Maven Privacy Statement

Last Updated: February 7, 2018

 

The General Motors Family of Companies (including Maven Drive, LLC (“Maven”), General Motors of Canada Company (operating as Maven and OnStar in Canada), OnStar, LLC (“OnStar”), and affiliates) (collectively, "GM" or "we") provides this Privacy Statement to let you know how we may collect, use, and share your information when you use a Maven Vehicle (“Vehicle”) and Maven products, services, websites, infotainment systems, social media sites, and mobile applications (collectively, products and services).  This Privacy Statement applies to the products and services offered by Maven, but excludes products and services with separate privacy statements that do not incorporate this Privacy Statement. 

 

Key points about our information practices:

 

Collection

We may collect information about you and the Vehicle, such as name, address, driver’s license information, vehicle diagnostics, and vehicle location, through your use of our products or services, and others who provide information to us.  See below to learn more.

 

Use

We may use your information to improve the quality, safety, and security of our products and services, to develop new products and services, to maintain member relationships, to communicate with you, and for marketing and analytics (including targeted marketing).  See below to learn more.

 

Sharing

We may share your information to provide you with products and services, to improve the quality, safety, and security of products and services, to comply with or as permitted by applicable law, to respond to your requests, and to allow recipients to use for marketing or other purposes subject to your consent where required.  See below to learn more.

 

Vehicle Location

Vehicle location information, such as the global position system (GPS) location of the Vehicle that may be collected by Maven on an ongoing basis, including during your trip. This information permits us to better administer and improve Maven and prevent fraud and theft. With your consent, we may also use location information to provide you with customized marketing communications and advertisements. See below to learn more.

 

Choices

You have choices regarding how we use and share your information for marketing and other purposes. See below to learn more.

 

Your Obligations

If you use the Vehicle’s infotainment system during your reservation (for example, to input contacts, perform address look-ups, or save map addresses), you are responsible for deleting this information at the end of your reservation. If you do not delete this information, it may be accessible to future Maven customers in the Vehicle.

 

Cookies and Tracking

We may use cookies and similar technologies to help provide our products and services, understand and customize your preferences, and display relevant advertising.  See below to learn more.

 

Interest Based Advertising

We may work with third party advertising companies to collect information about your activity on Maven and non-GM websites and apps over time and across different devices in order to deliver more relevant advertising to you.

 

Third Party Products and Services 

In connection with our products and services, you may be offered the opportunity to use third party products and services that are not owned or controlled by GM and are governed by separate user terms and privacy statements.  See below to learn more.

 

Access and Update

You may access your online account to update your information or you may contact us to learn about how to do so.  See below to learn more.

 

 

 

Security measures

We maintain reasonable and adequate security controls to protect your information and require our service providers by contract to do the same.  See below to learn more.

 

Retention

We keep information for as long as necessary to provide our products and services, operate our business, and comply with legal obligations. See below to learn more.

 

Children's privacy

We do not target or knowingly collect any information from children under the age of majority. See below to learn more.

 

International Data Transfers

We maintain appropriate protections for cross-border transfers as required by law for international data transfers. See below to learn more.

 

Changes

We will notify you of any material changes by posting the updated version of this Privacy Statement and taking other steps as needed.  See below to learn more.

 

Contact Us

Please contact us by mail, email, or phone with any questions about our privacy practices or this Privacy Statement.  See below to learn more.

 

 

INFORMATION WE MAY COLLECT

 

We may collect the following information through your use of the products and services, and otherwise with your consent. We may also collect your information from licensees, affiliates, dealers, partners, service providers, and independent third party sources. The types of your information that we may collect include:

 


·        Information about you and your accounts with us: such as your name, address, telephone number, date of birth, driver’s license information, e-mail address, login information, enrollment and reservation information, demographic data, gender, password, PIN, emergency contact information, and billing information, like your credit card number, CVV code and expiration date.

 

·        Information about the Vehicle: such as license plate number, vehicle identification number (VIN), mileage, oil/battery status, fuel or charging history, electrical system function, gear status, ignition on/off; idle time; and diagnostic trouble codes.

 

 

·        Information about the use of the Vehicle, including operational and safety related information: such as GPS location, speed, air bag deployments, crash avoidance alerts, impact data, safety system status, braking and swerving/cornering events, event data recorder (EDR) data, seat belt settings, vehicle direction (heading), trip start/end time and date, camera image and sensor data, voice command information, stability control or anti-lock events, security/theft alerts, infotainment system and WiFi usage.

 

 

 

·        Information about your device and how you interact with our products and services, including apps and websites: such as IP address, browser type, device location, unique device  identifier, cookie data, associated identifying and usage information from your mobile phone, laptop, or other device, and other device information that you give us consent to access, such as your device location, device photographs, to personalize the Maven mobile app experience.

 

 

 

 

 


HOW WE MAY USE YOUR INFORMATION

 

We may use your information in order to:

 


·        provide our products and services

·        improve the quality, safety, and security of our products and services

·        develop new products and services, including autonomous vehicle and car-sharing products and services

·        maintain customer relationships and communicate with you

·        administer your account(s) and process your payments for products and services

·        operate our websites and applications, including online registration processes

·        provide customer and vehicle support and service (for example, recall information,  servicing and maintenance or warranty service)

·        provide product and service updates

·        evaluate the quality, safety, and security of our products and services

·        collect outstanding debts relating to products and services, and parking/ moving violations

·        assist in locating or recovering a Vehicle that is missing, reasonably identified as stolen, or being used in an unauthorized manner

·        for research, evaluation of use, and troubleshooting purposes

·        protect the safety of you or others

·        verify eligibility for incentive and discount programs; and to evaluate ongoing program and membership eligibility

·        perform marketing and analytics, including interest based marketing and advertising and targeted advertising (with necessary consents)

·        administer your participation in contests, quizzes, surveys, promotions and offers

·        customize and improve communication content and your experience with GM and our products and services, and

·        comply with legal, regulatory or contractual requirements


 

 

 

We may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please send an email to privacy@gm.com.

 

Where required, we will de-identify or anonymize your information in a way that it can't reasonably be associated with you or the Vehicle. We may use de-identified or anonymized information or share it with third parties for any legitimate business purpose.

 

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message and other electronic messages, through the in-vehicle OnStar system or via our websites and applications. Communications may contain information regarding products or services, events, special offers, promotions and contests offered by GM, its affiliates, partners and/or the originating dealer and may be tailored based on information we have about you.  GM may send you text messages using an automated telephone dialing system to the mobile phone number you have provided if you have opted in to receive text messages and message and standard data and message rates may apply.  See “Choices” below to learn how to manage your communication preferences.

 

How We May Share YOUR INFORMATION

 

We may share your information as follows for the uses described below (and where required we will obtain additional consent or de-identify/anonymize the information):  


 


GM Family of Companies:  Within the GM family of companies (for example, Maven, General Motors of Canada Company, General Motors Company, OnStar LLC and other affiliates) for the above purposes.

 

Emergency Service Providers:  With emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers, in order to deliver related services.  

 

Business Partners and Independent Third Parties:  With business partners, such as SiriusXM in connection with the satellite radio hardware installed on the Vehicle and the associated products and services provided by SiriusXM, research institutes,  for research and development purposes (for example, improving highway safety),  dealers, fleet or rental companies, for service maintenance of the Vehicle, and marketing activities. We may also share data with third parties where you have elected to receive a service from them and authorized them to request data from GM.

 

Service Providers:  With our product and service providers who work on our behalf in connection with the above uses, such as wireless service providers (e.g. AT&T), companies that perform eligibility services, such as identity verification to prevent theft and fraud, companies that administer our contests and promotions, host and/or operate our website, send communications, perform data analytics, credit card processors, or system providers necessary to process, store, or manage credit card information (we will not otherwise share your credit card information).

 

Where Required or Permitted by Law:  As required or permitted by applicable law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, to detect, investigate and prevent fraud, or to conduct screening to ensure you are not on any government list of restricted parties (which may include lawful access by US or other foreign courts, law enforcement or governmental agencies).

 

Business Transfers:  With a prospective or completed sale, transfer, or financing of a part of a GM business or its assets.


 

 

VEHICLE LOCATION

 

Vehicle location information, such as the global position system (GPS) location of the Vehicle that may be collected by Maven on an ongoing basis, including during your trip. This information permits us to better administer and improve Maven and prevent fraud and theft. With your consent, we may also use location information to provide you with customized marketing communications and advertisements.

 

Vehicle data collection, use, and sharing practices may be tied to the products and services we offer. To stop the collection, use, or sharing of information, you may have to decline those products and services or be willing to accept limited functionality.

 

 

your choices

 

You have certain choices regarding how we use and share your information.  For example, you can restrict our access to, as well as the collection and sharing of, the location of your mobile device by disabling location-sharing in the settings feature on your device.  However, some of the products and services require access to and collection of the location of your device (for example, we require your mobile device’s location to unlock, start and end your reservation and confirm that the Vehicle has been returned to the appropriate location).

 

You may contact us directly, as provided below, to indicate your contact preferences. We will also provide opt-out instructions in our marketing communication channels; for example, an Unsubscribe option will appear at the bottom of all marketing-related emails.

If you exercise choice regarding certain marketing communications, your information may still be used for the other purposes described in this Privacy Statement (for example, vehicle support and service), including marketing communications where you have not exercised choice, or communications we are required or permitted by law to send to you (for example, certain types of transactional or account-related messages).

For additional information on your choice, please contact us.  See “How To Contact Us” below.

 

YOUR OBLIGATIONS and removal of information from vehicle

 

If you use the Vehicle’s infotainment system during your reservation (for example, to input contacts, perform address look-ups, or save map addresses), you are responsible for deleting this information at the end of your reservation. If you do not delete this information, it may remain on the Vehicle’s system and may be accessible to other Vehicle occupants, such as future Maven customers.

 

Saved devices can be deleted through the phone settings menu in the radio, addresses can be deleted in the Personal Data settings in navigation or all private information can be cleared at once using the Clear Private Data function in the Factory Settings Menu. For instructions on how to delete information from the Vehicle, please refer to the Vehicle owner’s manual or contact us.  See “How To Contact Us” below.

 

Cookies and Other Tracking Technologies

 

Maven products and services use cookies, web beacons, pixels and other tracking technologies (“cookies) to gather information, such as browser type, IP address, pages visited, activities conducted on the page, and the day and time of your visit.  We use cookies to measure website activity, remember your preferences, maximize the performance of our website and services, and customize your experience (for example, maintaining your account login or contact information, help you locate a nearby dealer, autofill fields on forms). 

 

In accordance with applicable law, we may also combine this information with other information collected online or offline about you, including information provided by third party sources, and it may be used or shared for the purposes described in this Privacy Statement. 

 

Similarly, we may also place cookies in our emails to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email and any URL accessed through our email message.

 

Please also refer to your browser Help instructions to learn more about cookies and other technologies and how to manage their use. If you elect to refuse or delete cookies, you will need to repeat this process if you use another computer, or change browsers. If you choose to decline cookies, some of the functionality of a website may be impaired.

 

At this time, we do not honour website browsers' "do not track" signals.  However, you may refuse or delete cookies, and otherwise express your choices on marketing issues as described below.

 

inTerest-based advertising

 

We work with third party advertising networks and other advertising and personalization partners that use their own tracking technologies (including cookies and pixel tags) on gm and non-gm websites and apps in order to provide you with tailored advertisements on our behalf across the internet (including on social networking websites and apps). These companies may collect information about your activity over time and across your different devices on gm and non-gm websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites and apps.  This information may also be used to evaluate our online advertising campaigns or to tailor promotions or other marketing messages to you across your devices.

 

GM adheres to the Digital Advertising Alliance of Canada's Self-Regulatory Principles for Online Behavioral Advertising (www.youradchoices.ca).  If you do not wish to receive personalized advertising or content from participating third-party advertising companies while visiting GM web sites, you may click on the AdChoices icon located at the top of the web site page or visit the Digital Advertising Alliance of Canada’s opt-out page.  If you do not wish to receive personalized advertising or content from participating third-party advertising companies on non-GM websites, please visit the Digital Advertising Alliance of Canada’s Opt-Out page or click on the AdChoices icon on a GM advertisement and follow the instructions on how to opt out.  To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the Digital Advertising Alliance of Canada’s AppChoices tool, please download the version of AppChoices for your device at https://youradchoices.ca/appchoices/.

 

Opting out of relevant advertising will not opt you out of all advertising, but rather only those advertisements that are personalized to your interests by gm or its agents or representatives.

 

To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again.

 

 

Third Party Services, Applications AND WEBSITES

 

Certain third party services or applications (for example, your carrier data plan, navigation services) you download, that are pre-installed, or which you may sign up for may have separate user terms and privacy statements, which are independent of our Privacy Statement.  GM is not responsible for the personal information practices of these third party services or applications.  We recommend that you carefully review the user terms and privacy statement of each third party service or application prior to signing up, downloading, or using them.

 

Similarly, our websites may contain links to independent sites outside of and not controlled by GM, such as those belonging to GM dealers, GM licensees, or independent product review sites. GM is not responsible for these sites, their omissions, policies, or content of the websites or for the personal information practices of such third parties. We recommend that you read the privacy policies of these third parties before making a decision to use the site or provide your personal information to the site operators.

 

Access AND UPDATES to Your INFORMATION

 

You can access your online account to view or update your information in that account.  You may also contact us, as provided below, to learn about how to access, review, correct, update, or delete the information about you in our records.  We may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. 

 

 

How We Safeguard YOUR INFORMATION

 

We maintain reasonable and adequate technical, administrative, and physical security and confidentiality measures designed to help protect your information from unauthorized access or acquisition.  We also require by contract (other than in an emergency situations) that third party services providers acting on our behalf or with whom we share your information also undertake to provide such security and confidentiality measures in accordance with industry standards. 

 

How Long We Keep YOUR INFORMATION

 

We may keep the information we collect for as long as necessary to provide products or services to you, to operate our business, to enable us to communicate with you, for our safety, research, evaluation of use, or troubleshooting purposes, or to satisfy our legal or contractual obligations.  Where required, we will anonymize or dispose of the information we collect when we no longer need it for the uses described above.

 

Children's Privacy

 

GM does not target or knowingly collect any information from children under the age of majority.

 

international Data TransferS

 

We store your information in the United States, the European Economic Area (EEA), and other locations where we or our affiliates or our service providers maintain servers or otherwise process personal information.  We provide appropriate protections for cross-border transfers as required by law for international data transfers.  With respect to such transfers between Canada, the EEA and the United States and other non-EEA jurisdictions, we implement standard contractual clauses and other mechanisms to protect such data. Your information may be accessible by law enforcement, governmental agencies or courts in the country where the data is processed or stored pursuant to a lawful access request in accordance with the laws of that jurisdiction. You may contact us, as set out below, in order to receive information about our policies and practices with respect to service providers outside of Canada.

 

Changes to This Privacy Statement

 

We may need to update this Privacy Statement from time to time as our business and products or services expand or change, or as required to by law. If we do, we may post the updated version of the Privacy Statement on our website or app, or ask for your consent to the changes if legally required.

 

 

How to Contact Us

 

If you have concerns or questions regarding Maven’s consumer privacy practices (including the use of service providers located outside Canada) or this Privacy Statement, please press the blue button in the Vehicle, visit our website, or call us at 1-844-446-2836 (1-844-HIMAVEN).  You may also contact the Maven Privacy Manager by mail at P.O. Box 1027, Warren, Michigan USA 48090-1027 or by email at privacy@gm.com.