This SiriusXM Guardian Privacy Policy (the “Policy”) applies to your trial, paid or other subscription to the SiriusXM Guardian suite of connected vehicle services (the “Services”), provided to you by Sirius XM Connected Vehicle Services Inc. (“Sirius XM CV”). This purpose of this Policy is to inform you how Sirius XM CV may collect, access, use, and disclose your personal information, vehicle information, and information related to your use of the Services. The Services governed by this Policy include the SiriusXM Guardian connected vehicle services, whether accessed through a vehicle equipped with a Uconnect or Alfa Connect device (each, a “Vehicle”) or otherwise, and any SiriusXM Guardian website operated by Sirius XM CV (the “Sites”). As used in this Policy, “we”, “our” or “us” refers to Sirius XM CV. 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. By submitting your information to us, or by enrolling in, activating, or using the Services, you agree to the terms of this Policy and you expressly consent to the collection, use, and disclosure of your information in accordance with this Policy. Use of the Services including the Sites are also subject to the Uconnect and SiriusXM Guardian Terms of Service as well as any terms of use for the Sites.

What Information is Covered and Not Covered by This Policy

Covered: This Policy applies to information that we collect, access, or use about you or your Vehicle (including information from or about any of the occupants in your Vehicle) through the Services or as described herein. This Policy also covers information that we collect on behalf of or share with our parent corporation, Sirius XM Radio Inc. (“Sirius XM Radio”), as described below. However, Sirius XM Radio’s use of the information is governed by the Sirius XM Radio privacy policy, found at www.siriusxm.com.

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/connectedservices/privacy.html.Please read these policies for additional information on collection and use of data through SiriusXM Guardian.

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. 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 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.
  • Sites Usage Data. We may use systems or tools to follow your use of the Sites, including using cookies, web beacons, log files, or other technologies. When you use the Sites, we or a third party acting on our behalf may collect and use or record site click-stream and cookie data regarding use and performance of the Sites during your visit (“Site Usage Data”). Site Usage Data may include without limitation the pages you view, the search terms you enter, your IP address, your operating systems and browser client, and your geographic region. We sometimes use cookies and similar technologies to enable features on our Sites, to develop products and services, and to personalize your experience. The Sites do not respond to “do not track” beacons or other such signals. You may have received a tracking mechanism prior to your visit to the Sites from other parties that will continue to track your activity while on the Sites. These third party cookies and technologies are governed by the privacy policies of the entities placing those mechanisms and are not subject to this Policy. For more information on how to opt-out of advertiser tracking mechanisms, please visit www.networkadvertising.org/managing/opt_out.asp.

How We Use Your Information.

In addition to the uses set forth above, we retain and useCollected 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.

We share Collected Data with FCA for its use in providing Uconnect or Alfa Connect services and for other purposes set forth in the Uconnect and SiriusXM Guardian Terms of Service, the Alfa Connect and SiriusXM Guardian Terms of Service, and the FCA Connected Vehicle Privacy Policies located at www.driveuconnect.com/connectedservices/privacy and www.alfaromeoconnect.com/connectedservices/privacy, respectively.We may disclose Collected Data to third parties 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 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.

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.

Privacy Choices.

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

Please see below for additional provisions required under the consumer privacy law of the respective states.

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. Sirius XM CV does not sell your 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 privacy@siriusxm.com, 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 SiriusXM Guardian subscriber. If you are a former or current SiriusXM Guardian subscriber, in order to process your request, your email address must match the email address on your account. 

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, 1290 Avenue of the Americas, 11th Floor, New York, NY 10104. 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.

Territorial Limitations.

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.

Contacting Us.

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:

Privacy Officer
Sirius XM Connected Vehicle Services Inc.
1500 Eckington Place
N.E. Washington, D.C., 20002
Or email us at privacy@siriusxm.com.

Do not include any sensitive or personal information in an email.