PRIVACY POLICY

This Privacy Policy is effective and was last updated on January 1, 2020.

Introduction

Welcome to UVO Services!  The term "UVO Services" refers to our suite of UVO products (including, without limitation, UVO products currently or previously branded as UVO eServices, UVO link, UVO luxe and UVO eco or any other UVO services).  To access or use features available through UVO SERVICES, you may have either visited the Kia Owners Portal (formally known as a MyUVO account) or a 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 may be available through your Vehicle’s head unit, which, if available for your Vehicle, you can use to download applications ("Apps") for use in your Vehicle.  UVO Services are provided by Kia Motors America, Inc. (collectively, "Kia", "we", "our" or "us").  

This privacy policy ("Privacy Policy") describes how we collect, use, and share information when you use UVO Services. This Privacy Policy governs your use of UVO Services, our use of your data, and also applies to your use of the interactive features, widgets, Apps, content or downloads that we make available through (or that interact with) UVO Services and which post a link to this Privacy Policy regardless of how you access or use them, whether via personal computers, mobile devices, through your Vehicle’s head unit or otherwise.  In order for you to use UVO Services, the Kia Vehicle ("Vehicle") must come equipped with the equipment, including hardware and software, used to assist with providing UVO Services (the "UVO Services Hardware"). 

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 this Privacy Policy, the Terms of Service, and our collection, use and sharing of your information and other activities, as described below. 

Linkable Table of Contents

  1. Who We Are
  2. What Information Do We Collect?
  3. How Do We Use The Information?
  4. Do UVO Services Contain Third Party Content and Links to Third Party Services?
  5. Do Third Party Apps Appear on UVO Services?
  6. How Do I Change My Information and Communication Preferences?
  7. Where Does Kia Process the Information?
  8. What About Information on Children and Minors?
  9. What About Security?
  10. Data Retention, Deletion, or De-identification
  11. What About Changes to the Privacy Policy?
  12. Your California Privacy Rights

 

1. Who We Are

Kia is a United States based subsidiary of Kia Motors Corporation, which is based in Seoul, South Korea. We are the exclusive distributor of Kia-branded motor Vehicles, parts, and accessories in the United States. Our "dealers" and "licensees" are independent companies that sell our Vehicles, parts, and accessories, and are licensed to operate such businesses using the trade names, trademarks, and service marks owned by us or our affiliates. Our "business partners" are independent companies that we contract with to provide you with or offer you other services and products. In this Privacy Policy, we refer to dealers, licensees, and business partners collectively as "Partners." This Privacy Policy governs only Kia's privacy practices for UVO Services. It does not govern the privacy practices of our Partners, even if you contact them or connect to their websites from UVO Services. To learn about the privacy practices of our Partners, please review the privacy policies of each of those Partners. 

Our "Affiliates" include our parent company(ies), subsidiaries, sister companies, and affiliated companies. As described below, we may share information that we collect with our Affiliates. Our Affiliates may have their own privacy policies that govern their treatment of information that you provide to them directly or that they collect when you use their websites, applications, or other services. For example, Kia customers who have financed or leased a Kia Vehicle through Kia Motors Finance will be subject to Kia Motors Finance’s own privacy policy (and terms of use) with respect to the information collected via Kia Motors Finance’s websites, applications, and other services.

 

2. What Information Do We Collect?

Through UVO Services, we collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information"). Depending on how you use the available UVO Services, we may have collected the following categories of Personal Information from you in the last twelve (12) months, which we may also share with third parties for the purposes outlined in this Privacy Policy.  The categories below are those identified in the California Consumer Privacy Act (CCPA). Please note that we have not collected every type of Personal Information identified in the Examples below on every user of UVO Services, and the types of Personal Information we have collected on, or shared about, any consumer depends on what UVO Services the consumer has used.  

Category

  • Examples

Collected?

Identifiers.

This category may include: name, postal address, unique personal identifiers, online identifiers, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Under the CCPA, "unique identifiers" or "unique personal identifier" means a persistent identifier that can be used to recognize a consumer, a family, or a device that is linked to a consumer or family, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device.

YES

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

This category may include: name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education or employment information, financial account numbers, medical information, or health insurance information.

YES

Protected classification characteristics under California or federal law.

This category may include: age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex and gender information, veteran or military status, or genetic information.

YES

Commercial information.

This category may include: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

Biometric information.

This category may include: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted.

NO

Internet or other electronic network activity information.

This category may include: browsing history, search history, and information regarding interactions with an Internet Web site, application, or advertisement.

YES

Geolocation data.

This category may include: physical location or movements.

YES

Sensory data.

This category may include: audio, electronic, visual, thermal, olfactory, or similar information.

NO

Professional or employment-related information.

This category may include: current or past job history or performance evaluations.

NO

Non-public education information

This category may include: education records directly related to a student maintained by an educational institution or party acting on its behalf (e.g., grades, transcripts, schedules, and student ID numbers).

NO

Inferences drawn from other personal information.

This category may include: inferences drawn from the above information that may reflect your preferences, characteristics, predispositions, behavior, attitudes, or similar behavioral information.

YES

 

The below sections describe how we collect information from UVO Services, our purposes for collection, and how we may share and use the information. Our data collection and usage greatly varies depending on the UVO Services available in your Vehicle, and how you may choose to interact with us and the UVO Services. 

Information Collected Directly From You and Your Vehicle. Depending on the UVO Services available for your Vehicle, the following types of information may be provided to us by you (or your Vehicle), as applicable:

  • Personal Information and Demographic Information. If you sign-up to use UVO Services, we may ask you to provide us with certain categories of Personal Information such: (1) identifiers, which is information that identifies you personally like the examples listed above; and (2) demographic information, such as information about your gender or your preferred authorized Kia retailer. We may collect this information through various forms and from various places on UVO Services, including account registration forms, or when you otherwise interact with certain UVO Services. 
  • Vehicle Information. When using your Vehicle, certain UVO Services that may be available in your Vehicle automatically (or passively), collect and store information about your Vehicle, including through the use of telematics and/or an embedded modem, if applicable to your Vehicle.  This type of information may include: (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, 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 may 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), model, model year, trim, selling dealer, servicing dealer, date of purchase or lease and service history) (collectively, "Vehicle Information"). 

Information We Collect Through Automatic Data Collection Technologies.  As a user navigates through and interacts with UVO Services, we may use automatic data collection technologies that automatically (or passively) store or collect certain information, whenever you visit or interact with certain UVO Services ("Usage Information"). Some Usage Information may be considered Personal Information, such as if and when it is linked to any information that reasonably identifies you. This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your Vehicle's UVO Services Hardware, your personal computer, browser, laptop, tablet, mobile phone or other device (each, a "Device") whenever you visit or interact with UVO Services. Usage Information may include, but is not limited to, the following technologies and information:

  • Device information. Information about the Device used to access UVO Services, which may include: your IP address or other Device identifier that is automatically assigned to a Device used to access UVO Services; your Device functionality (including browser, operating system, hardware and mobile network information), location, and characteristics; and other Device data, including the time of day, among other information. 
  • Cookies.  A cookie is a data file that may be placed on a Device that is used to utilize UVO Services. We may use Cookies for many purposes, including, without limitation, remembering a user and his/her preferences, and learning how you interact with our UVO Services. Please be aware that if you disable or remove cookies on a Device that you use to utilize 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. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web or mobile 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 users of UVO Services and to learn how users interact with UVO Services, to let us know whether you viewed our emails or other electronic communications, and to learn whether our ads are effective.
  • Embedded Scripts.  An embedded script is code that helps us collect information about a user's interactions with certain UVO Services, such as the links clicked on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, and is active only while you are connected to UVO Service
  • 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
  • Location-Based Information.  Some UVO Services use GPS (or other location-based services) to locate you so that we may verify your exact location, deliver relevant content based on your location, and provide certain UVO Services (more fully described below). 

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). Because a "Do Not Track" protocol has not yet been finalized, the information collection and disclosure practices of our websites, and the choices that our websites provide to consumers, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received. Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

Recording of Conversations With Sales, Customer Service Representatives and Interactive Voice Responses. 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 Kia Owners Portal account ("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, and such actions are outside of Kia's control.  

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, which will have its own privacy policy that applies to the third party's 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 practices and you should review the third party's privacy policy for more information.

3. How Do We Use The Information?

We may use the information we collect in order to:

  • Process your registration for UVO Services;
  • Provide you with information or services that you have requested or agreed to receive such as requests for a service appointment with a Partner's dealership;
  • Enable you to participate in a variety of UVO Services' features such as Roadside Assistance Find My Car, or Remote Start with Climate Control;
  • Customize and personalize your experience with UVO services;
  • To understand you and your preferences to enhance and personalize your experience;
  • Maintain, operate, and improve the UVO Services and our vehicles, products, and other offerings, including delivering software updates;
  • Develop new UVO Services, vehicles, and products; 
  • Contact you with regard to your use of UVO Services or changes to UVO Services and/or policies;
  • Send you special offers or promotional materials on behalf of us or third parties;
  • Advise you of important safety-related information, such as recalls;
  • Learn more about our customers and their experiences and to monitor your satisfaction with Kia products and UVO Services provided to you;
  • Detect and prevent fraudulent, unlawful, unauthorized, or abusive use of UVO Services;
  • Conduct internal research;
  • Support our internal business operations; and
  • Process information as disclosed at the time we collect the information or as otherwise set forth in this Privacy Policy or in any other document made available to you. 

 

Why We May Share Information With Third Parties.  We may share your information with third parties including our Affiliates and our Partners and their service providers. We may also share your information with our service providers who assist in providing the following UVO Services: 

  • Crash Notification Assistance. UVO Services may automatically connect you to certain service providers such as the police, fire department, or ambulance service in the event of an airbag deployment in your Vehicle and we will provide them with your location so they can find you and respond to your emergency. 
  • Roadside Assistance. We may provide roadside assistance providers with your location in the event you request roadside assistance so that the service provider may locate you and assist you with your issue. 
  • Content-Based Services. The location of your Vehicle is collected and used to provide content-based services such as navigation, maps, guidance, point-of-interest searches, and finding your closest charging station (for Kia electric vehicles), etc. 
  • My Car Zone Features: Curfew Alerts, Geo-Fence, & Speed Watch. 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 or your KOP Account or the UVO Services App, you can opt through the settings to use certain features available for your Vehicle through the My Car Zone such as the curfew alert, geo-fence and speed watch features. These features will collect information about the Vehicle’s location even if someone other than you is driving or occupying the Vehicle. For example, a parent who purchases a Vehicle for their child to use that includes this feature can set preferences and controls that will collect information about their child’s driving habits, such as when the Vehicle is being driven and whether the Vehicle is being driven beyond a pre-determined speed limit or boundary location. You understand that when you use any of these features, this Vehicle information may be stored and accessible on your KOP Account in the My Trips feature portion of UVO Services and you may also receive a detailed alert on your Device, depending on the UVO Services available.
  • 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 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 that includes this feature can set preferences and controls on their UVO Services Hardware, KOP Account or the UVO Services App that will collect information about the Vehicle's location, such as the roads the Vehicle has been driven on and  the locations the Vehicle has visited.  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. 
  • Location Sharing. When UVO Services are active in your Vehicle, your Vehicle’s location information may be sent to all persons/Devices that have been designated in your preferences via UVO Services. 
  • 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 may be disclosed to such third parties and the information you disclose will be subject to the 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 technologies, content, tools, Apps or ads through our UVO Services or link to them from our UVO Services.  This may include using third party tools such as Twitter, Google Maps, HERE 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 you should review their privacy policies prior to interacting with them.  For example, if you are utilizing the maps or navigation functionality available in your Vehicle through UVO Services, these services are provided through the incorporation of Maps APIs from Google, Inc. ("Google") or HERE Global B.V. ("HERE"), depending on the Vehicle. If your Vehicle has maps or navigation functionality from Google, you therefore acknowledge that Google's Privacy Policy (currently found at http://www.google.com/policies/privacy) applies to Google's collection and use of your information.  If your Vehicle has maps or navigation functionality from HERE, you therefore acknowledge that HERE's Privacy Policy (currently found at https://legal.here.com/en-gb/privacy) applies to HERE’s collection and use of your information.
  • Third Parties Providing Services on Our Behalf.  While UVO Services are provided by Kia, we 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, such as wireless service providers, telematics service providers, such as Cellco Partnership, d/b/a Verizon Wireless, underlying wireless carriers, suppliers, licensors, public safety answering points, emergency responders and other service providers (such as police, fire and ambulance), towing or other roadside assistance companies, automobile makers, distributors and dealers.  Additionally, we may use third party vendors to perform certain services on our behalf, such as hosting UVO Services, designing and/or operating 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 to carry out the services they are performing for you or for us. Third party analytics service providers may use technology to track a Device's interactions with UVO Services.  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 Adobe’s website at http://www.adobe.com/privacy/opt-out.html.  If 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.  
  • Administrative and Legal Reasons. We may also share your information to satisfy any applicable law, regulation, subpoenas, court orders, warrants, governmental requests, or legal process if in our good faith opinion such is required or permitted by law. We may also share your information with a third party performing audit, legal, operational, or other similar services for or on behalf of Kia. 
  • Affiliates and Business Transfer. We may share your information with our Affiliates.  We also reserve the right to disclose and transfer the information we collect: (i) to a subsequent owner, co-owner, or operator of the UVO Services or applicable databases; or (ii) in connection with the negotiation, planning, or completion of a corporate merger, consolidation, restructure, sale of substantially all of our shares or assets, or other corporate change. 

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.

4. Do UVO Services Contain Third Party Content and Links to Third Party Services?

UVO Services may contain content that is supplied by third parties, including our Partners. Those third parties may collect information about your use of UVO Services, and they may be able to track your online activities over time and across various websites. In addition, when you are using UVO Services you may be directed to other services that are operated by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, a link may take you away from a UVO Services page and onto a third party's website or application. These other websites and applications may send their own cookies to you, independently collect data, or solicit Personal Information. We encourage you to note when you leave UVO Services and to read the privacy policies of all third party websites or applications before submitting any Personal Information to third parties. 

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 Party 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 registration. Your KOP Account may allow you to review, correct, or update information that you have provided through UVO Services registration forms or otherwise and may allow you to review certain 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 the same changes in our active databases as soon as reasonably practicable. With respect to the UVO Services App, you can prospectively stop all collection of information through your mobile Device by uninstalling the application. You may use the standard uninstallation 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 Kia’s administrative purposes. You may opt-out from receiving or modify your e-mail marketing communications preferences 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 may contact us by calling (800) 333-4KIA (4542) or by writing us directly at Kia Motors America, Consumer Affairs Department, P.O. Box 52410, Irvine, CA 92619-2410. If you wish for UVO Services to stop collecting Vehicle Information, please contact your Vehicle technician who can determine whether your UVO Services is collecting such information and/or whether UVO Services Hardware can be deactivated or uninstalled from your Vehicle. California consumers have additional rights to learn about what Personal Information a business has collected, sold and disclosed about them, opportunities to opt-out of such sales, opportunities to request deletion of their Personal Information, and protection from discrimination for exercising their rights. These rights are more thoroughly discussed below in Section 12 ("Your California Privacy Rights").

7. Where Does Kia Process the Information?

UVO Services are operated from the United States and intended for users located in the United States. If you are located anywhere outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, processed in, and stored in 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. By using UVO Services or providing us with any information, you consent to this transfer, processing and storage of your information in the United States.

8. What About Information on Children and Minors?

We do not knowingly collect personal information from children younger than the age of thirteen (13) or minors under the age of sixteen (16). We will delete any personal information collected through the UVO Services if it is later determined that the information belongs to a minor younger than the age of sixteen (16). If you are a parent or guardian of a child under the age of sixteen (16) and believe he or she has disclosed personal information to us, please contact us at 1-800-333-4542. 

9. What About Security?

We incorporate commercially reasonable security procedures and practices to help protect and secure your Personal Information. However, no data transmission over the Internet, 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 that we collect, and you use UVO Services provide us with your information at your own risk.  

10. Data Retention, Deletion, or De-identification

Kia is committed to only retaining personal and Vehicle information for only the period of time in which retention 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 3 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. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy from time to time. Any changes will be effective immediately upon the posting of the updated Privacy Policy, or such later date as may be specified in the updated Privacy Policy. Under certain circumstances (for example, in connection with certain material changes), we may also elect to notify you of changes or updates to our Privacy Policy, such as posting a notice on the home page of our website or via a link or tab on the mobile applications. Therefore, you should review this Privacy Policy from time to time, and before using any of our Services. You are responsible for ensuring we have a deliverable email address for you, and for periodically monitoring and reviewing any updates to this policy. Your continued use of UVO Services after such amendments will be deemed your acknowledgement of these changes to this Privacy Policy. 

12. Your California Privacy Rights

The California Consumer Privacy Act ("CCPA") provides eligible California residents with specific rights with respect to our collection, retention, and use of Personal Information. This California Privacy Rights section supplements this Privacy Policy and applies solely to eligible residents of California as of January 1, 2020. Any terms not defined in this section have the same meaning as defined in the CCPA.

            (a) Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide certain information to you about our collection and use of your Personal Information over the past twelve (12) months.  Specifically, you have the right to request disclosure of the categories of Personal Information and specific pieces of Personal Information we have collected about you over the last 12 months. Upon the submission of a verifiable consumer request (see Exercising your California Privacy Rights, below), we will disclose to you: 

  1.  the categories of Personal Information we collected about you; 
  2.  the categories of sources from which Personal Information was collected; 
  3.  the business or commercial purpose for collecting Personal Information; 
  4.  the business or commercial purpose for disclosing or selling Personal Information; and 
  5.  the categories of third parties with whom we sold or disclosed Personal Information for a business purpose. 

We will also provide the specific pieces of Personal Information we collected about you, subject to certain exceptions under applicable law, if you also request access to such information.  

As discussed in our General Privacy Policy, if you have visited our websites, we may have collected information about you and the Device you used to engage with our websites, such as an IP address, device type, operating system, time of visit, and other similar information, as discussed above. Such information may not be stored with other personal information that identifies you (such as your name, postal address, email address, etc.), and we therefore may not be able to reasonably associate this device-level information with you. Thus, we may not be able to provide you with specific information, or delete specific information that we have collected that cannot be reasonably associated with you.  You may exercise your privacy rights for device-level data by engaging with the consent management platform displayed when you enter our website, or by using any AdChoices on our website, if applicable. You may also exercise rights related to advertising and analytics as discussed in Section 3.  

             (b) Right to Request Deletion of Personal Information

You also have the right to request that we delete Personal Information that we have collected and maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will conduct a reasonable search of our records in order to locate any Personal Information we have collected about you that is eligible for deletion, and delete such Personal Information. To the extent we have shared any Personal Information collected about you with service providers that is eligible for deletion, we will direct those service providers to delete that Personal Information as well. For the sake of clarity, however, Kia may not be able to comply entirely with your request to delete all of your Personal Information as set forth under the CCPA. For example, if you purchased, leased, or serviced a Kia Vehicle at a Partner’s dealership, we may need to keep records related to these types of transactions in order to, for instance, fulfill the terms of an applicable warranty or contact you about a product recall or other safety issue. Specifically, we are not required to delete any Personal Information we have collected about you that is necessary for us and our service provider(s) to: 

  1.  Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between Kia and you.
  2.  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3.  Debug to identify and repair errors that impair existing intended functionality.
  4.  Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  5.  Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6.  Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of  the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  7.  Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8.  Comply with a legal obligation, such as retaining records for a period of time as set out in local, state, or federal laws.
  9.  Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided your information.

Following a deletion request, any Personal Information about you that was not deleted from our systems due to the above exceptions will only be used for the purposes provided for by the applicable exceptions. Thus, all Personal Information about you that is not subject to a deletion exception will either be (1) permanently deleted on our existing systems (with the exception of archived or back-up systems maintained for emergency disaster recovery and business continuity purposes); (2) de-identified; or (3) aggregated so as to not be personal to you.

                (c) Right to Opt-Out of the Sale of Personal Information

If Kia sells or discloses personal information about you to third parties, you may have the right to opt-out and request that Kia not sell your Personal Information. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

Do Not Sell My Personal Information

Once you make a verified opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, if at a later time, you wish to allow us to sell your personal information to third parties, you must opt-in to such sharing, and may be do so by calling 800-333-4KIA (4542). If a transaction requires the sale or transmission of your personal information in order to complete the transaction, we will notify you and provide instructions on how you can opt-in.

 

            (d) Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by applicable law, we will not:

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  5. Exercising Your California Privacy Rights
  6. You do not need to create an account with us to exercise your CCPA rights. To exercise the CCPA rights described above, please submit a verifiable consumer request to us by either: 
  7. Visiting our online request portal
  8. Calling us at (800) 333-4KIA (4542)

Requests to exercise your rights under the CCPA require verification of your identity, and may be made only by you, your parent or guardian (if you are under 18 years of age), a person to whom you have given power of attorney pursuant to California Probate Code sections 4000 to 4465, or an authorized agent that is registered with the California Secretary of State. If a parent or guardian is submitting a request on behalf of a minor, the parent or guardian must submit proof that they are the parent or guardian of the subject consumer, and must verify the consumer's identity. A downloadable Notarized Letter of Parent or Guardian form is available in the online request portal, and may be uploaded for submission once completed and notarized. If someone with power of attorney is making a request on behalf of a consumer, they must verify the individual consumer's identity and submit documentation establishing the power of attorney, such as by uploading it onto the online request portal.  If an authorized agent is submitting a request on behalf of a consumer, they must verify the individual consumer’s identity, provide written permission from the consumer to submit the request on the consumer's behalf, and submit documentation establishing registration with the Secretary of State. Such documentation may be uploaded onto the online request portal. If Kia cannot verify that the requestor is authorized by the consumer to act on such consumer's behalf, Kia is not obligated to provide information or respond to the request.  If you have any questions about making a request on behalf of another consumer, please call us at 800-333-4KIA (4542).  

Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or that you are an authorized representative of such person. We will not respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. While we may ask for Personal Information to verify the requestor or consumer's identity when making a request, we will only use that Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.   Additionally, you may only make a verifiable consumer request for access twice within a 12-month period. 

            (f) Response Timing and Format

We will make our best effort to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Within ten (10) days of receiving the request, we will confirm receipt and provide information about our verification and processing of the request. Kia will maintain records of consumer requests made pursuant to the CCPA as well as our response to said requests for a period of at least twenty-four (24) months.

If you have an account with us, we may require you to take delivery of our written response through that account. If you do not have an account with us, we will deliver our written response electronically, though you may alternatively choose to receive delivery by mail.  The response will also explain the reasons we cannot comply with a request, if applicable.  Requests for the specific pieces of information that we have collected about you will be sent in a portable, readily useable format that you may transmit to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

            (g) Your Rights Under "Shine the Light"

In addition to your rights under the CCPA, California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their Personal Information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2018 will receive information about 2017 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to Consumer Affairs Department: P.O. Box 52410, Irvine CA 92619-2410. 

 

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