Effective as of: February 11th, 2016
To the extent we provide you notice on any UVO eServices of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
Table of Contents
You may give us Personal Information and Demographic Information, such as when you register or contact us. More
Your Vehicle gives us information detailed here. More
Tracking Technologies collect Usage Information based on your Device Identifier. More
We do not look for or respond to do not track signals, but you may have certain other options regarding tracking and/or targeting. More
We obtain information about your Vehicle’s location. More
We may obtain information about you from third parties. More
If you interact with third party sites, those sites may send us information about you and we may send them information about you. More
We and our service providers record conversations of you or your Vehicle’s occupants if UVO eServices are used to call our call center or our service providers. More
We use your Personal Information, Vehicle Information, Demographic Information and Usage Information for a variety of purposes. More
We may provide your information to third parties under various circumstances. These may include:
If you request information from third parties, request that we send information to third parties or if you interact with third party sites, content, ads or tools (including Twitter and other share third party share functionality), we may share your information with such parties and/or they may collect your information directly. More
Our vendors may collect your information or we may share it with them. More
There are a variety of administrative and legal reasons for which may share your information. More
We may share your information, either with our affiliates or in the event of a sale, merger or similar transaction. More
Co-branded areas may include information collection by us and third parties. Such third parties privacy policies, not ours, govern their practices. More
Promotions entrants may be required to consent to certain information sharing. More
We are not responsible for your interaction with third party content or locations. More
We are not responsible for your interaction with third party Apps. More
You may change certain MyUVO Account information and preferences. More
Data may be transferred to the United States and data may be transferred outside of the United States. More
We do not intend to collect Personal Information from children. If you think we have, let us know. More
No data security is absolute, but we take reasonable steps to secure data appropriately. More
KMA is committed to only retaining Personal Information and Vehicle Information for a period of time that is necessary to fulfill our legitimate business purposes. More
1. What Information Does UVO eServices Collect?
(a) Information You and Your Vehicle Provides To Us
(ii) Vehicle Information. When using your Vehicle, UVO eServices automatically (or passively), including, through the use of telematics, collects and stores information about your Vehicle, such as: (i) information about your Vehicle’s operation, performance and condition, including such things as diagnostic trouble codes, oil life remaining, tire pressure, fuel economy and odometer readings, battery use management information, battery charging history, battery deterioration information, electrical system functions; (ii) driver behavior information, which is information about how a person drives a Vehicle, such as the actual or approximate speed of your Vehicle, seat belt use, information about braking habits and information about collisions involving your Vehicle and which air bags have deployed; (iii) information about your use of the Vehicle and its features, such as whether you have paired a mobile Device with your Vehicle); (iv) the precise geographic location of your Vehicle; (v) data about remote services we make available such as remote lock/unlock, start/stop charge, parking location, climate control, charge schedules, and Vehicle status check; (vi) when there is a request for service made; and (vii) information about the Vehicle itself (such as the Vehicle identification number (VIN), make, model, model year, selling dealer, servicing dealer, date of purchase or lease and service history) (collectively, “Vehicle Information”). You consent to our collection, recording, access, retrieval storing and use of all such Vehicle Information, including, without limitation, to the extent that any aspect of the UVO eServices are considered an “event data recorder” under any applicable federal or state law.
(b) Information We Collect and/or Store As You Access And Use UVO eServices
In addition to any Personal Information, Demographic Information, Vehicle Information or other information that you choose to submit to us via UVO eServices, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information, whenever you visit or interact with UVO eServices (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your Vehicle’s UVO eServices Hardware, personal computer, laptop, tablet or mobile phone (each, a “Device”) whenever you visit or interact with UVO eServices. Usage Information may be non identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat the combined information as Personal Information.
This Usage Information may include:
We may use various developed methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies, include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit UVO eServices. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our UVO eServices may not function properly, and that when you revisit our UVO eServices, your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our UVO eServices’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to UVO eServices, to monitor how users navigate UVO eServices, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with UVO eServices, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to UVO eServices, and is deactivated or deleted thereafter.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple Devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our UVO eServices and third party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
(c) California Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
(d) Location-Based Information
UVO eServices use GPS software (or other location-based services) to locate you so we may verify your exact location, deliver you relevant content based on your location, as well as to allow you to share your location with third parties as part of the features offered through UVO eServices, which may, include, without limitation, the following:
(i) Crash Notification Assist. UVO eServices may automatically connect you to certain service providers such as the police, fire department, or ambulance service in the event of airbag deployment in your Vehicle and we will provide them with your location so they can find you and respond to your emergency.
(ii) Road Side Assist. We may provide road side assistance providers with your location in the event you request road side assistance so the road side assistance service provider may find you to assist you with your Vehicle issue.
(iii) Content-Based Services. The location of your Vehicle is collected and used to provide content-based services provided by UVO eServices such as navigation, maps and guidance, point-of-interest searches, and finding your closest charging station (for Kia electric vehicles), etc.
(iv) My Car Zone Features: Curfew Alerts, Geo-Fence, Parking Minder & Speed Watch. Your use of UVO eServices may allow you or others (such as in the case of a parent about a child driver of the Vehicle) to obtain information about a Vehicle’s location and other Vehicle Information, including the speed the Vehicle was driven. Through UVO eServices Hardware, you can opt through the settings to use certain features available through UVO eServices My Car Zone such as the curfew alert, parking minder, geo-fence and speed watch features, which will collect and share information about the Vehicle’s location (as well as other Vehicle Information). These features will collect information about the Vehicle’s location even if someone other than you is driving or occupying your Vehicle. For example, a parent who purchases a Vehicle for their child, can set preferences and controls on their UVO eServices Hardware that will collect information about their child’s driving habits such as when the Vehicle is being driven and information about whether the Vehicle is being driven beyond a pre-determined speed limit or pre-set boundary location. You understand that when you use any of these features, this Vehicle Information will be stored and available to be accessed when you log-in to your UVO eServices Hardware in the My Car Zone Features portion of UVO eServices and you may receive a detailed alert on your Device the next time you pair your Device with the Vehicle via Bluetooth wireless technology. You consent to the collection and use of such Vehicle Information in this manner and agree to give notice of these features to all other drivers and occupants of your Vehicle and obtain their consent to collect information about their use of the Vehicle.
(e) Information Third Parties Provide About You
(f) Interactions with Third Party Services
(g) Recording of Conversations with Sales, Customer Service Representatives and Interactive Voice Response
2. How Do We Use The Information Collected?
(a) Use of Information by Us.
Please note that information submitted to UVO eServices via a “contact us” or other similar function may not receive a response; we will not use that information so provided to contact you for marketing purposes unrelated to your inquiry unless you agree otherwise.
3. How and When Do We Disclose Information to Third Parties?
(a) When You Request Information From or Provide Information to Third Parties.
(b) Third Parties Providing Services on Our Behalf.
UVO eServices are provided to you by KMA. KMA in turn may interact with and/or engage one or more third party providers as necessary to provide UVO eServices. Those third party providers include any person, company, or entity who provides any service, equipment, or facilities in connection with UVO eServices, including, but not limited to, suppliers, licensors, emergency responders and other service providers (such as police, fire and ambulance), towing companies, automakers, distributors and dealers. Additionally, we may use third party vendors to perform certain services on behalf of us or UVO eServices, such as hosting UVO eServices, designing and/or operating UVO eServices’ features, tracking UVO eServices’ activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers, Vehicle Information and Personal Information, to carry out the services they are performing for you or for us. Third party analytics service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. These service providers use the Tracking Technologies described above to help us analyze how users use UVO eServices. We are not responsible for those third party Tracking Technologies or activities arising out of them. For example, we may use Adobe’s analytics and on-site personalization services. See www.adobe.com/privacy/analytics.html for more information. To learn about opting out of the use of Adobe cookies for analytics and on-site personalization, visit www.adobe.com/privacy/opt-out.html#4. After you opt-out of the use of Adobe cookies for analytics and on-site personalization, Adobe will no longer collect and analyze information via cookies associated with your browser for these services. When you opt out, Adobe will place opt-out cookies on your browser. If you delete your cookies, change browsers, or change devices, you will need to repeat this opt-out process. Also, please note that this opt-out process will work only if your browser is set to accept all cookies. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
(c) Administrative and Legal Reasons.
We may access, use, preserve, transfer and disclose your information (including Device Identifiers, Vehicle Information and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend UVO eServices’ Master Terms of Service or other policies applicable to UVO eServices, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of UVO eServices or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
(d) Affiliates and Business Transfer.
We may share your information, including your Device Identifiers and Personal Information, Vehicle, Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates (“Affiliates”). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of UVO eServices or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
(e) Co-branded Areas.
(f) Sweepstakes, Contests and Promotions.
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through UVO eServices that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
4. Do Third Party Content and Links To Third Party Sites Appear on UVO eServices?
UVO eServices may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from UVO eServices are served to you. In addition, when you are on UVO eServices you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple services and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off of UVO eServices onto a different site. These other services may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave UVO eServices and to review the third party privacy policies of all third party locations and exercise caution in connection with them.
5. Do Third Party Apps Appear on UVO eServices?
Third party Apps may be available via UVO eServices and our App Center. The owners of these Apps (“Third Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how Third Party Owners or their Apps collect or use your information and they may be tracking you across multiple services and may be sharing the results of that tracking with us and/or others. These Third Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third party privacy policies or the practices of Third Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third party application or otherwise interacting with it and exercise caution in connection with these Apps.
6. How Do I Change My Information And Communications Preferences?
7. Transfer of Information To And From The United States
8. Note To Parents About Children
We do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us here.
9. Note About Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use UVO eServices and provide us with your information at your own risk.
10. Data Retention, Deletion or De-Identification