Use Your Information.
In addition to the uses set forth above, we retain and use Collected Data for a variety of purposes including without limitation, to provide the Services to you; to communicate with you about your account; for troubleshooting and maintenance of the Services and our networks and systems; to prevent fraud and misuse of the Services; to allow us, FCA US’s and Alfa Romeo’s dealers and third parties to evaluate and improve products or services and present you with promotional offers, new or additional products or services or for marketing purposes; to protect your safety and the safety of others; to comply with laws, regulations, court orders, and subpoenas or similar requests for information by authorities; to conduct market research; to analyze Vehicle information and Vehicle use information for quality and product improvement purposes, and to enforce the Uconnect and SiriusXM Guardian Terms of Service or Alfa Connect and SiriusXM Guardian Terms of Service, as applicable.
We use Location Data to perform the Services, for quality or research and development purposes; to notify emergency service providers; to send you Services–related messages; to assist law enforcement as part of a request for stolen vehicle assistance or other assistance in response to a valid court order or subpoena; and to protect your safety or the safety of others in our sole discretion (e.g., to locate a missing person).
We use Site Usage Data to provide the Services you request through the Sites, and to administer, troubleshoot and improve the Sites.
How We Share Your Information.
Business Transfers. Collected Data may be disclosed and transferred by us as part of any merger, acquisition, financing, sale of company assets or interests in the respective company, or the transition of service to another provider. In the unlikely event of insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset.
Safeguards And Retention Of Information.
We may retain your information in order to fulfill our respective business purposes and use a variety of procedural, physical, and technological safeguards in our efforts to protect your information from unauthorized access, use, or disclosure. We require you to have a Uconnect Services or Alfa Connect Services, as applicable, user ID and password, and it is important that you maintain the confidentiality of this information at all times and update the password regularly. We also require that you establish a SiriusXM Guardian personal identification number (PIN) which is required to use certain SiriusXM Guardian features such as remote door lock and unlock. It is important that you do not provide your PIN to anyone who is not authorized to use or incur charges on your SiriusXM Guardian account. We are NOT responsible for unauthorized use of the Services or FOR charges to your account when the appropriate authentication has been provided. No method of electronic transmission, or method of electronic storage, is 100% secure, and it may be possible for third parties not under our control to intercept or access information unlawfully. Therefore, we cannot guarantee its absolute security.
SMS Terms for Access to In-Vehicle and Dealership Enrollment.
Utilization of the head unit of your Vehicle to access enrollment in the Services is subject to the terms contained in this section (the “SMS Terms”). Enrollment is necessary in order to activate the Services. In order to request access to enrollment using the head unit on your Vehicle, you will be required to enter your mobile telephone number where indicated on the head unit’s screen. At the time you purchase your Vehicle, you may also elect to access enrollment in the Services at the Dealership. Accessing enrollment at the Dealership is also subject to the SMS Terms. After requesting access to enrollment by entering your mobile telephone number into your Vehicle’s head unit or at the Dealership, you will receive a single text message containing a link with further instructions to complete the enrollment process. (the “Enrollment Message”). Message and data rates may apply. Your mobile telephone carriers are not liable for delayed or undeliverable messages.
You will only receive one text message per request for enrollment. Should you require additional information for assistance, you may respond to that text with “HELP” and will then receive an additional text with further information on how to receive assistance. Should you wish to rescind your request for access to enrollment, you may respond to the text with “STOP” and no more messages will be sent to your mobile telephone number even if you subsequently request access to enroll in the Services through the head unit of your Vehicle or at the Dealership.
In addition to the SMS Terms, the Terms of Service, and this Policy apply. You can obtain a copy of the Terms of Service in effect at: www.driveuconnect.com/sirius-xm-guardian/terms.html. In the event of any potential conflict between any offer for Services and the SMS Terms, Terms of Service, and Policy (the “SiriusXM Guardian Terms”), the SiriusXM Guardian Terms will govern.
The Services are not directed at children and we do not knowingly collect any personal information from children under the age of 13. If you are under 18, or otherwise would be required to have a parent or guardian consent to share information with us, you should not send any information about yourself to us. If a person under 13 submits information through any part of the Services and we learn the person submitting the information is a child, we will attempt to delete this information as soon as possible.
Your choices to limit collection and use of Collected Data
The collection, use and sharing of Collected Data is essential to providing the Services. You may not disable the transmission of Location Data, Service Usage Data or Vehicle Data within the use of the Services. To disable Location Data, Service Usage Data or Vehicle Data, you must cancel your SiriusXM Guardian subscription by calling 844-796-4827 or any other method mandated by law.
If you do not want Transmitted Vehicle Data to be collected or used, you must contact us directly at 844-796-4827 and ask to cancel your Services for privacy reasons. This request will result in the deactivation of your wireless transmission network service and will cease your access to SiriusXM Guardian safety and convenience services and certain other Uconnect or Alfa Connect services. It will also prevent updates to your In-vehicle Manual and the implementation of any Wi-Fi services through the Vehicle, if available. Please note that cancelling your SiriusXM Guardian subscription without the request to deactivate for privacy reasons will not cancel the transmission of Transmitted Vehicle Data to FCA or Alfa Romeo.
If you wish to opt out of receiving promotional communications related to the Services by email or telephone, you may do so at any time by calling customer care at 844-796-4827. You may also follow the links to unsubscribe from promotional email communications in the footer of our marketing communications with you. Even if you opt out of promotional communications, you may continue to receive service or account-related communications from time to time.
Your Privacy Rights Under State Laws
Residents of certain U.S. states may have the ability to exercise additional rights and choices regarding their personal data. Please see below for additional provisions required under the consumer privacy law of the respective states. We will take reasonable steps to accommodate your request but may need to verify your identity before doing so.
California Residents: We do not share your personal information (as defined) with unaffiliated third parties for their own independent marketing purposes without your consent. You may request the categories of personal information we shared with third parties for their own marketing purposes and the names of those third parties during the previous calendar year. To make your request to Sirius XM, please write to: Sirius XM, Attn: Legal Department - CA Privacy Rights, 1221 Avenue of the Americas, 35th Floor, New York, NY 10020. Requests that come to us by other means may result in a delayed response.
Your rights under the California Consumer Privacy Act of 2018 (CCPA): Under CCPA, a business is required to provide certain information about your rights and the personal information we collect, sell and disclose for a business purpose. To view this information, please visit Your California Consumer Privacy Act Rights.
Colorado, Connecticut, Utah, and Virginia Residents: As required by the laws of the enumerated states, this Policy describes the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. Residents of Virginia, Colorado, Connecticut, and Utah have the following rights, all subject to the meanings and exceptions set forth in the respective law applicable to their state of residency:
- Right to Access. (CO, CT, UT, VA Residents) You have the right to confirm whether we are processing your personal data and to request a copy of the personal data previously provided by you to us, up to twice annually, and in a readily usable format to allow data portability to the extent feasible.
- Right to Delete. (CO, CT, UT, VA Residents) You have the right to request that we delete your personal data, subject to certain exemptions and exceptions.
- Rights Around the Processing of Sensitive Personal Information.
- (CO, CT, VA Residents) You have the right to consent prior to the processing of sensitive personal information as defined by applicable law of your state of residency. To the extent Sirius XM processes sensitive data, we will obtain your opt-in consent in accordance with law.
- (UT Residents) Commencing December 31, 2023, Utah residents have the right to opt out of the processing of sensitive personal information as defined by Utah law.
- Right to Opt-Out of Sale of Personal Data and/or Targeted Advertising. (CO, CT, VA and UT residents) If a business sells personal data as defined by the respective state law, you have the right to opt-out of such sale.
- Sirius XM does not sell personal data to third parties for monetary compensation.
- Sirius XM does not process or share personal data for use in targeted advertising.
- Right to Opt-Out of Profiling. (CO, CT, VA Residents) Sirius XM does not process personal data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects.
Exercising your Rights:
If you are a resident of one of the states listed in this subsection and would like to exercise any of these rights described above pursuant to the applicable law and any implementing regulations adopted thereunder, please submit a request here. Colorado, Connecticut and Virginia residents also have the right to request correction of inaccurate personal data we hold about you (“Right to Correct”). This right may be exercised directly through your account online.
If you are a resident of Colorado, Connecticut or Virginia and you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by submitting your request here. Please provide all of the requested information so that we may properly address your appeal.
Authorized Agents Submitting Opt-Out Requests for Sales (CO and CT Residents). Residents of Colorado and Connecticut may submit a privacy rights request to opt out of sales or from the use of their personal data in targeted advertising through an agent operating on behalf of the resident. SXMCV does not use or disclose personal data for targeted advertising. If you are an agent authorized by a Colorado or Connecticut resident to submit a request on the resident’s behalf to opt out of the sale of personal data, as defined by the respective law, please submit the request pursuant to the instructions on the respective form. We may authenticate the consumer’s identity and require documentation to confirm your authorization from the consumer to act on the consumer’s behalf, in order to be able to fulfill the request. If we are unable to verify either the consumer’s identity or your authority, we may deny the request.
Nevada Residents: If you are a resident of Nevada, you have the right to request limits to the sale of certain personal information to third parties for resale or licensing purposes, subject to applicable law. SXMCV does not sell such personal information for any use. You are entitled to register your preference for limits on such sales in the future by sending an email to [email protected], with the subject line, “Nevada Do Not Sell Request” along with your first and last name, zip code, and whether you are a former or current Connected Services subscriber. If you are a former or current Connected Services subscriber, in order to process your request, your email address must match the email address on your account.
The Services are operated and performed from the United States and are not intended to be subject to the laws or jurisdiction of any state, country, or territory other than that of the United States. The Services for U.S. subscribers may function with limited availability and functionality on U.S. registered vehicles while in Canada. We do not promote the Services in Europe and do not provide service to vehicles in Europe. We do not intend to collect, and we do not knowingly store personal information from consumers or users who are residents of countries outside of the United States or Canada.
Updating This Policy.
We may change this Policy at any time. If we make material changes to this Policy or how we handle your personal information, we will provide notice by changing the Effective Date of the Policy or as required by law. By using the Services after the Effective Date, you are deemed to consent to the then-current Policy. We recommend that you check back and review this Policy from time to time.
Your privacy concerns are important to us. If you have privacy-related questions or concerns about this Policy or the SiriusXM Guardian Services, please write to:
Sirius XM Connected Vehicle Services Inc.
8550 Freeport Parkway
Irving, TX 75063
Or email us at [email protected].
Do not include any sensitive or personal information in an email.