Effective Date: April 26, 2024

This Privacy Notice describes the information Subaru of America, Inc. (“Subaru”, “we”, “our”, or “us”) collects, how we use and retain this information, with whom we share it, and the choices you have in connection with these activities in the United States. “Affiliate” means a company directly or indirectly controlling, controlled by, or under common control with Subaru. All information posted in the Services is intended for the U.S. market only. 

1. SCOPE

This Privacy Notice applies when Subaru processes information from or about you in relation to our Mobility Assistance Program (the “Program”). See the Subaru Mobility Assistance webpage for more information. For information about how Subaru processes your personal information generally and your rights in connection with this click here.  

2. PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT

When you interact with the Program, we collect your personal information as described below. “Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for one or more disclosed operational purpose, or a service provider or contractor’s operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including related to safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete your personal information. 

A. When you engage with us regarding the Program.

• Submit a Completed Claim Form. When you submit the claim form for the Program, we will collect from you your identifiers (name, address, telephone number, email address), commercial information (retailer name, date of vehicle purchase, receipt that shows payment was made in full, vehicle purchase order and VIN#), and your signature. When you submit the claim form, we will also collect from you your medical information (letter from the doctor describing the condition or a doctor’s prescription). This is considered Sensitive Data or Sensitive Personal Information under applicable consumer privacy laws described below. We will use this information to process your claim, contact you regarding the status and decision related to your claim, and (if applicable) send you reimbursement money for the necessary vehicle modification cost.  This information will be retained for five years.
• Contact Customer Advocacy Department. When you contact the Customer Advocacy Department by telephone about the Program, we will collect your identifiers (name, address, telephone number, email address). With your consent, we will record this telephone conversation for training, quality assurance, and to comply with our legal obligations. We will use your identifiers to send you the claim form, to provide you with a status update on your claim, or to address any issues you have with your claim.  This information will be retained for two years.
• Access our mobility assist website. When you access our mobility assistance website, we also automatically collect from you information through cookies and similar technologies. For more information on this and your rights related to it click here. To opt out of the sharing of your information through certain trackers click here. 

3. HOW WE SHARE YOUR PERSONAL INFORMATION

A. General Sharing. Subaru shares personal information in the following instances:

• Within Subaru. We share your personal information within Subaru for the legitimate business purposes of efficiently and effectively providing the Program, such as accounting and customer service support. Access to your personal information is limited to those on a need-to-know basis.
• With service providers. We share personal information with service providers that assist us in providing the Services. These service providers are described more specifically in the PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT section of this Privacy Notice.
• In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
• For legal purposes. We will share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.
• With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time. 

Subaru may also share anonymized and aggregated data (“De-Identified Information”) in marketing materials and for benchmarking and internal analytics. Subaru may also use De-Identified Information for commercial collaborations with private companies for purposes such market analysis. 

B. Sharing in the Last Twelve (12) Months

For a business purpose. In the preceding twelve (12) months, Subaru has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

• We have disclosed your identifiers with service providers, including call center service providers, that assist us in providing the Services. These service providers assist us with the following: cloud data storage and infrastructure, customer services, auditing, data validation, website hosting, email communication, and customer relationship management. 

C. Sale/Sharing of Personal Information 

In the preceding twelve (12) months, Subaru has not sold or shared your information related to the Program. 

4. RIGHTS OF CONSUMERS

A. Rights of California, Connecticut, Virginia, Utah, and Colorado Residents

The California Privacy Rights Act (“CPRA”), Virginia Consumer Data Protection Act (“CDPA”), Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UTCPA”), and the Colorado Privacy Act (“CPA”) entitle residents of those states to certain rights. To the extent the CPRA, CDPA, CTDPA, UTCPA, or the CPA apply applies to our processing of your personal information, you are entitled to the following rights:

• Right to Access/Know. You have the right to request categories and/or specific pieces of personal information we have collected, used, disclosed, and sold about you, unless an exception applies. For California residents, you may only make a request for access twice within a 12-month period.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
• Right to Opt Out of Sale/Sharing. You have the right to opt out of the sale or sharing of your personal information to third parties. Subaru does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years without their affirmative consent.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt out, correct, or limit use of sensitive personal information.
• Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.
• Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin.
• Right to Appeal and File a Complaint. You have the right to appeal an action taken (or not taken) by Subaru in response to your request. We will inform you of any action we have taken in response to your request without delay and, in any event, within forty-five (45) days after we receive your request. If you believe your privacy rights have been violated, you can submit a complaint to the California Privacy Protection Agency at https://cppa.ca.gov/webapplications/complaint, the California Attorney General at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company, or the Connecticut Attorney General at https://www.dir.ct.gov/ag/complaint/e-complaint.aspx?CheckJavaScript=1?CheckJavaScript=1.
• Right to Data Portability. You have the right to ask that we transfer the personal information you gave us, to you, or in certain cases, directly to another organization, in a format that is easily understandable and to the extent technically feasible, in a structured, commonly used, machine-readable format. However, you make exercise this right no more than two times per calendar year.
• Right to Opt Out of Profiling. You have the right to opt out of profiling of your personal information in furtherance of decisions that produce legal or similarly significant effect concerning a consumer by fully automated means.
• Right to Opt Out of Targeted Advertising. You have the right to opt out of the processing of your personal information for targeted advertising purposes. 

For additional information regarding how to exercise your rights, please see EXERCISING YOUR RIGHTS immediately below or click here. 

C. Exercising your rights.

To exercise your rights, as applicable, you may submit a request by completing our webform, or by contacting us at our toll-free number 1-800-782-2783. To opt out of the sale or sharing of your personal information via cookies, please click here or utilize the opt out preference signal to instruct us to not sell or share any of your personal information collected online. The opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings. 

For requests submitted via email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information (which may include, but may not be limited to, your name, contact information and Vehicle Identification Number, if applicable) and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. 

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual. 

D. Nevada Residents

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. You can submit a request to opt-out of future sales by contacting us at https://www.subaru.com/support/consumer-privacy.html. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message. 

5. DO NOT TRACK

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com. 

6. SECURITY OF YOUR PERSONAL INFORMATION

We implement and maintain reasonable security measures to protect the personal information we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. These security measures include secure server software and firewalls designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you. 

7. AGE RESTRICTION

The Services are not intended for individuals under the age of eighteen (16) years old, and we do not knowingly collection personal information of persons under the age of 16 years old. If we learn that we have collected or received personal information from a child under the age of sixteen (16) years old, we will delete that information. If you believe we might have information from or about a child under the age of sixteen (16) years old, please contact us at https://www.subaru.com/contactus. 

8. CHANGES TO THIS PRIVACY NOTICE 

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and request your consent, if required. 

9. US MARKET ONLY

All information posted in the Services is only intended for the U.S. market. If you are accessing the Services from outside of the U.S., please be aware that information collected through the Program may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. 

10. CONTACT US

If you have any questions regarding this Privacy Notice, please contact us at 1-800-782-2783 or Subaru.com/contactus and we'll be happy to help in any way we can. 

Updated: April 26, 2024