Uconnect and SiriusXM Guardian Privacy Policy Effective Date: October 2016

This Uconnect and SiriusXM Privacy Policy (the "Policy") describes how FCA US LLC and its affiliates (together, “FCA US”) and Sirius XM Radio Inc. and its subsidiaries (together, “Sirius XM”) may collect, access, use, and disclose your personal information, vehicle information, and information related to your use of the Uconnect and SiriusXM Guardian Services (the “Services”), whether in part or in whole.As used in this Policy, “we”, “our” or “us” refers to FCA US and Sirius XM collectively. The Services governed by this Policy include the Uconnect website operated by FCA US, the SiriusXM Guardian website operated by Sirius XM (individually a “Site” or together, the “Sites”), and any mobile application related to the Services (the “App(s)”). 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. This Policy applies only to information that we collect about you or your vehicle (including information from or about any of the occupants in your vehicle) through the Services or as described herein, and does not govern other information independently collected by FCA US or Sirius XM. 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). This Policy is in addition to privacy policies for FCA US and Sirius XM, which are found at www.fcagroup.com and www.siriusxm.com, respectively. In the event of any conflict between this Policy and FCA US or Sirius XM privacy policies, this Policy shall govern with respect to the Services. Use of the Services including the Sites and the App are also subject to the Uconnect and SiriusXM Guardian Terms of Service as well as the terms of use for each Site or App, respectively.


INFORMATION WE COLLECT FROM YOU OR YOUR VEHICLE. Information that may identify you or your vehicle may be collected, used, disclosed, and shared by us in accordance with this Policy and the laws, rules, and regulations of the United States (“Collected Data”). By enrolling in, activating or using the Services, you consent to the collection, use, and disclosure of Collected Data as described in this Policy. We collect personal 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, and credit card information. We may also collect information from you or your vehicle in the course of your use of the Services and of Satellite Services (as defined below), when applicable. Some of this information may be collected even after the ignition is turned off.


Collected Data transmission begins with the activation of the Services in a vehicle. In the event of a subsequent purchase, the Services may have been activated prior to the purchase. Cancellation of SiriusXM Guardian services alone does not stop the transmission of Collected Data to us. If you do not want Collected Data collected, retained, or used, you must follow the steps listed below in the Privacy Choices section to deactivate the Services in your vehicle in their entirety.


Collected Data may include the following:


HOW WE USE YOUR INFORMATION. In addition to any uses set forth above, we use Collected Data for a variety of purposes including without limitation: to provide the Services to you; for troubleshooting and maintenance of the Services; to communicate with you about your account; to prevent fraud and misuse of the Services; to allow us and FCA US’ dealers to evaluate and improve products or services and present you with promotional offers, new or additional products or services; to perform market research; 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 analyze vehicle information and vehicle use information for quality and product improvement purposes, and to enforce the Uconnect and SiriusXM Guardian Terms of Service. Location Data is also used 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; and to protect your safety or the safety of others in our sole discretion (e.g., to locate a missing person). We use Application Usage Data to provide the Services you request through the Sites or the Apps, and to administer, troubleshoot and improve the Sites and the Apps.


HOW INFORMATION IS SHARED We may disclose Collected Data to any of the third parties described below, for any of the uses described in How We Use Your Information. For example, we may share Collected Data with roadside assistance providers, third-party applications or service providers, law enforcement, regulatory agencies, or emergency service providers. Where applicable, your choice to use third party applications through the Services or otherwise may result in these third parties collecting your personal information. You may also choose to give personal information directly to third parties when using the Services. In each case, personal information you give a third party will be subject to that third party’s terms, conditions, and policies and is not governed by this Policy. You should review a third party’s privacy policy and terms of service before providing your information or prior to using the third-party service.


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 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 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.


PROTECTING CHILDREN. 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.


CONTACTING US If you have any questions about, or complaints that concern, this Policy, please write: to SiriusXM at: Privacy Officer, Sirius XM, 1500 Eckington Place, N.E. Washington, D.C., 20002 or email us at privacy@siriusxm.com; to FCA US at: FCA US LLC, Attn: Data Privacy Office, CIMS 485-02-12, 1000 Chrysler Drive, Auburn Hills, MI 48326 or email us at dprivacy@fcagroup.com. Do not include any sensitive or personal information in an email.


PRIVACY CHOICES. The collection, use and sharing of Collected Data is essential to providing the Services. If you do not want this information to be collected, used, or shared, you must contact us at 844-796-4827 and ask to cancel Uconnect and SiriusXM Guardian 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 other Uconnect services. It will also prevent updates to your In-vehicle Manual and the implementation of any Wi-Fi services through the vehicle. Please note that cancelling your SiriusXM Guardian subscription without the request to deactivate for privacy reasons will not cancel the transmission of Collected Data to us.


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 visiting www.moparownerconnect.com and following the link to the SiriusXM Guardian Services site. Even if you opt out of promotional communications, you may continue to receive service or account-related communications from time to time.


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 CALIFORNIA PRIVACY RIGHTS. Unless otherwise stated in this Policy, we do not share your personal information with unaffiliated third parties for their own independent marketing purposes without your consent. California residents may request the categories of personal information we shared with third parties for 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, 1290 Avenue of the Americas, 11th Floor, New York, NY 10104. To make your request to FCA US, please write to: FCA US LLC, Attn: Data Privacy Office, CIMS 485-02-12, 1000 Chrysler Drive, Auburn Hills, MI 48326. Requests that come to us by other means may result in a delayed response.