Privacy Policy for Volkswagen Car-Net Security & Service

Protecting your privacy is very important to us. This Privacy Policy is effective as of June 2013.

The purpose of this privacy policy (the “Policy”) is to describe what information Volkswagen of America,

Inc., a business unit of Volkswagen Group of America, Inc. (“VWoA”) and Verizon Telematics (“VZT”) may collect in connection with VW Car-Net Security & Service, including when you use VW Car-Net Security & Service, operate a vehicle equipped with VW Car-Net Security & Service, use the VW Car-Net Security & Service mobile application, or visit the VW Car-Net Security & Service Web site. It also describes how and with whom that information may be used or shared. This Policy is not intended to limit any data usage provisions contained in the VW Car-Net Security & Service Terms of Service (the “Terms of Service”) that you agreed to in order to receive the VW Car-Net Security & Service or any other agreements that you may enter into with VZT or VWoA. Please read this Policy and the Terms of Service carefully.

INFORMATION WE COLLECT AND HOW WE USE IT

We collect information about you and your Volkswagen vehicle (the “Vehicle") to facilitate the provision of VW Car-Net Security & Services. Providing these services involves a commercial relationship between you and us. Your use of VW Car-Net Security & Service may involve your interaction with our Service Providers, which include entities with whom you may interact directly such as roadside assistance, emergency service,and other similar providers. We and our Service Partners require certain information from you to provide those services. For example:

  • To provide VW Car-Net Security & Service, we must collect certain information when you activate your account and agree to the Terms of Service, including your contact information (e.g., your name, address, email and emergency contact), your billing and payment information and various other information. We may use this information to establish your credit or protect against fraud and misuse.

We may also monitor or record conversations you have with our customer service representatives, emergency personnel, or the police, as well as your use of any of our or their automated services, for purposes such as assessing, maintaining or improving service quality; issue resolution; training; or promoting and providing services. You understand and agree to such monitoring and recording and you are responsible for notifying any users of your vehicle that this may occur. When you contact VW Car-Net Security & Service for the provision of services, we may collect caller identification information and the date and time of call. Our and our Service Partners’ customer service representatives may remain on the line while conferencing in a third party to assist in completing a service request.

We may use information about you and your Vehicle to customize VW Car-Net Security & Service for your use, analyze and troubleshoot VW Car-Net Security & Service and usage, improve our product offerings, maintain internal records, and communicate with you about VW Car-Net Security & Service or other products or services. For information about your choices regarding communications, refer to Section 9 of this policy.

The information we may collect about your Vehicle or your mobile application includes by way of example:

  • information relating to the purchase or lease of your vehicle (e.g., make, model, year and vehicle identification number (VIN));
  • information concerning your Vehicle’s operation, performance and feature utilization (e.g., diagnostic trouble codes and maintenance conditions such as tire pressure and fuel economy) to enable VWoA to, among other things, provide you with VW Car-Net Security & Service, perform research, and improve our products and services;
  • information about accidents involving your Vehicle (e.g., whether air bags deployed) for the purposes of notifying emergency personnel or otherwise addressing potential emergencies;
  • information about your vehicle’s location, direction, or speed when you request a VW Car-Net Security & Service (e.g., to provide you with Destinations/Points of Interest; to provide automatic collision notification; to provide vehicle location services in the event your Vehicle is stolen), to comply with legal obligations, or to use or share in an anonymized or aggregate manner for purposes including research, analysis, product or service improvement, and aggregated information services such as traffic reporting; and
  • information concerning the type of mobile device you use, the device’s operating system, information you provide via the device, and, when you request a VW Car-Net Security & Service, the location of the device at the time of a service request, and other information as needed to provide a VW Car-Net Security & Service.

HOW WE OBTAIN INFORMATION ABOUT YOU AND YOUR VEHICLE

We obtain information about you and the Vehicle in a number of different ways. These include, but are

not limited to:

  • information you or your Vehicle dealer, distributor, or manufacturer provide to us when you buy or lease your Vehicle or register for Service;
  • information obtained from VW Car-Net Security & Service Equipment in the Vehicle and your use of the Service;
  • information you provide when you use the Web sites or other online services of VW Car-Net Security & Service or our Service Partners or from the mobile application;
  • information collected about your use of the Web sites or other online services of VW Car-Net Security & Service or our Service Partners;
  • information provided by you directly, through communications between you and us (or our Service Partners);
  • information obtained through publicly available or commercial sources; and
  • information exchanged between us, our affiliates and our Service Partners.

In addition, we and our Service Partners and the Volkswagen Companies may intercept any wire, wireless,oral or electronic communications made or transmitted through the Service, at any time and for any reason.

DISCLOSURE OF YOUR INFORMATION

To provide VW Car-Net Security & Service, we share your information with Service Partners including, for example, roadside assistance providers and emergency service providers (e.g., 9-1-1) for the purpose of delivering VW Car-Net Security & Service to you. We may also share information about you and your Vehicle with service providers, i.e., third parties that perform services on our behalf, such as call centers,mailing vendors and Web site hosting companies. We may share information about the Vehicle and you with each other and our affiliated companies to facilitate research, improve our product and service offerings, and for marketing.

We may share information about activation of the services with your Volkswagen dealer in order to allow the dealer to contact you. We also share pertinent information with law enforcement or others in case the stolen vehicle location assistance service has been requested. When required we may release information to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law, or to enforce or apply the terms of our agreements with you or to defend ourselves or Volkswagen in a litigation. For example, we may be legally compelled to provide location data and other information to law enforcement agencies, pursuant to validly issued subpoenas or similar judicial or law enforcement procedures. We may also share your information with third parties for purposes other than as described in this policy with your consent.

We may share information with dealers, our affiliates, our Service Partners and their affiliates to provide information about products and services that may be of interest to you.

We may share information with our business partners for joint marketing offers that may be of interest to you.

We also may disclose information about you and your Vehicle when we have reason to believe thatsomeone is causing injury to or interference with our rights or property, other users of the Web sitesor anyone else that could be harmed by such activities.

We may aggregate or anonymize information we collect about you and your Vehicle so that it no longer reasonably identifies you. We may share aggregate or anonymous information with certain third parties.Should we declare bankruptcy or should our assets ever be acquired by or merged into anotherorganization, the information we have collected about you and your Vehicle will be treated as an asset and may be transferred to a third party that purchases or otherwise acquires our assets.

UPDATING OR CHANGING YOUR ACCOUNT INFORMATION

It is your obligation to correct or update the information you provide upon activation of the VW Car-Net Security & Service when that information changes. You may review, update or change your information by calling one of our customer specialists at 1-877-820-2290 or writing to the Volkswagen Car-Net Security & Service Response Center c/o Verizon Telematics, Inc., P.O. Box 422628, Atlanta, GA 30342.

PROTECTION OF INFORMATION

We employ administrative, technical and physical controls to protect against the loss of, or unauthorized access to, the information under our control. Although we take your privacy very seriously and we useresponsible and reasonable practices to protect the privacy of your information, we cannot guarantee that your information will always remain secure.

SECURITY ON CELLULAR AND WIRELESS NETWORKS

The VW Car-Net Security & Service transmit voice and data between the response center and your Vehicle over wireless and cellular telephone networks. Although it may be illegal for unauthorized people to intercept these transmissions, we cannot guarantee the privacy and security of conversations or data transmitted to and from the Vehicle.

FINANCIAL INFORMATION

We may collect your financial information such as credit and debit card numbers and bank and other financial institution account numbers in connection with transactions you enter into with us. We use your financial information to help us process these transactions. We may use third-party service providers to help us perform some of these tasks. In such instances, we will provide your financial information to these third parties for the sole purpose of performing these tasks. We may also provide your financial information to your credit card issuer, financial institutions, credit card processors or other payment processors to process transactions.

USE OF VW CAR-NET SECURITY & SERVICE WEB SITE AND MOBILE APPLICATIONS

When you browse the VW Car-Net Security & Service or VZT Web sites or use the VW Car-Net Security & Service mobile application, we collect information about you, your use of the services, and your device. For example, you may submit on our Web site your name, contact information, VIN, and the like. In addition, we collect information about your interactions with the VW Car-Net Security & Service Web site and mobile app, the VZT Web site or Web sites of our Service Partners. We may collect and use your IP address and the Web site address of your point of entry to our sites, as well as other information about your connection, including your computer’s browser and platform type and your Internet connection speed, and your mobile device type and operating system version. We may collect and use information concerning the type of mobile device you use; the device’s operating system; information you provide via the device; the location of the device at the time of a service request; and other information as necessary to provide a VW Car-Net Security & Service. We use this information to monitor statistics such as how many people visit our Web sites and use our mobile apps, which pages people visit on our sites and how much time is spent on each page, which Web domains our visitors come from, which browsers are used to visit our sites, and how people use our mobile apps.

In addition, we may use “cookies” and other technologies on our Web site. Our use of cookies allows you to maintain your account login information between visits to our Web sites. It also better allows us tomeasure activity at the site and improve the user experience. We may use cookies or other technologies to tell us the time and length of your visit to the Web sites. We and our advertising partners may also use cookies or other similar technologies, including those of third-party online advertising networks, to collect information about your browsing activities to help tailor the ads you see on our and other sites.For example, if you visit a VW Web site, you may later see a related ad from us on a third-party Web site you visit. If you wish to disable or delete cookies from your computer, please see your browser’s help instructions and follow the procedures they provide. Additional information about removing cookies is found in the user documentation for your Adobe Flash player software. Please be aware that disabling cookies may prevent you from using specific features on our Web sites.

We may also use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies on our Web sites and/or in our communications with you to enable us to know whether you have visited a Web page or received a message.

YOUR CONSENT AND CHOICE REGARDING COMMUNICATIONS

By using VW Car-Net Security & Service, you agree to the practices and procedures described in this Policy. You also consent to our contacting you in your Vehicle or at your address, email address or phone number on file for the purpose of delivering VW Car-Net Security & Service to you and to discuss your account services, features and benefits. From time to time, we may also send you information about selected products, services or offers we think may be of interest to you. In addition to any unsubscribe options that may be contained in emails you receive from us that provide offers for VW Car-Net Security & Service or other products or services, if you do not want to receive emails or other communications about our offers, products or services, contact a Customer Service representative at 1-877-820-2290 or VW Car-Net Security & Service Privacy Policy c/o Verizon Telematics, Inc., P.O. Box 422628, Atlanta, GA 30342-2628.

Please note that even if you choose not to receive marketing emails from us, you may still hear from usregarding the status of VW Car-Net Security & Service and any other service issues and order status updates that will allow us to provide you with the optimal user experience.

We or our Service Partners or affiliates may also use your name, postal delivery information and phonenumber to contact you offline about products, services or offers that we think would be of interest to you.If you do not wish us to contact you offline, please contact us at or 1-877-820-2290 or VW Car-Net Security & Service Privacy Policy c/o Verizon Telematics, Inc., P.O. Box 422628, Atlanta, GA 30342-2628.

By giving us your e-mail address and/or obtaining products and/or services through our Web sites, youagree to receive e-mail marketing from us and our third-party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Telemarketing Sales Rule,16 C.F.R. § 310 et seq., as amended from time to time (the “TSR”). Notwithstanding that your telephone number may be listed on the Federal Trade Commission’s or a State’s Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the Telephone Consumer Protection Act (TCPA) 47 U.S.C. § 227; the TCPA rules issued by the Federal Communications Commission 47 C.F.R. § 64.1200; the TSR; and state laws, rules and regulations governing telemarketing. Moreover, by registering with, or requesting information from, a Service Partner or affiliate, such action constitutes a purchase, an inquiry and/or an application with the respective Service Partner or affiliate for purposes of the TSR and you may be contacted via e-mail, direct mail and/or telemarketing by such Service Partner or affiliate in accordance with the TSR, the TCPA and its implementing regulations and applicable state laws, rules and regulations.(You may always opt out of receiving promotional calls from us by contacting us at 1-877-820-2290 or VW Car-Net Security & Service Privacy Policy c/o Verizon Telematics, Inc., P.O. Box 422628, Atlanta, GA 30342.)

LINKS

The VW Car-Net Security & Service or VZT Web site may contain links to other sites, including, among others, those of advertisers, other third parties, and companies whose trademarks may appear on the site. We are not responsible for the information collection practices or the content of the sites to which we link or for content and information collection practices of the Web sites and online services belonging to our Service Partners.

Service Partners may include Google, Inc’s map services. Information collected through such services is subject to the Google Maps Privacy Policy, available at https://www.google.com/intl/en_us/policies/privacy.

CHANGES TO THIS POLICY

We reserve the right to change this Policy. Any changes will be effective immediately upon the posting of the revised Policy. We will notify you of any material changes to this Privacy Policy by posting a revised Policy on the VW Car-Net Security & Service Web site. You can access the current Policy at www.vw.com/carnet, by requesting a copy from us by writing to VW Car-Net Security & Service Privacy Policy c/o Verizon Telematics, Inc., P.O. Box 422628, Atlanta, GA 30342, or by calling us at 1-877-820-2290. Your continued use of VW Car-Net Security & Service after any such change is made constitutes acceptance of the terms of the modified Policy.

YOUR COMMENTS

We welcome feedback concerning this Policy. Please send your comments and questions to VW Car-Net Security & Service Privacy Policy c/o Verizon Telematics, Inc., P.O. Box 422628, Atlanta, GA 30342-2628, or call 1-877-820-2290.

What is a Service Partner?

Service Partners are third parties that work with us to provide services, equipment, content, features, or facilities connected with the provision of VW Car-Net Security & Service.Service Partners include, without limitation, telecommunications providers, call center operators, wireless service providers, public safety operators, emergency personnel, towing companies, vehicle distributors and dealers, equipment and software manufacturers, certain advertising companies and content providers,or other third vendors acting on our behalf to provide the VW Car-Net Security & Service.

For more information, call (877) 820-2290 or go to vw.com/carnet.

“Car-Net” is a registered trademark of Volkswagen Group of America, Inc. Apple, the Apple logo and iPhone are trademarks of Apple Inc., registered in the U.S. and other countries. App Store is a service mark of Apple Inc. “Android” and “Google” are trademarks or registered trademarks of Google Inc.
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