Privacy Policy

Last Updated as of: September 6, 2018

OVERVIEW

 

YOU SHOULD READ THIS ENTIRE UVO SERVICES PRIVACY POLICY (“PRIVACY POLICY”), BUT HERE ARE SOME HIGH POINTS DETAILED BELOW:

  • You consent to our practices detailed in this Privacy Policy, including, without limitation, the collection, recording and storing of information, as further described below.  If you want to change your consent, you will need to: (i) remove UVO Services from your Kia Owners Portal (“KOP”) Account (defined below); (ii) stop using UVO SERVICES; (iii) uninstall the UVO SERVICES App from your mobile device (if you previously installed it); and (iv) contact the UVO Call Center at 1-844-UVO-9411 (1-844-886-9411), in order to determine whether UVO SERVICES Hardware (defined below) can be deactivated from your Vehicle.
  •  We ask you for, and use technology to detect and collect, information about you through UVO Services.  Some of this information is shared with third parties.
  • Third parties may directly collect information about you through UVO Services.
  • Currently, we do not monitor or take any action with respect to third party signals for the expression of choice regarding collection of information about an individual over time and across third-party web sites or online services (e.g., browser do not track signals).
  • Certain Kia Vehicles with embedded modems include a feature as part of UVO Services known as “Route Mapping”, which, if you enable, will allow us to collect and continuously stream GPS data from your Vehicle so that every time you drive your Vehicle, your locations, including the exact route driven in the Vehicle for all Vehicle trips, will be stored and available for review in your KOP Account.  If you wish to discontinue utilizing the “Route Mapping” feature, you will need to: (i) contact the UVO Call Center at 1-844-UVO-9411 (1-844-886-9411); or (ii) visit your KOP Account and look for applicable settings that allow you to turn off the Route Mapping feature.
  • This Privacy Policy does not apply if you have UVO Play installed in your Vehicle.
  • Click HERE for a table of contents of topics covered.  You may click on any topic to go to the details.

TO PRINT OUR PRIVACY POLICY, CLICK HERE. TO PRINT OUR TERMS OF SERVICE, CLICK HERE.

INTRODUCTION

Welcome to UVO SERVICES!  The term “UVO SERVICES” refers to our suite of UVO products (including, without limitation, UVO eServices, UVO link, UVO luxe and UVO eco, but excluding UVO play).  To access or use features available through UVO Services, you may have either visited the Kia Owners Portal (formally known as a MyUVO account and available at www.myuvo.com) or the Kia Owners Portal/UVO smartphone application (the “UVO SERVICES APP”), have UVO SERVICES Hardware (defined below) installed within your Vehicle (defined below) or are otherwise accessing our App Center that is available through your Vehicle’s headunit, which you can use to download applications (“APPS”) for use in your Vehicle.  UVO SERVICES are provided by Kia Motors America, Inc. (collectively, “KMA,” “WE,” “OUR” or “US”).  This Privacy Policy governs your use of UVO SERVICES and also applies to your use of the interactive features, widgets, Apps, content or downloads that we make available through (or interact with) UVO SERVICES and post this Privacy Policy regardless of how you access or use them, whether via personal computers, mobile devices, through your Vehicle’s headunit or otherwise.  Your Kia vehicle (“VEHICLE”) must come equipped with authorized UVO SERVICES hardware (the UVO SERVICES HARDWARE”), which is the equipment, including all hardware (e.g., certain Vehicle makes and models include embedded modems) and software, used to provide UVO SERVICES to your Vehicle.  

TO THE EXTENT WE PROVIDE YOU NOTICE ON ANY UVO SERVICES 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.

 

In addition, please review UVO SERVICES’ TERMS OF SERVICE, which governs your use of UVO SERVICES.  By using UVO SERVICES, you consent to our UVO SERVICES Privacy Policy and Terms of Service and our collection, use and sharing of your information and data, and other activities, as described below.

 

TABLE OF CONTENTS

 

IT IS IMPORTANT THAT YOU READ AND UNDERSTAND THE ENTIRE PRIVACY POLICY BEFORE USING UVO SERVICES. HOWEVER, THIS TABLE OF CONTENTS HIGHLIGHTS KEY ISSUES AND POINTS AND YOU CAN CLICK ON THE HEADINGS AND THE “MORE" LINKS TO BE TAKEN TO THE FULL EXPLANATION.

 

1.    WHAT INFORMATION DOES UVO SERVICES COLLECT?

    (a)    Information You and Your Vehicle Provides to Us

                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

    (b)     Information We Collect and/or Store As You Access And Use UVO Services

                Tracking Technologies collect Usage Information based on your Device Identifier.  More

    (c)     California / Delaware Do Not Track Disclosures

                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

    (d)     Location-Based Information

                We obtain information about your Vehicle’s location.  More

    (e)     Information Third Parties Provide About You

                We may obtain information about you from third parties.  More

    (f)      Interactions with Third Party Services

                If you interact with third party sites, those sites may send us information about you and we may send them information about you.  More

    (g)     Recording of Conversations With Sales, Customer Service Representatives and Interactive Voice Response

                We and our service providers record conversations of you or your Vehicle’s occupants if UVO SERVICES are used to call our call center or our service providers.  More

2.     HOW DO WE USE THE INFORMATION COLLECTED?

    (a)     Use of Information By Us

                We use your Personal Information, Vehicle Information, Demographic Information and Usage Information for a variety of purposes.  More

3.    HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

    We may provide your information to third parties under various circumstances. These may include:

    (a)     When You Request Information From or Provide Information to Third Parties

                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 third party share functionality), we may share your information with such parties and/or they may collect your information directly.  More

    (b)     Third Parties Providing Services on Our Behalf

                Our vendors may collect your information or we may share it with them.  More

    (c)     Administrative and Legal Reasons

                There are a variety of administrative and legal reasons for which we may share your information.  More

    (d)     Affiliates and Business Transfer

                We may share your information, either with our affiliates or in the event of a sale, merger or similar transaction.  More

    (e)     Co-branded Areas

                Co-branded areas may include information collection by us and third parties.  Such third parties privacy policies, not ours, govern their practices.  More

    (f)      Sweepstakes, Contests and Promotions

                Promotions entrants may be required to consent to certain information sharing.  More

4.    DO THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SITES APPEAR ON UVO SERVICES?

    We are not responsible for your interaction with third party content or locations.  More

5.    DO THIRD PARTY APPS APPEAR ON UVO SERVICES?

    We are not responsible for your interaction with third party Apps.  More

6.    HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?

    You may change certain KOP Account information and preferences.  More

7.    TRANSFER OF INFORMATION TO AND FROM THE UNITED STATES

    Data may be transferred to the United States and data may be transferred outside of the United States.  More

8.    Note to Parents About Children

    We do not intend to collect Personal Information from children.  If you think we have, let us know.  More

9.    Note About Security

    No data security is absolute, but we take reasonable steps to secure data appropriately.  More

10.    Data Retention, Deletion or De-Identification

    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

11.    Changes to The Privacy Policy

    We may change this Privacy Policy as explained here.

The Full Detailed Privacy Policy

 

1.    What Information Does UVO SERVICES Collect?

 

    (a)    Information You and Your Vehicle Provides to Us

        (i)    Personal Information and Demographic Information.  To use UVO SERVICES, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, information about the purchase or lease of your Vehicle, such as the Vehicle identification number, your mobile phone number, e-mail address, home address and biometrics information (collectively, “PERSONAL INFORMATION”); and (2) demographic information, such as information about your gender and your preferred authorized Kia retailer (collectively, “DEMOGRAPHIC INFORMATION”).  We may collect this information through various forms and in various places on UVO SERVICES, including account registration forms, or when you otherwise interact with UVO SERVICES.  If we combine Demographic Information with the Personal Information we collect directly from you on UVO SERVICES, we will treat the combined data as Personal Information under this Privacy Policy.

        (ii)    Vehicle Information.  When using your Vehicle, UVO SERVICES automatically (or passively), collects and stores information about your Vehicle, including, through the use of telematics and/or an embedded modem, 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 SERVICES 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 SERVICES

In addition to any Personal Information, Demographic Information, Vehicle Information or other information that you choose to submit to us via UVO SERVICES, 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 SERVICES (“USAGE INFORMATION”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your Vehicle’s UVO SERVICES Hardware, personal computer, laptop, tablet or mobile phone (each, a “DEVICE”) whenever you visit or interact with UVO SERVICES.  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:

  • your IP address or other unique identifier (“DEVICE IDENTIFIER”).  A Device Identifier is a number that is automatically assigned to your Device used to access UVO Services, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware and mobile network information);
  • the URL that referred you to UVO Services;
  • the areas within our UVO Services that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day, among other information.

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 Services.  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 Services may not function properly, and that when you revisit our UVO Services, 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 Services’ 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 Services, to monitor how users navigate UVO Services, 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 Services, 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 Services, 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:

Strictly Necessary.  We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our UVO Services, including cookies required to prevent fraudulent activity or improve security.

Performance‑Related.  We may use cookies or other Tracking Technologies that are useful in order to assess the performance of UVO Services, including as part of our analytic practices or otherwise to improve the content or services offered through UVO Services.

Functionality‑Related.  We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing UVO Services, including identifying you when you sign‑in to our UVO Services or keeping track of your specified preferences, including in terms of the presentation of content on UVO Services.

Targeting‑Related.  We may use Tracking Technologies to deliver content relevant to your interests on our UVO Services 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. 

There may be other Tracking Technologies now and later devised and used by us in connection with UVO Services.  Further, third parties may use Tracking Technologies with UVO Services, which may include the collection of information about your online activities over time and across third-party web sites or online services.  We may not control those Tracking Technologies and we are not responsible for them.  However, you consent to potentially encountering third party Tracking Technologies in connection with use of our UVO Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. 

 

    (c)    California / Delaware 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 Services 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 Services, which may include, without limitation, the following (Not all of these services may be available in your Vehicle, but if they are, the following applies):

        (i)  Crash Notification Assist.  UVO Services 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 Services 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 Services 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 Services Hardware, your KOP Account or the UVO Services App, you can opt through the settings to use certain features available through UVO Services’ 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 Services Hardware, KOP Account or the UVO Services App 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 KOP Account in the My Car Zone Features portion of UVO Services and you may receive a detailed alert on your Device.  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.

        (v) Route Mapping.  Your use of UVO Services may allow you or others (such as in the case of a parent about a child driver of a Vehicle) to obtain information about each route (including identification of each road) driven and places visited when driving a Vehicle.  Once this “Route Mapping” feature is turned on, we will continuously collect (through streaming GPS technologies) information about the Vehicle’s location and your driving routes 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 Services Hardware that will collect information about their child’s Vehicle’s location, such as all of the roads the Vehicle has being driven on by the child and information about all the locations the Vehicle has been visited by the child.  Thus, Route Mapping will allow us to collect and continuously stream GPS data from your Vehicle so that every time your Vehicle is driven, all locations, including the exact route driven in the Vehicle for all Vehicle trips, will be stored by us and available for you to review in your KOP Account.  We may make settings available in your KOP Account that will allow you to delete trip information.  If you wish to discontinue utilizing the “Route Mapping” feature, you will need to: (i) contact the UVO Call Center at 1-844-UVO-9411 (1-844-886-9411); or (ii) visit your KOP Account and look for applicable settings that allow you to turn off the Route Mapping feature.  You understand that when you use this feature, this Vehicle Information will be stored and available to be accessed when you log-in to your KOP Account in the ‘Trip Information’ features portion of UVO Services.  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

We may receive information about you from third parties such as the Kia dealer where you purchased your Vehicle.  We may, from time to time, supplement the information we collect directly from you on our UVO Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.  To the extent we combine information we receive from those sources with Personal Information we collect on UVO Services, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise.  In no other circumstances do our promises under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

 

    (f)    Interactions with Third Party Services

UVO Services may include functionality that allows certain kinds of interactions between UVO Services and your KOP Account on a third party web site or application.  The use of this functionality may involve the third party operator providing certain information, including Personal Information, to us.  For example, when you register with UVO Services, you may have an option to use your Facebook, Twitter, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process or otherwise link accounts.  If we offer and you choose to use this functionality to access or use UVO Services, the third-party site or application may send Personal Information about you to us.  In addition, we may provide third party sites’ interfaces or links on the UVO Services App to facilitate your sending or receiving a communication.  Thus, we may use third parties to facilitate e-mails, Tweets or Facebook postings.  These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy.  KMA may not control or have access to your communications through these third parties.  You should review the applicable third party privacy policies before using such third party tools through UVO Services, and we are not responsible for these parties’ practices.

 

    (g)    Recording of Conversations With Sales, Customer Service Representatives and Interactive Voice Response

We and our service providers may monitor and record conversations between service center representatives and your Vehicle’s occupants, as well as any conversations between our service center representatives and you or others contacting the service centers to discuss your KOP Account.  Additionally, we and our service providers may collect and store audio files of voices in the Vehicle when you use certain features of UVO Services that incorporate voice recognition technologies.  We may collect, record, store and monitor such conversations and other interactions between us and between you and voice recognition features of UVO Services in order to maintain and improve the quality of our service, for training purposes or to promote and provide UVO Services.  Call center advisors may remain on the line, if, during a request for service, we conference in a third party such as emergency service providers or the police.  It is important for you to know that these parties may also separately record and/or monitor the interaction.  Call recordings may be shared with Kia dealers and other service providers to fulfill the purpose of your call or for the reasons otherwise detailed in this Privacy Policy.  YOU CONSENT, ON BEHALF OF YOURSELF, ALL OCCUPANTS OF YOUR VEHICLE, AND ANYONE ENGAGED IN A CONVERSATION WITH A SERVICE PROVIDER ABOUT YOUR VEHICLE OR YOUR KOP ACCOUNT, TO THE MONITORING AND RECORDING OF ALL CONVERSATIONS BETWEEN THE SERVICE CENTERS AND SUCH PERSONS.   

 

2.    How Do We Use The Information Collected?

 

    (a)    Use of Information by Us.  We may use your Personal Information, Vehicle Information, Demographic Information or Usage Information that is subject to this Privacy Policy: (1) to provide you with information or services or process transactions that you have requested or agreed to receive including to assist with scheduling an appointment with a Kia dealer so you can have your Vehicle serviced; (2) to enable you to participate in a variety of UVO Services’ features such as to provide you with an eco & safe driving score; (3) to process your registration with UVO Services, including verifying your information is active and valid; (4) to improve UVO Services or our services, to customize your experience on UVO Services, or to serve you specific content that is relevant to you; (5) to contact you with regard to your use of UVO Services and, in our discretion, changes to UVO Services and/or UVO Services’ policies; (6) for internal business purposes; (7) to investigate any warranty or other type of claim or in any dispute with you (e.g., in the instance you fail to follow any recommended maintenance notifications provided by or through UVO Services and we determine that your Vehicle is no longer eligible for warranty service); and (8) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy or our Terms of Service or any applicable Additional Terms. 

Please note that information submitted to UVO Services 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?

We may share non-personally identifiable information and Vehicle Information, such as aggregated user statistics, with third parties.  We may share your Device Identifiers with third parties along with data related to you and your activities.  We do not share your Personal Information that we have collected directly from you on our UVO Services with third parties for those third parties’ marketing purposes unless you consent to such sharing at the time you provide your Personal Information.  In addition, we may share the information we have collected about you, including Personal Information and Vehicle Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.

 

     (a)    When You Request Information From or Provide Information to Third Parties.  You may be presented with an option on our UVO Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties.  In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, Apps or ads on our UVO Services or link to them from our UVO Services.  This may include using third party tools such as Twitter, Google Maps or other third party posting or content sharing tools.  We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices prior to requesting information from or otherwise interacting with them.  For example, if you are utilizing the maps or navigation functionality available through UVO Services, these services are provided through the incorporation of Google Maps APIs into the UVO Services and therefore you acknowledge that Google Inc.’s Privacy Policy (currently found at http://www.google.com/policies/privacy), as amended by Google from time to time, applies to any collection and use of your information by Google.

 

    (b)    Third Parties Providing Services on Our Behalf.  UVO Services 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 Services.  Those third party providers include any person, company, or entity who provides any service, equipment, or facilities in connection with UVO Services, including, but not limited to, suppliers, licensors, emergency responders and other service providers (such as police, fire and ambulance), towing companies, automakers, insurance companies, data aggregators, distributors and dealers.  Additionally, we may use third party vendors to perform certain services on behalf of us or UVO Services, such as hosting UVO Services, designing and/or operating UVO Services’ features, tracking UVO Services’ 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 Services.  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 http://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 http://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 Services’ MASTER TERMS OF SERVICE or other policies applicable to UVO Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of UVO Services 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 Services 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.  Certain areas of UVO Services may be provided to you in association with third parties (“CO-BRANDED AREAS”) such as sponsors and Kia dealers and may require you to disclose Personal Information to them.  Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of you information.  If you elect to register for products and/or services, communicate with such third parties or download their content or Apps, at Co-Branded Areas, you may be providing your information to both us and the third party.  Further, if you sign-in to a Co-Branded Area with a username and password obtained on UVO Services, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area.  We are not responsible for such third party’s data collection or practices and you should look to such third party privacy policies for more information.

 

    (f)    Sweepstakes, Contests and Promotions.  We may offer sweepstakes, contests, and other promotions (any, a “PROMOTION”) through UVO Services 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 SERVICES?

UVO Services 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 Services are served to you.  In addition, when you are on UVO Services 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 Services 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 Services 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 SERVICES?

Third party Apps may be available via UVO Services and our App Center.  The owners of these Apps (“THIRD PARTH 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?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of your KOP account (formally known as a “MYUVO ACCOUNT”) (“KOP ACOUNT”) registration.  Your KOP Account may allow you to review, correct or update Personal Information that you have provided through UVO Services’ registration forms or otherwise and may allow you to review certain types of Vehicle Information collected through UVO Services, such as in-Vehicle diagnostics.  If you make changes to your KOP Account information after logging in to your KOP Account, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.  With respect to UVO Services App, you can prospectively stop all collection of information through your mobile Device by uninstalling the application.  You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace.  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  When you edit your Personal Information or change your preferences on your KOP Account, information that you remove may persist internally for KMA’s administrative purposes.  You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your KOP Account and changing your communication preferences.  This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited.  If you subscribe to text messages from us, you can terminate a particular text message subscription by reply texting “STOP.”  Subsequent or different subscriptions will be unaffected.  Please note that we reserve the right to send you certain communications relating to your KOP Account or use of our UVO Services, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Kia Motors America, Inc., 111 Peters Canyon Road, Irvine, CA  92606, Attn: KMA Consumer Affairs, or by sending us a message HERE.   If you wish for UVO Services to stop collecting Vehicle Information, please contact your Vehicle technician who can determine whether UVO Services Hardware can be uninstalled from your Vehicle.

 

7.    Transfer of Information to And From The United States

UVO Services are operated in the United States and intended for users located in the United States.  If you are located outside of the United States, please be aware that information we collect, including Personal Information, may be transferred to, and processed, stored and used in the United States.  Additionally, information, including Personal Information collected in connection with the operation and use of the UVO Services, may be processed and/or transferred outside of the United States.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States and may be subject to access requests from governments, courts, or law enforcement in the other countries according to laws of those countries.  By using UVO Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States and other countries, as set forth in this Privacy Policy.

 

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 Services and provide us with your information at your own risk.

 

10.    Data Retention, Deletion or De-identification

KMA is committed to only retaining Personal Information and Vehicle Information for a period of time that is necessary to fulfill a legitimate business purpose and deleting or de-identifying the information thereafter.  The legitimate business purposes for which we retain information are described in Section 2 above and throughout this Privacy Policy but may additionally include, without limitation: to provide, develop and improve the products and services we make available through UVO Services, to maintain the security, integrity and operation of UVO Services, to comply with our legal and regulatory obligations and other third party requirements,  to resolve disputes, to enforce our agreements, to diagnose and troubleshoot Vehicle systems, to improve Vehicle safety, to communicate with you, to prevent fraud or criminal activity, to maintain warranty and business records and for other purposes we determine in our sole discretion.  In certain instances, this may potentially include retaining Personal Information and Vehicle Information in perpetuity provided we have a legitimate business purpose for needing to retain the information forever.  Once we determine there is no longer a legitimate business purpose for retaining either Personal Information or Vehicle Information, we will delete or de-identify such information, as determined in our sole discretion.

 

11.    Changes to The Privacy Policy

We reserve the right to change this Privacy Policy at any time without notice to you.  Any changes will be effective immediately upon the posting of the revised Privacy Policy.  However, we will not use your Personal Information in a manner materially different than promised at the time it was collected without your consent.  To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.