Privacy Statement for OnStar Vehicle Insights

Last Updated November 1, 2019

Your privacy is important to us. This Privacy Statement describes how we, General Motors Holdings LLC

and its affiliates (“GM” or “we” or “us”), collect, use, and share information when you download and/or

use the OnStar Vehicle Insights services (the, “Services”) via the compatible electronic device you own

or control, such as your Apple or Android mobile device, your Vehicle’s infotainment system, or such

other compatible computing system that you use to access the Services (each, your “Device”).via the

Service’s application (the, “Application”), the Service’s website (the, “Website”), or through your car or

truck (your “Vehicle”). This Privacy Statement incorporates the OnStar Privacy Statement, which is

posted at www.onstar.com/privacy, which also applies to your use of other OnStar services, and the

General Motors Privacy Statement, which is posted at https://www.gm.com/privacy-statement.html.

Together these privacy statements describe our privacy practices for the Services. Capitalized terms, if

not defined in this Privacy Statement, are defined in the OnStar Privacy Statement.

GM and the owner of the fleet of which the Vehicle is enrolled in, and any authorized representatives of

the fleet owner such as a fleet manager (collectively, “Fleet Owner”), may be able to see certain

information about you or the Vehicle through the Service if the Vehicle is equipped with GM connected

services. It is the responsibility of the Fleet Owner, or any individual the Fleet Owner designates, to notify

any drivers, passengers, or users of the Vehicle of this Privacy Statement and any connected services on

the Vehicle.

Information collected by the Service may include:

• Vehicle location (if GM connected services are enabled)

• Any personal information you provide us through the Application or Website

• Your driving behavior, including emergency events, airbag deployments, routes, hard breaks, and

hard accelerations (if GM connected services are enabled)

• view information describing how the Vehicles are being operated,

• Vehicle diagnostics (if GM connected services are enabled) interact, on a limited basis, with other

automotive vehicles that you own or control or that are part of your fleet.

Information We Collect

When you access the Services, we collect:

• Device information, such as the location of your Device, Device type, Device operating system,

Internet Protocol (IP) address, unique identifier, type of browser, Internet service provider,

information about your use of the Application, and phone number; and

• Information about your use of the Application or Website, including screen view time, scrolling,

specific actions to activate features and/or otherwise navigate the application, reactions to alerts,

searches, and your interactions with in-application marketing offers; and

• If enabled with GM connected services, information about your Vehicle such as license plate

number, vehicle identification number (VIN), mileage, oil/battery status, fuel or charging history,

electrical system function, gear status, and diagnostic trouble codes.

• If enabled with GM connected services, Information about the use of your Vehicle, including

operational and safety related information such as GPS location, speed, air bag deployments,

crash avoidance alerts, impact data, safety system status, braking and swerving/cornering

events, event data recorder (EDR) data, seat belt settings, vehicle direction (heading), camera

image and sensor data, voice command information, stability control or anti-lock events,

security/theft alerts, infotainment system usage, and WiFi data usage.

• OnStar account information associated with your Vehicle and/or fleet, vehicle-related information,

and driving information, such as the location and speed of your Vehicle based on GPS; and

• Information about you from additional online and offline sources including commercially or

publicly available third-party sources; and

• Information you input into the Service, such as your personal account information, notification

preferences, photos and images, and Vehicle check in or check out information such as Vehicle

type, time, and location;

• Demographic information (such as gender, date of birth, marital status and household

composition); and

• Marketing profile information

We collect and treat this information as described in the OnStar Privacy Statement and the GM Privacy

Statement.

Use of Your Information

We use the information we collect as described in the OnStar Privacy Statement and in the GM Privacy

Statement. For example, we use the information to:

• Provide the Services;

• Communicate with you about your account or the Services;

• To develop new products and services;

• Provide product and service updates;

• Provide you with marketing offers that may interest you, including offers relevant to the location of

your Device or Vehicle;

• Improve, troubleshoot, and evaluate the use of our products and Services (including the

Application and the Website);

• Evaluate the quality, safety, and security of our products and services;

• Collect outstanding debts for products and services;

• Protect the safety of you or others;

• For research, evaluation of use, and troubleshooting purpose; and

• Perform analytics across your Devices

Where required, we will anonymize your information in a way that it can't reasonably be associated with

you or your vehicle. We may use anonymized information or share it with third parties for any legitimate

business purpose.

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message

and other electronic messages, through the in-vehicle OnStar system or via our websites and

applications.

Restricting the Collection of Location and Speed Information

You can restrict our access to and collection of the location of your Device or Vehicle by disabling

location-sharing on your Device or Vehicle, if that feature is available. Your Fleet Owner may have

restrictions on disabling location sharing on your Vehicle. Please consult your Fleet Owner before

disabling location sharing on your Vehicle.

Sharing of Information

We share your account information, vehicle related Information, and driving information (such as the

location and speed of your Vehicle) as described in the OnStar Privacy Statement. For example, we

share information with necessary third parties when you use the Services to make requests for third party

or related services available through the Service, such as for dealer maintenance appointments or

roadside assistance. We may share the location of your Device in the same manner as we share location

and speed of your Vehicle. For example, we may share the location of your Device or Vehicle with:

• The Fleet Owner

• Third party service providers working on our behalf,

• Emergency service providers,

• Individuals specified by you or by your Fleet Owner

• Others when required by law, and

• Those you ask us to share this information with.

We may also share the location of your Device when necessary to provide the Application Services to

you; to comply with legal obligations; to protect the safety and rights of you and others; for product safety

and security purposes; and for the purposes described in the OnStar Privacy Statement.

Fleet Owner Use and Access

You understand that by linking your account with a fleet, the Fleet owner, colleagues, administrators, and

anyone designated by the Fleet Owner may view some or all of your information, including but not limited

to, images or photos for expense reporting or account identification, routes, Device and/or Vehicle

location, driver score, vehicle assignment, and check in/out status of a vehicle.

For a detailed description of the specific information collected by your Fleet Owner and/or employer and

how that information may be used by the Fleet Owner and/or employer, please consult the Fleet Owner

and/or Employer.

Your Obligations

We rely on you to inform any persons using your Device or Vehicle about this Privacy Statement and the

privacy choices you have made. We also rely on you to obtain any necessary consents for the information

you provide to us, including but not limited to any images or photos and any personal information of

others.

Cookies and Tracking Technologies

GM products and services use cookies, web beacons, pixels and other device tracking technologies that

allow us to identify you on your devices in a unique manner, such as through IP address or VIN

(collectively, “Cookies”), to gather information about your activity, such as demographic data, browser

type, pages visited, activities conducted on the page, and the day and time of your visit. We use Cookies,

sometimes across devices, to measure your activity, remember your preferences, maximize and improve

the performance of our website, products and services, and customize your experience (for example,

maintaining your account login or contact information, help you locate a nearby dealer, and autofill fields

on forms).

We may also combine this information with other information collected online or offline about you,

including information provided by third party sources, and it may be used or shared for the purposes

described in this Privacy Statement. We may also allow third party advertising and personalization

partners to use Cookies on our website in order to develop personalized content and appropriate

advertising based on your visits over time on GM websites and applications and non-GM websites and

applications. This information may also be used to evaluate our online advertising campaigns or to tailor

promotions and other marketing messages to you.

Similarly, we may also place Cookies in our emails to measure the effectiveness of our email campaigns

by identifying the individuals who open or act upon an email message, when an email message is

opened, how many times an email message is forwarded, the type of software, device, operating system

and browser used to deliver the email and any URL accessed through our email message.

California Do-Not-Track. At this time, we do not honor website browsers' "do not track" signals. However,

you may refuse or delete cookies, and otherwise express your choices on marketing issues as described

above.

Limiting Marketing and Promotional Communications

You may choose to limit the marketing and promotional communications we send you. You can do this by

visiting www.gmcontactpreferences.com and updating your contact preferences. We will also provide opt-

out instructions in all of our promotional communication channels; for example, an Unsubscribe option will

appear at the bottom of all marketing-related emails.

Security

We use technical, administrative, and physical safeguards designed to protect your information and we

require third party service providers to maintain similar safeguards against loss, misuse, and

unauthorized access, disclosure, alteration, destruction, or theft of your information.

Changes to This Privacy Statement

We reserve the right to update this Privacy Statement from time to time for any reason. We will notify you

of a material change to this Privacy Statement by placing a notice on www.onstar.com/privacy or within

the Application on your Device, or by notifying you via email or postal mail.

Access

If you would like to access or ensure the accuracy of your account information, please contact us at

+1.833.266.6565.