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PRIVACY NOTICE
Version 1.1
Ford Motor Company, S.A. de C.V. (Lincoln), with registered office at Circuito Guillermo González Camarena Número 1500, Colonia Centro de Ciudad Santa Fe, Álvaro Obregón, C.P. 01210, Mexico City, Mexico, is responsible for the treatment of your personal information. The information of our clients is treated with strict confidentiality and is as important as their safety while driving our vehicles, which is why we make an ongoing effort to safeguard it.
COLLECTED DATA
The personal information, which Lincoln will handle in order for you to use the Lincoln Way®, are as follows:
1) Information to create or access your account: name, address, e-mail, telephone number (home and/or mobile), banking card information in order to perform a payment if needed, if you are a social network user, gender, likes and preferences.
2) Vehicle information: vehicle identification number (VIN), electronic serial number (ESN), hardware model, number of parts, diagnosis, odometer, model, year, color, ID of key in use, global positioning system (GPS) and integrated circuit card identifier (ICCID or SIM).
3) Information regarding the condition of the systems of your vehicle: information concerning the performance of the vehicle; door closing condition; tire pressure condition; doors, fuel shut-off, and air bags; fuel consumption, distance to empty, battery charge information; gear box positioning; ignition system condition; alarm condition; warning lights; problem diagnosing codes condition; battery condition; seatbelt condition; brake and acceleration pedals condition; break pad sensor condition; parking brake condition; door opening condition; and window condition. The aforementioned information will be originally linked to the VIN, ICCID and ESN, but shall be unattached before its storing and processing and will be stored and processed anonymously.
4) Information regarding its driving characteristics: track record, speed, accelerator use, brakes, steering wheel and seatbelts.
5) Information regarding the computer or mobile phone on which you access the Lincoln Way®: software or operating system version, unique identifiers of the device, IP address, information of the mobile network, location of the device, motion related information from the mobile device’s accelerometer, gyroscope and compass.
6) Information regarding the use of the Lincoln Way®: when and how often you use the Lincoln Way®, how is the Lincoln Way® performing, how does it use the services provided by third parties that integrate to the Lincoln Way®.
7) Information regarding the diagnosis remotely executed: it is possible for diagnosis or monitoring to be requested or executed in order to go through with repairs, services, improvements, or specific investigations of a product (it may be concerning quality or safety). The information sent to Lincoln will be pseudonymous and, if possible, anonymous.
8) Information regarding the remote updates: necessary information to go through with the updates. The information concerning the updates will be identifiable with regard to the VIN.
PURPOSE OF THE PERSONAL INFORMATION TREATMENT
More than a policy, in Lincoln we have the philosophy to maintain a close and active relationship with our clients. Therefore, Lincoln will handle your personal information for the following purposes:
a) Necessary purposes for the withstanding relationship with the Lincoln Way® user:
· Provide you with a good and/or service through the app functions;
· Allow you to control certain characteristics of your vehicle;
· Maintain our registers up to date, in order to respond the inquiries and requests that you share with us through the Lincoln Way®;
· Validate the guarantee of your vehicle;
· Provide updated and personalized location search
· Personalize your Lincoln Way® user experience;
· Develop new and improved products;
· Develop services, as well as marketing and investigation strategies, with the purpose of protecting your safety, property and privacy or complying with the legal demands.
· Go through with the diagnosis or monitoring of your vehicle and inform you about calls for revision or maintenance of your vehicle ; and
· Perform repairs or improvements to your vehicle and/or updates to the connectivity system, maps or other systems remotely.
b) OTHER PURPOSES:
· Perform marketing and advertisement activities;
· Offer our products, services and information regarding our business partners;
· Statistics and market analysis;
· Invite you to events;
· Make you knowledgeable of our offers and releases; and
· Anonymous processing of information in order to improve the vehicle and its components. Whenever remote diagnosis are performed in order to go through with a specific investigation regarding a product, such information will not be sent on an ongoing basis.
Given the case that our clients do not wish that Lincoln handles their personal information for the purposes contemplated in the aforementioned section b), they will have a 5 (five) days term to declare their denial by a dully signed writing that complies with the characteristics of the Arco Petition, which is mention in the present document, sent to the Personal Information Protection Committee of Lincoln and/or the Legal Affairs Office through e-mail to the following address: privacy1@ford.com; or presenting it on working days from 10:00 to 17:00 hrs; at the address of Lincoln mentioned at the opening of the present Privacy Notice.
MEASURES TO PROTECT THE PERSONAL INFORMATION
In order to prevent the non-authorized access to your personal information and with the purpose of insuring that the information will be used for the purposes stablished on the present Privacy Notice, Lincoln has set physical, electronic and administrative procedures, using advances technologies that limit the use or disclosure of your information, which allows to treat them adequately. Such procedures are evaluated and reviewed constantly by the Internal Control Area of Ford, with the purpose of controlling the use and disclosure of your personal information.
PERSONAL INFORMATION TRANSFER
With the purpose of providing a good or service, as well as to validate the guarantee of your vehicle, perform advertising activities, statistical analysis and marketing, as well as to deliver the information of our business partners, Lincoln may transfer your personal information both in the United Mexican States and abroad to subsidiary companies, affiliated or related to Lincoln, its Authorized Dealers and/or to third parties provider of services with whom they have a legal relationship, as well as the competent authorities.
The consent of the clients of Lincoln will not be necessary when the transfers are made to companies belonging to the same group as Lincoln, whenever they operate under the same internal procedures and policies; or when such transfer is necessary to provide a good or service, maintain our registers up to date, to respond inquiries, make the guarantee of your vehicle valid or make calls for revision of your vehicle derived from the commercial relationship.
To provide you with updated and personalized location search results through your SYNC 3 in-vehicle system that you have connected to Lincoln Way, we use cloud-based location services provided by Telenav, Inc. (“Telenav”). To provide these services, Telenav obtains certain information, including: a unique user ID assigned by Lincoln, your current GPS location and planned route and/or destination information from your SYNC 3 in-vehicle system, your address or point of interest search requests and search results selections, information about your use of the location search service, its performance, and your related actions and selections. Telenav may use this information to provide, improve, and enhance these products and services, and may store such information for up to two (2) years. By using location search services, you agree that we can disclose this information to Telenav for its use for these purposes.
Regarding the transfer of personal information of potential clients to third parties provider of services, we inform you that if you do not express your denial by submitting a petition dully signed by the Holder and complying with the characteristics of the ARCO Petition mentioned in the present document, addressed to the e-mail: privacy1@ford.com, or presenting it on working days from 10:00 to 17:00 hrs; at the address of Lincoln mentioned in the present document, in a five calendar days term, counting form the making available of the present Privacy Notice, we will acknowledge your granting of consent for such transfer.
ACCESS REQUEST, RECTIFICATION, CANCELING OR OPPOSING PERSONAL INFORMATION AND REVOKING THE CONSENTMENT (ARCO PETITION, FOR ITS SPANISH NAME)
All your personal information is treated according to the applicable and in force legislation in the country (United Mexican States), therefore, we inform you that you have the right to access at any time the personal information that Lincoln possesses and the details of the treatment of such, as well as to rectify them, given the case that that they are inaccurate or incomplete; cancel them when they turn out to be excessive or unnecessary for the purposes that justified their obtaining; and oppose their treatment for the purposes stablished on the present Privacy Notice, through the Personal Information Protection Committee of Ford and/or the Legal Affairs Office, by submitting a petition signed by the Holder, addressed to the e-mail: privacy1@ford.com,; or presenting it on working days from 10:00 to 17:00 hrs; at the address of Lincoln mentioned in the present document, that contains the following information:
· Full name of the Holder of the information.
· Address of the Holder of the information and/or e-mail address to communicate the response to the petition.
· Official documents that validate identity and/or authorization to be a representative in the petition (Valid Voting ID granted by the National Electoral Institute “INE” or valid Passport).
· Description of the personal information on which the exercising of an ARCO right is intended.
· Your vehicle serial number (VIN) (given the case).
· Any other element that allows the locating of your personal information and the attention to your petition.
Through these channels, on your petition, you can specify the means on which you want to receive the answer to such, since in the event of not having such specifications on your behalf, Lincoln will stablish the means on which to make you knowledgeable of the answer to your requirement.
MECANISMS AND PROCEDURES FOR THE REVOCATION OF CONSENT
At any moment, the clients can request the revocation of consent granted for the treatment of their personal information, communicating such request to the Personal Information Protection Committee of Ford and/or the Legal Affairs Office, by submitting a petition containing the conditions mentioned for the ARCO Petition, signed by the Holder, addressed to the e-mail: privacy1@ford.com, or presenting it on working days from 10:00 to 17:00 hrs. at the address of Lincoln mentioned at the opening of the present Privacy Notice. In any case, such petition must clearly specify the personal information on which the consent is being revoked.
OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL INFORMATION
Our clients have the possibility of limiting the use or disclosure of their personal information or refusing the transfer of such, by the Personal Information Protection Committee of Ford and/or the Legal Affairs Office, by submitting a petition signed by the Holder, complying with the characteristics of the ARCO Petition mentioned in the present document, addressed to the e-mail: privacy1@ford.com , or presenting it on working days from 10:00 to 17:00 hrs. at the address of Lincoln mentioned on the opening of the present Privacy Notice, detailing unequivocally the wanted limitation for the use of your personal information.
If you want to stop receiving advertising messages, you may request so through the Personal Information Protection Committee of Lincoln and/or the Legal Affairs Office, by submitting a request signed by the Holder addressed to the e-mail: privacy1@ford.com, or presenting it on working days from 10:00 to 17:00 hrs. at the address of Lincoln mentioned on the opening of the present Privacy Notice.
MECANISMS TO COLLECT PERSONAL INFORMATION AUTOMATICALLY ON REMOTE MEANS OR ELECTRONIC COMUNICATION SITES
The Lincoln Way application, the Lincoln Way internet website (www.lincolnwayapp.mx), as well as other sites and microsites property of Lincoln, use “cookies” of their own and from third parties for their functioning, therefore allowing us to obtain personal information of the Holder that reaches us by such means. The clients that browse through out websites may opt to deactivate the function of the “cookies” on their browser, considering that they may not view the full display of contents of such application and websites.
We inform you that automatically, through the remote means of communication, the modem and the system installed in your vehicle, some of the personal information mentioned on the section “Collected Data” of the present Privacy Notice will be sent to Lincoln with the aforementioned purposes, including the sending of information that is initially identifiable to the VIN, ICCID and ESN, but immediately will turn to anonymous information for different purposes. We inform you that you may avoid the sending of such personal information through the disconnection of the modem located at your vehicle or through the multimedia system of the vehicle. For further information about the disconnecting of the modem or disabling of the connectivity system, please consult the manual of your vehicle. Please consider that the disconnection of the modem will disable any type of software update that may be essential for the functioning of your vehicle and/or the hired connectivity service and, given the case, Lincoln will not be responsible in the event of a malfunction on your vehicle taking place or that you cannot use the connectivity service.
MODIFICATIONS TO THE PRIVACY NOTICE
Lincoln may modify the present Privacy Notice from time to time. Such modifications will be informed in due course to you through the website www.lincolnwayapp.mx or any other means of oral, written, or electronic communication or by the use of any other technology that Lincoln stablishes for such.
Last update date: October 21th, 2019