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By entering into the SUBARU STARLINK Subscriber Agreement or using SUBARU STARLINK, you agree to the practices and procedures described in this Policy. These privacy practices apply to past, current and potential future subscribers who purchase and use SUBARU STARLINK. We may revise this Policy at any time, and any changes will be effective immediately upon the posting of the revised Policy on the SUBARU STARLINK web page. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the SUBARU STARLINK web page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Continued use of SUBARU STARLINK following changes to these terms will mean that you accept these changes. You can access the current policy online at www.MySubaru.com and www.Subaru.com, or request a copy by contacting us as set forth below.
By enrolling in or using SUBARU STARLINK, you consent to allow us to contact you about the Services via the SUBARU STARLINK system (the “System”) in your vehicle, your mailing address, email, and your home, mobile or business phone number on file. You also consent on behalf of other drivers or occupants of your vehicle to allow us to contact them through the System.
We may monitor or record conversations between you, another driver of your vehicle, or your vehicle’s occupants and the SUBARU STARLINK agent, between you, another driver of your vehicle or your vehicle’s occupants and the interactive voice recognition systems, or calls that occur outside the vehicle to or from our contact centers. BY ENROLLING IN THE SERVICES, YOU CONSENT TO SUCH MONITORING AND RECORDING ON BEHALF OF YOURSELF AND ANYONE USING OR OCCUPYING YOUR VEHICLE. THIS CONSENT IS INTENDED TO BE CONTINUOUS AND APPLY TO ALL SUCH CONVERSATIONS WITH OUR CONTACT CENTERS OVER TIME.
2. How SUBARU STARLINK Collects Information
We collect and store information voluntarily provided to us by you when you purchase a car and/or enroll in the Services, such as your name, address, telephone number, email address, and payment method information, when applicable, and information you provide us about your emergency contacts. We may collect and retain vehicle and service-related information, including but not limited to vehicle identification number and description; vehicle maintenance information; mechanical condition or incidents involving the vehicle including crash severity sensor data; time, location and speed of vehicle at a time of requested service; your or your vehicle’s occupants’ search content; your personal identification number (“PIN”) and information about a call related to the Services or your account, such as the date, time and duration of the call, the identity and phone number of the caller, and contents of or notes about the call. In addition, your vehicle may be equipped with one or more sensing or diagnostic modules capable of automatically retrieving, recording, transmitting, or storing certain vehicle data, including but not limited to trouble codes, tire pressure, battery voltage, coolant temperature, and service requirements. We may collect and retain data from any such modules in your vehicle.
We may record, monitor or determine the location of the vehicle or other information, regardless of who is driving it a) when you, other occupants, or another driver of the vehicle request the Services; b) when your vehicle’s air bag deploys or a severe impact occurs; c) when you report your vehicle as stolen; d) when we are required to do so by applicable local, state or federal laws, rules or regulations; or e) while diagnostic trouble codes are being transmitted. In addition, the LOCATION of fleet vehicles used by employees as company cars may be monitored by the employer or by the fleet management company leasing the vehicle to the employer.
3. Use of Information
We use the personal and vehicle information including your location data, whether received or collected from you, or other drivers or occupants of your vehicle, to deliver and improve SUBARU STARLINK, to provide other product information to you, to answer questions you pose to us, to inform you about special discounts or added services or functions, to notify you that your vehicle should be taken to a dealership for maintenance, to enhance communication between you and us, to manage your account, or to enforce the Subscriber Agreement. We do not share your personal information with third parties for their own marketing purposes without your consent; provided however that we may share your personal and vehicle information with Service Providers to permit them to market services for your vehicle to you (such as for a WiFi hotspot). We may also use your information for market research, an analysis of SUBARU STARLINK service usage, or in other ways to customize or improve our services.
4. Disclosure of Your Information
We may share your information including your location data, with third parties who assist us in the delivery or maintenance of the Services and subscriber accounts, such as suppliers, roadside assistance providers, emergency service dispatchers and providers, anyone you designate as an emergency contact and our affiliates for any of the purposes listed above. We do not supply your credit card information to any third party, other than as required to process and service a transaction.
We may release personal or vehicle-related information including location data, to law enforcement authorities in response to your request to locate a vehicle you reported as stolen. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law and may be compelled to disclose your information to government or law enforcement officials or private parties in response to a validly-issued subpoena or court order to:
· satisfy any applicable law, regulation, subpoenas, governmental requests, or legal process;
· protect and defend the Subscriber Agreement, including investigation of potential violations thereof;
· protect the safety, rights, property, or security of Subaru, SUBARU STARLINK, Service Providers, or any third party;
· protect the safety of the public for any reason;
· detect, prevent or otherwise address fraud, security, or technical issues; and
· prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.
If we should ever file for bankruptcy or merge with another company, or if we should decide to buy, sell, or reorganize some part or all of its business, we may disclose your information, including to prospective or actual purchasers in connection with one of these transactions.
We may provide aggregated data derived from your use of SUBARU STARLINK to third parties, but this data will be anonymized and will not include personally identifying information.
5. California Residents
Under California Civil Code Section 1798.83, also known as California’s “Shine the Light Law,” residents of California may request and receive, free of charge, a copy of Subaru’s California Information Disclosure Notice for the previous calendar year. This Notice lists the third party entities with which Subaru shared personal information for the third parties’ direct marketing purposes. To request this notice, please go to the Contact Us page on www.MySubaru.com, or request a copy by emailing or writing to the address above.
6. Updating and Managing Your Information.
You are responsible for maintaining the accuracy of the information you submit to us, such as the contact information provided as part of account registration. You may access, review, correct, or update the personal information you have provided to us, through your account at www.MySubaru.com, or by making a request through email or mail to the address below. You may opt-out of receiving unsolicited marketing or promotional email, mail or telephone communications by selecting your contact preferences online at www.MySubaru.com, by methods specified within the communications sent to you, or as otherwise provided by applicable law. If you opt out of receiving future promotional emails from us, we will implement your opt-out request within ten (10) business days of receiving it. If you have opted out of receiving future promotional materials by other means, we will implement such request within a commercially reasonable time.
Even if you opt out of receiving unsolicited promotional communications from us, we may still communicate with you via telephone (including by text message), mail, and electronic mail as necessary to provide the services to you and/or maintain your account.
We will retain your information as needed to deliver the services and to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, enforce our agreements, and to execute any other reason under this Policy. Anonymized data, without personal identifying information, may be aggregated and retained for as long as we determine in order to provide SUBARU STARLINK effectively.
7. Information from People under the Age of 18.
We do not knowingly collect, maintain or use personal information from people under the age of 18 years old without parental consent. You must be 18 years old or older to enter into an enrollment agreement for SUBARU STARLINK. If you are under the age of 18, please do not submit any personal information to us directly. You must ask a parent to do so on your behalf.
8. Security on a Cellular Telephone Network.
In providing SUBARU STARLINK to you, voice and data are transmitted between our response centers and your vehicle over a cellular telephone network. This network is complex and not necessarily secure. The privacy and security of conversations or data transmitted to and from the vehicle cannot be guaranteed.
9. Protection of Subscriber Information.
We use commercially reasonable safety procedures and policies commensurate with industry standards to protect your information from loss, theft, misuse, alteration, or disclosure. We store your information under commercially reasonable security measures with access limited to authorized employees or representatives. WE ASSUME NO RESPONSIBILITY OR LIABILITY WITH REGARD TO ANY THEFT, LOSS, ALTERATION OR MISUSE OF PERSONAL INFORMATION OR OTHER INFORMATION WHICH WE LAWFULLY PROVIDE TO THIRD PARTIES, OR WITH REGARD TO THE FAILURE OF ANY THIRD PARTY TO ABIDE BY THIS POLICY OR AGREEMENT BETWEEN THAT THIRD PARTY AND US OR YOU.
10. Contact Us
You may contact us in relation to this Policy at 1-800-782-2783 or Subaru.com/contactus. Or you may write to us at Subaru of America, Inc., Subaru Plaza, One Subaru Drive, Camden, NJ 08108, Attn: Customer/Retailer Service - Privacy. Please note that sensitive, personal information should not be sent via email.