Last Modified: December 16^th 2024

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY STATEMENT, YOU SHOULD NOT USE OUR CV SERVICES. BY ACCESSING, DEPLOYING, ACTIVATING, OR USING OUR CV SERVICES, REGISTERING OR SUBMITTING YOUR INFORMATION THROUGH OUR CV SERVICES, OR OTHERWISE INTERACTING WITH US REGARDING THE CV SERVICES, YOU AGREE TO THE PRACTICES, TERMS, AND CONDITIONS DESCRIBED IN THIS PRIVACY STATEMENT. THIS PRIVACY STATEMENT MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF THE CV SERVICES AFTER WE MAKE CHANGES IS DEEMED ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THE PRIVACY STATEMENT PERIODICALLY FOR UPDATES.

CV SERVICES ARE INTENDED FOR USERS LOCATED IN THE UNITED STATES AND ARE NOT INTENDED FOR USERS LOCATED IN ANY OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.

1. INTRODUCTION

Mitsubishi Motors North America, Inc, ("MMNA", "we", “us”, or “our”) provides those who purchase certain models of Mitsubishi vehicles the ability to receive Connected Vehicle Services ("CV Services") via:

· The telematics device on your vehicle (the "Device"), which can record information about how you drive, vehicle maintenance data, and your location via GPS;

· The online MMNA Connected Vehicle Services website for customers (the "Owner Portal");

· The My MITSUBISHI CONNECT mobile application (the "Mobile App");

· The MMNA Connected Vehicle Services customer care center at (888) 564-1411 ("Customer Care"); and

· Dealership records provided to MMNA in connection with the CV Services.

This Privacy Statement (the “Privacy Statement”) explains how information about you is collected, used, and disclosed by MMNA with respect to the CV Services. This Privacy Statement does not apply to vehicles, products, mobile applications, or services that are unrelated to the CV Services as listed above. This Privacy Statement supplements our Privacy Policy, which is available at https://www.mitsubishicars.com/privacy, but where there is any conflict between this Privacy Statement and the Privacy Policy, the Privacy Statement Controls. To obtain an accessible copy of this Privacy Statement please contact us via the methods identified in the "Contact Us" section below.

For more information about the types of Services or Subscription Packages that are offered in connection with the CV Services, please review the MMNA Connected Vehicle Services website. Terms that are used but not defined in this Privacy Statement are defined in the MMNA Connected Vehicle Services Terms and Conditions, available at https://www.mitsubishicars.com/cvsterms. The terms "Location Services", "Parental Control Services", "Remote Services", "Safeguard Services", "Services", "Vehicle Data", and "Vehicle Data Collection" are defined in the Connected Vehicle Services Terms and Conditions.

2. DEFAULT VEHICLE DATA (AS DEFINED IN THE TERMS AND CONDITIONS, WHICH INCLUDES YOUR GEOLOCATION INFORMATION, ODOMETER VALUE, VEHICLE ERRORS AND OTHER VEHICLE-RELATED DATA) WILL BE COLLECTED, USED, DISCLOSED AND SHARED BY MMNA IN ACCORDANCE WITH THIS PRIVACY STATEMENT, THE CONNECTED VEHICLE SERVICES TERMS AND CONDITIONS, AND U.S. LAWS, RULES AND REGULATIONS, INCLUDING FOR MARKETING PURPOSES TO OFFER PRODUCTS AND OTHER SERVICES TO YOU. THIS DATA MAY START BEING COLLECTED IMMEDIATELY UPON YOUR PURCHASE OR LEASE OF YOUR VEHICLE FROM THE DEALER. YOU WERE NOTIFIED OF AND CONSENTED TO THIS COLLECTION, USE, DISCLOSURE AND SHARING AT YOUR TIME OF VEHICLE PURCHASE OR LEASE. THIS DATA MAY BE COLLECTED FROM YOUR VEHICLE, EVEN IF YOU DO NOT ACTIVATE THE SERVICES OR PURCHASE A SUBSCRIPTION SERVICES PACKAGE OR IF YOUR SUBSCRIPTION, TRIAL OR RENEWAL PERIOD HAS EXPIRED.

IF YOU DO NOT WANT THIS DATA TO BE COLLECTED, CONTACT CUSTOMER CARE TO DEACTIVATE YOUR VEHICLE'S TELEMATICS-ENABLING DEVICE AND REQUEST THAT THIS VEHICLE DATA COLLECTION BE STOPPED. UPON DEACTIVATION OF THE DEVICE, YOU WILL NO LONGER BE ABLE TO RECEIVE ANY SERVICES, AND ANY APPLICABLE SUBSCRIPTION SERVICE PACKAGE. ANY FREE "TRIAL" SUBSCRIPTION, PURSUANT TO WHICH YOU WERE RECEIVING THE SERVICES, WILL IMMEDIATELY TERMINATE.

It is your sole responsibility to tell your vehicle occupants and users about the CV Services, how they work, what data may be collected (e.g., collection of geolocation data), how that data may be shared, and what the limitations of the CV Services are (e.g., they may not work in remote areas). If you choose to activate features such as curfew, boundary or speed alerts, you have the obligation to explain that remote monitoring of the vehicle will be conducted using parameters that you set. You agree to make all vehicle occupants and users aware of this Privacy Statement and the privacy choices you have made.

If you sell, lease or otherwise transfer your vehicle directly to another person, it is your responsibility to notify such subsequent owner of the CV Services (including the Vehicle Data Collection and any other collection of data), this Privacy Statement, and the Connected Vehicle Services Terms and Conditions. In addition, prior to such transfer, you should delete all information (such as contacts and saved map addresses stored in the vehicle) from the vehicle and contact Customer Care to cancel your account. Any information you do not delete may be accessible to future users of the vehicle. Please refer to your Owner's Manual for instructions on how to delete information from your vehicle's system.

3. INFORMATION MMNA MAY COLLECT

Depending on how you use the CV Services, we may collect the following personal information from you, your vehicle, and/or your devices (collectively, "Collected Data") when you use the CV Services:

· Contact Information: Such as your name, email address, mailing address, and telephone number.

· Registration Information: Such as your username, email address, and/or password to login to an online account with us.

· Vehicle information: Such as make, model, year, condition, purchase and service dealerships, dates of ownership or lease, license plate and vehicle identification numbers, as well as Mileage (odometer information), diagnostic trouble codes, Device errors, oil status, vehicle CAN signals (signals transmitted to, from and across the various software modules contained in your vehicle), Vehicle speed, air bag deployments, vehicle status information (e.g., status of powered doors), vehicle settings, anti-lock events, information from your vehicle's event data recorder, and infotainment system usage.

· Government Issues Identifiers: Such as your driver’s license information, or other identification numbers issued by government bodies or agencies.

· Financial Information: Such as your billing information (e.g., last four digits of credit card number) and information about your acquisition and financing of the vehicle.

· Communications Data: Such as information you provide through our online web forms when you contact us with questions, feedback, surveys, engage with us for customer support or customer service-related requests, or otherwise choose to provide to us when you correspond with us online.

· Cookies and Similar Technologies: We use cookies, pixels, and similar technologies as described in the “Cookies and Similar Technologies” section of this Statement. If you choose to disable cookies and similar technologies, some areas and features of the CV Services may not work properly.

· Usage Data: Such as information about how you use our CV Services and interact with us, including information you provide when you use any interactive features of the CV Services, the URL that referred to you our CV Services, the areas within our CV Services that you viewed and your activities there, domain name, a date/time stamp, Internet service provider (ISP), operating system, IP address, clickstream data, and similar device and usage information.

· Geolocation Information: This may include the IP address or other location information transmitted by a mobile or other device (depending upon your settings) when you interact with the CV Services; Vehicle geolocation information (latitude and longitude at a particular point in time); Vehicle direction; and mobile device geolocation information.

· Device Information: Such as information that is automatically assigned to your devices used to access our CV Services, including IP address, unique device identifier, device type, browser type, location information, and other information about your browser. Mobile device type, mobile device operating system, type of browser, Internet service provider, screen view time, scrolling, specific actions to activate features and/or otherwise navigate the Mobile App, reactions to alerts, searches, and your interactions with in-application marketing offers. Browser type, usage transaction logs, internet service providers (ISP), referring/exit pages, operating systems, date/time stamps, your usage and activity on our Owner Portal (e.g., clickstream data), device type, log files, campaign engagement (e.g., clicking through campaign emails).

· Other information that you voluntarily share with us to facilitate your use of our CV Services which is not specifically listed here, such as Voice recordings of interactions with Customer Care and emergency personnel. We will use such data in accordance with this Privacy Statement, as otherwise disclosed at the time of collection, in accordance with our agreement, or to the extent necessary for performing the services.

We may also collect information about you from additional online and offline sources, including our affiliates, subsidiaries, and other third-party sources as permitted by law.

When you are asked to provide your information, you may choose not to provide us with your information or otherwise decline or use browser or device controls to prevent certain types of data collection. However, in some cases, if you choose not to provide information that is necessary, you may not be able to access portions of the CV Services or features may not be available or fully functional.

With your consent, we may also collect driving information, including motion and wellness program activity, trip information (e.g., trip start and end date and time), miles traveled, speed acceleration, deceleration, and braking data, road surface information, location and directional information, and mobile device usage information (e.g., whether the hands-free feature was used or texts were sent during a trip).

We have collected the personal information identified in this Privacy Statement from the following categories of sources:

Directly from you. For example, from forms you complete, applications you submit, or products or services you obtain from us.
Indirectly from you. For example, from lead generation companies or cookies.
Service Providers and Contractors. For example, credit reporting agencies or credit and verification providers.

Third parties in connection with financing your vehicle

Emergency service providers.
Unaffiliated third parties to provide select products and services to you.
Government entities or law enforcement agencies.

4. How MMNA May Use Your Information

We may use the information described above, including any personal information, in connection with the following business or commercial purposes or otherwise to the extent permitted by law:

· Providing Our Products and Services: We use your information to provide the CV Services, which includes, to present, maintain, support, and/or modify the CV Services, to perform our contractual obligations to our customers, monitor, measure, and report on vehicle and user engagement and CV Services usage, inform you of various features and the CV Services, including to encourage use of certain features, to communicate with you about the CV Services, communicate relevant messages based on pattern and usage of the CV Services, to facilitate, manage, and personalize your experience online or with the CV Services; or to otherwise provide you with the CV Services.

· Security and Fraud Prevention: We use your information for security and fraud prevention purposes, which includes to protect, investigate, mitigate, and deter against fraudulent, malicious, unauthorized, infringing, or illegal activity relating to the CV Services, or to monitor and ensure the safety and security of our premises, property, employees, customers, and visitors.

· Advertising and Marketing: We may use your information for marketing and advertising purposes, which includes direct marketing and promotional purposes, processing and delivering sweepstakes, contests, and promotions, posting ads through our third-party websites or mobile applications that may be of interest to you, contacting you with advertisements, promotions, other goods and services or offers that may be of interest to you (as permitted by law and consistent with any marketing preferences that we offer and you have registered with us) and to link or combine with personal information we get from third parties to help understand your needs and provide you with better service.

· Operating Our Business: We use your information to operate our business which includes to facilitate and service our business, including the creation of new products or services, conduct data analytics, surveys, research and analysis, benchmarking, maintain accounting records, analyze financial results, comply with internal audit requirements, managing risk, obtaining professional advice, to operate and improve our Owner Portal and other MMNA websites, and create Aggregated Data and developing industry and sector-wide reports, to better understand our customers, users of the CV Services, to comply with any contractual obligations, to comply with your instructions or requests, manage our relationships with you, improve our CV Services, and otherwise facilitate the operation of our CV Services.

· Communicating With You: We may use your information to communicate with you, such as to contact you directly by mail, telephone, email, SMS, or other electronic messaging service to in order to respond and provide the appropriate assistance to you; administer your account(s) and process your payments for products and services; provide customer and vehicle support and service (for example, recall information; servicing and maintenance or warranty service); to extend offers of goods and services or information that may be of interest to you; to keep records of our communications with you; to determine user interests; to solicit your feedback on the vehicle and the Services; for usage analytics purposes; provide information about our products and send you related information, including confirmations, brochures, technical notices, updates, security alerts and support and administrative messages; notify you of the closest Mitsubishi dealer; and to administer a promotion, sweepstakes, contest, survey, or other customer engagement features.

· Corporate Activities: We may use your personal information in connection with evaluating, conducting, or implementing a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
· Legal Requirements: We may use your information to satisfy legal requirements which includes to enforce our terms and conditions or protect our business or our customers, and to comply with our contractual and legal obligations, such as complying with national security or law enforcement requirements, discovery requests, or where otherwise required or permitted by applicable laws, court orders or regulatory authorities, or to establish, exercise, or defend legal claims, whether in court, administrative, or other proceedings, including disputing a claim or recovering a debt; and

· As otherwise set forth in this Privacy Statement, to fulfill the purpose or reason you provided the information, and/or with your consent such as when required by law.

5. How MMNA May Share Your Information:

We may disclose the personal information described above to the following types of third-parties:

Corporate Affiliates, which include, our subsidiaries, divisions, affiliates, and holding companies for various purposes permitted by law, including business purposes as well as the advertising and marketing of their products and services to you.
Service Providers, which include agents, contractors, consultants, service providers and other third parties we use to support our business and deliver products or services to you, and/or who perform functions on our behalf such as customer service, data analysis, servicing accounts, marketing, and/or development of our products and services. We may share with analytics and advertising technology companies. Vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see below. We may also share with other parties in connection with facilitating your request to finance your vehicle and to publicly post information on unaffiliated online services, or other parties or partners to provide you with discounts, coupons, and other promotions on MMNA and other party products and services.

We may also disclose the personal information we collect to our analytics vendors and partners, including social media companies such as Facebook, to develop aggregate analytics and business intelligence for our advertising and marketing purposes. For example, we use personal information to create custom audiences and measure the success of promotions.

When you watch videos while using our CV Services, you agree that we may disclose your video viewing to or obtain information about your video viewing from analytics service providers, advertising partners, and social media platforms.

Mitsubishi Dealers, in connection with the services we provide to them. For example, we share information with Mitsubishi Dealers when you request a price quote on a vehicle or trade-in appraisal, when you request a test drive for a vehicle, when you use the credit score estimator for purposes of facilitating the car buying process, and for vehicle servicing and the dealers' own marketing purposes
Acquisitions or Similar Transactions, which include to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.
With Your Consent or at Your Direction, which includes to third parties to market their products or services to you if you have consented to these disclosures or where you have consented to the disclosure of your information to other unaffiliated third parties who are not described elsewhere in this Privacy Statement.
In Response to Legal Process or Defending Legal Claims, which includes, as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the law and the reasonable requests of regulators, law enforcement, or other public authorities or quasi-government authorities, including fraud detection agencies. We may also disclose the information to establish, protect, or exercise our legal rights, to enforce our terms and conditions or other legal agreements, to defend against a legal claim, to detect, investigate, prevent, or take action against illegal activities or potential threats to the rights, property, or safety of any other person, or as required by law. To the maximum extent permitted by applicable law, we may also use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.
Professional Advisors, which includes our attorneys, accountants, tax advisors, investment advisors, and other fiduciaries or consultants that need access to your information to provide operational or other support on your behalf.
Third Parties: We may provide personal information about you to third parties that may offer services specifically requested by you, including without limitation, in connection with financing your vehicle, with emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers, in order to deliver the Services (including, for example, Stolen Vehicle Assistance services, as defined in the Connected Vehicle Services Terms and Conditions), with certain third parties to provide select products and services to you.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with our affiliates or other parties for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

6. RETENTION OF PERSONAL INFORMATION

We retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

We take reasonable steps to delete the personal information we collect when: (1) we have a legal obligation to do so; (2) we no longer have a purpose for retaining the information; or (3) if you ask us to delete your personal information unless we determine that doing so would violate our existing, legitimate, legal, regulatory, dispute resolution, contractual, or similar obligations. We may also delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.

7. SECURITY AND PROTECTION OF PERSONAL INFORMATION

We recognize the importance of safeguarding your personal information. We endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards designed to protect your personal information from accidental loss and unauthorized access, use, alteration, or disclosure. From time to time, we review our security procedures to consider appropriate new technologies and methods. We use reasonable security measures when transmitting personal information to customers in responding to requests under applicable data protection or privacy laws.

While our security measures seek to protect the personal information in our possession, no security system is perfect, and no data transmission is 100% secure. Although we do our best to protect your personal information, we cannot guarantee or warrant the security of your personal information transmitted when accessing our CV Services. The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of our CV Services, you are reasonable for keeping your password confidential. Do not share your password with anyone. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.

8. COOKIES AND SIMILAR TECHNOLOGIES

Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your device and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your device until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Other Similar Technologies

In addition to cookies, there are other automatic data collection and tracking technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, pixels are small images on a web page or in an email that collect information about your browser or device and can set cookies. Web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

What Cookies and Similar Technologies Do We Use and Why Do We Use Them?

We use certain cookies and similar technologies to operate the Owner Portal and Mobile App, to measure and track how you interact with the Owner Portal and Mobile App, to enable certain functions on the Owner Portal and Mobile App, to ensure the privacy and security of the Owner Portal and Mobile App, to enhance your experience, to understand the number of hits and range of devices and browsers used to view our Owner Portal and Mobile App, to develop usage analytics, to enhance your experience, to honor your preferences and settings and provide you with a more personal experience, to provide interest-based advertising and marketing, when applicable, and to otherwise tailor our communications to you.

After accessing our CV Services, you may see information about our services on unrelated websites. This may occur as a result of a placement of a cookie or other tracking technology from your past browsing. For example, our advertisers may display targeted advertisements when you visit third-party websites or social networks based on your previous interactions with our Owner Portal and Mobile App as tracked by cookies and similar technologies. This process also helps us understand the effectiveness of our content and marketing efforts.

Some of our service providers may use cookies or other methods to gather information regarding your use of the Owner Portal and Mobile App and may combine the information in these cookies with personal information about you that you may have provided or that they may have through permissible means. How and when a third party uses that tracking information depends on their privacy policy, which you should review.

The Owner Portal and Mobile App may use the following categories of cookies :

Essential: Essential cookies are necessary for basic features and functionality of the Owner Portal and Mobile App. Without these essential cookies, the Owner Portal and Mobile App will not perform property and we may not be able to provide you with certain services you have asked for, provide access to secure areas, and choices you have made for better functionality cannot be provided.

Functionality: Functionality cookies help us customize content on the Owner Portal and Mobile App based on your preferences. We use functionality cookies to remember choices you’ve made or information you’ve provided, such as your username or the region you are in. This allows us to tailor your experience on Owner Portal and Mobile App to your preferences. For example, authentication cookies are functionality cookies that are used for the duration of a session (or persistent, if you agree to the “remember me” function) to allow users to authenticate themselves on subsequent visits or gain access to authorized content across different parts of Owner Portal and Mobile App.

Analytics and Performance: We use analytics and performance cookies to collect information about how you use the Owner Portal and Mobile App, including which pages you go to most often and if users receive error messages from certain pages in order to help us fix technical issues or errors and highlight areas where we can improve the Owner Portal and Mobile App. We also use these cookies to detect the most searched for words in search engines that lead to the Owner Portal and Mobile App. You may also encounter third-party analytics and performance cookies on our Owner Portal and Mobile App which may gather browsing activity (such as information you have entered or choices you have made) across numerous websites that you visit and across numerous browsing sessions. These cookies also help improve how our Owner Portal and Mobile App function and perform, customizes your interaction with our Owner Portal and Mobile App, and helps provide more relevant messaging and marketing communications to you. We also use Google Analytics and other third-party analytics providers listed below to help measure how users interact with our Owner Portal and Mobile App content. These cookies “remember” what our users have done on previous pages and how they’ve interacted with the Owner Portal and Mobile App.

Advertising: Advertising cookies and other similar technologies are used by us to enable us to understand your interests and tailor marketing to you and your interests and provide you with a more personalized service. These cookies remember that you used our Owner Portal and Mobile App and we may share this information with third-parties, such as advertising platforms, so that we can show you relevant offers and direct personalized advertising to you. We may also use these cookies to target and re-target users of our Owner Portal and Mobile App with digital advertising that is most relevant to the user. These cookies are also used to limit the number of times you see an advertisement or particular content, as well as help measure the effectiveness of an advertising or marketing campaign.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can read more about how companies use cookies to conduct targeted or retargeted advertising, and ways to opt-out of receiving targeted ads from members of the National Advertising Initiative (“NAI”) on its website at: www.networkadvertising.org.

The Owner Portal and Mobile App may also use particular third-party cookies or tracking technologies including, but not limited to, the following:

Google Analytics: We may use Google Analytics to collect and process statistical data about the number of people using the Owner Portal and Mobile App and to better understand how they find and use the Owner Portal and Mobile App. The cookie installed by Google Analytics calculates visitor, session, and campaign data and also keeps track of usage for the Owner Portal and Mobile App analytics report. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. Any data collected by is used in accordance with this Policy and Google’s Privacy Policy. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy. You can learn more about Google’s advertising services by visiting its Technologies page along with information on Google Analytics.

You can opt-out of Google’s use of cookies or device identifiers by visiting Google’s Ads Settings. You can also opt-out of Google Analytics, by installing the Google Analytics Opt-out Browser Add-on feature. For more details, visit the Google Analytics Opt-out Browser Add-on page.

Google Tag Manager. We may use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal information under certain circumstances. Google Tag Manager does not access this information Google Tag Manager is subject to the Google Privacy Policy located at: https://www.google.com/intl/en/policies/privacy.

Meta Pixel. We may use Meta Pixel to customize and display advertisements only to Facebook users who have shown an interest in our Owner Portal and Mobile App or who have specific characteristics (e.g., certain demographics or interests in certain topics or products determined by websites visited) that we submit to Facebook. The use of Meta Pixel helps ensure that our advertisements are in line with the potential interests of users and do not have a nuisance effect. Meta Pixel also allows us to track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether uses have been redirected to our Owner Portal and Mobile App after clicking on a Facebook advertisement. Meta Pixel is directly integrated into our Owner Portal and Mobile App by Facebook and can store a cookie on your device. The information collected about you is anonymous for us. However, the information collected via the Meta Pixel, on the Owner Portal and Mobile App as well as other websites on which Meta Pixel is installed, is also stored and processed by Meta. Meta may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy.

To understand more about Facebook advertising please visit:

https://www.facebook.com/about/ads.

You may deactivate Meta Pixel via the Cookie Settings on Facebook. The Settings are located at the bottom of the main page for logged in users at:

https://www.facebook.com/settings/?tab=ads#.

LinkedIn: Our Owner Portal and Mobile App may also have cookies set by LinkedIn which are used to connect data from LinkedIn with actions performed on the Owner Portal and Mobile App, to identify a browser ID, facilitate data center selection, and a visitor’s consent regarding using cookies for non-essential purposes. These cookies enable LinkedIn to display ads on LinkedIn to those LinkedIn users who have used our Owner Portal and Mobile App. If you are logged into LinkedIn with your user account, the fact that you used our Owner Portal and Mobile App is recorded in your user account. We have no control over the scope and further use of data collected by LinkedIn. Please see LinkedIn’s Privacy Policy for more information on how they may use the data collected from our Owner Portal and Mobile App.

If you are a LinkedIn member, you may manage your preferences, including opting-out of LinkedIn and its partners tracking visits to LinkedIn for targeted advertising by going to LinkedIn’s Ads Settings page. If you are not a LinkedIn member, you can opt-out of the tracking of these visits for targeted advertising purposes through LinkedIn’s Retargeting Opt-Out page.

-CrUX Dataset: The Chrome User Experience Report (also known as the Chrome UX Report, or CrUX for short) is a dataset that reflects how real-world Chrome users experience popular destinations on the web. CrUX data is collected from real browsers around the world, based on certain browser options which determine user eligibility. A set of dimensions and metrics are collected which allow site owners to determine how users experience their sites.

How Do Our Advertising and Marketing Partners Use Cookies for Interest-Based Advertising?

We may allow other parties to use cookies, web beacons, pixels, embedded scripts and other tracking technologies to automatically collect information about your use of our Owner Portal and Mobile App, including your IP address, web browser, pages viewed, time spent on pages, links clicked, conversion information, and other device information. We may also engage other parties to serve advertisements on our behalf across the Internet and to provide analytics about the use of our Owner Portal and Mobile App. This information may be used by us and others, among other things, to analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and to better understand the usage and visitation of our Owner Portal and Mobile App and other sites tracked by these other parties. These and other parties may collect information about your online activities over time and across different websites when you use our Owner Portal and Mobile App.

We serve ads on and through another party’s services, such as Facebook and Google, that are targeted to reach people, or people similar to people, who have used our Owner Portal and Mobile App or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the other party’s service or incorporating a pixel from the other party’s service on our Owner Portal and Mobile App, and the other party’s service matching common factors between our data and their data.

We may use third parties such as advertising networks and other content providers to serve targeted ads on our Owner Portal and Mobile Apps and on other websites like social media sites (e.g. LinkedIn). This practice is referred to as interest-based advertising. These advertising networks and/or content providers may use cookies and similar tracking technologies such as pixels to uniquely distinguish you, your web browser, or your device and report certain information about your visits to our Owner Portal and Mobile App and other websites (e.g., web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off the Owner Portal and Mobile App and across your devices, including on social media sites. This information may also be used to evaluate our online advertising campaigns.

Some third parties may use data collection technologies to collect information from our Owner Portal and Mobile App and combine it with other information they have collected relating to your web browser’s activities across their network of websites, where permitted. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

This Privacy Statement does not apply to, and we are not responsible for, other party’s cookies or other tracking technologies. We encourage you to check the privacy policies of advertisers and/or ad services to learn more about their privacy practices.

How Can You Opt-Out from Interest-Based Advertising?

Some advertising networks we may use for these purposes may be members of the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). Please visit the websites below to learn more about interest-based advertising and to opt out of receiving personalized advertising or content from participating third-party advertising companies:

Digital Advertising Alliance: https://optout.aboutads.info/?lang=EN&c=2#!%2F

National Advertising Initiative: https://optout.networkadvertising.org/?c=1#!%2F

Please note that if you opt-out, you may still receive online advertising from us, but it will not be tailored to your interests based on online behavioral information about you. To successfully opt-out, you must have cookies enabled in your web browser (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 computer you use. Once you opt-out, if you delete your browser’s saved cookies, you will need to opt-out again.

Choices About Cookies

We provide you with choices regarding the personal information you provide us and have created ways to give you control over our use of your information. You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our site may no longer be fully accessible.

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies you may set your browser controls to refuse all or some types of cookies, or to alert you when cookies are being sent by website tracking technologies and advertising. When a user visits our Owner Portal and Mobile App , the Owner Portal and Mobile App will prompt the user to confirm whether he or she approves of the use of a cookie. You may adjust your browser settings to opt-out of accepting a “persistent” cookie and to only accept “session” cookies, but will need to log in each time you want to enjoy the full functionality of the Owner Portal and Mobile App. You may also adjust your cookie preferences by using the cookies consent banner, if available.

Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browser providers. Please note these third-party links are provided for your convenience and we may not actively monitor the content of these links:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari & iOS: http://help.apple.com/safari/mac/8.0/#/sfri11471 and

https://support.apple.com/en-us/HT201265

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-inmicrosoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

9. CHATBOT TECHNOLOGY

We may use chatbots to help provide customer service and support, including through the use of a virtual assistant. A chatbot is a software application that mimics human conversations in text or voice interactions on our Owner Portal and Mobile App. It enables the communication between a human and a machine, which can take the form of messages or voice commands. The chatbot is designed to work without the assistance of a human operator. It responds to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts and machine learning algorithms. While the chatbot aims to offer accurate and helpful responses, its information may not always be exhaustive, up-to-date, or tailored to individual circumstances. If you use our chatbot service, we will collect any personal information you provide to us. We will also create and store a transcript of your chat interaction with us which will be shared and stored with our third-party service provider. We use these transcripts for quality control, customer service, fraud prevention, and security. We do not assume any liability for actions taken based on the chatbot’s responses. By using our Owner Portal and Mobile App and our chatbot, you acknowledge and agree to these terms.

10. VISUAL MATERIALS AND CONSENT TO COLLECT, USE, AND DISCLOSE VIDEO VIEWING HISTORY

The Owner Portal and Mobile App may display live or prerecorded videos or similar audio-visual materials (“Videos”). We are not in the business of delivering audiovisual materials. Rather, the display and use of Videos on the Owner Portal and Mobile App is incidental to our business and merely a peripheral part of our marketing strategy. The provision of Videos on our Owner Portal and Mobile App is not an admission by us and it shall not otherwise be interpreted, in any form or manner, to mean that we are a “video tape service provider” for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the “VPPA”) or that we are otherwise subject to the VPPA.

We may collect personal information with respect to you viewing, streaming, or otherwise accessing such Videos and we may disclose such personal information regarding your video-viewing history on the Owner Portal and Mobile App to third parties through the use of cookies, pixels, or other tracking technologies, such as Facebook, to facilitate or assist with our marketing and advertising campaigns. Such personal information may include: (i) identifiers that can be used to recognize you or the device you use to access our Owner Portal and Mobile App over time and across different services, such as a device identifier, an IP address, mobile ad identifiers, and similar data; (ii) the Video(s) you viewed, streamed, or otherwise accessed, including the nature, scope, and duration of such access and (iii) identifiers associated with your social media account, or similar online accounts.

By viewing, streaming, or otherwise accessing Videos on the Owner Portal and Mobile App, you hereby acknowledge, agree, and consent to our collection, use, and disclosure of such personal information regarding your video-viewing history on the Owner Portal and Mobile App

Withdrawal of Consent. You acknowledge and agree that you may prevent us from collecting and disclosing personal information from you with respect to you viewing, streaming, or otherwise accessing Videos on our Owner Portal and Mobile App: (i) by changing your browser settings in accordance with the instructions set forth in our Privacy Statement or (ii) by adjusting your privacy settings in our cookie management tool. These options will prevent the deployment of cookies and similar online tracking technologies that are used to collect, process, and disclose your personal information in connection with the Videos.

11. YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION

Please use the “Contact Us” details provided at the end of this Privacy Statement to exercise your rights and choices under this Privacy Statement. We honor such requests when we are required to do so under applicable law. Please be aware that if you disable or remove these technologies some parts of the Owner Portal and Mobile App may not work and that when you revisit the Owner Portal and Mobile App your ability to limit tracking technologies is subject to your browser and device settings and limitations.

Email Opt-Out: If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at the “Contact Us” information at the end of this Statement and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Online Tracking Signals: We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. Like many websites and online services, MMNA currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser and will continue this practice unless and until the law is interpreted to require us to do so. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Cookies: You may be able to set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Browsers offer different functionalities and options so you may need to set them separately. You may also adjust your cookie preferences by using the cookies consent banner, if available. Please note that disabling or removing cookies may not limit collection through other types of tracking technologies.

Accuracy and Updating Your Information: Our goal is to keep your information accurate, current, and complete. If you have an account with MMNA, you may review and update certain information in that account by logging into your online account or sending an email to privacy@mitsubishicars.com. We may require additional information from you to allow us to confirm your identity. You may also use the “Contact Us” details at the end of this Privacy Statement to correct or update any personal information that you have provided to us. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We are not responsible for any losses arising from inaccurate, inauthentic, deficient, or incomplete personal information that you provide to us. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

App: You can stop all collection of information via an app by uninstalling the app. You can also reset your device AD Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Promotional Texts: You may opt out of receiving promotional SMS messages from MMNA at any time by visiting:

https://owners.mitsubishicars.com/s/communication-preferences and changing your communication preferences. To opt out of SMS messages, you can also text STOP in response to any SMS messages you receive from MMNA.

You may also request changes to your contact preferences by writing to:

Mitsubishi Motors North America, Inc.

Customer Relations Department

PO Box 689040

Franklin, TN 37068

Matched Ads: To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will request that the applicable technology service not serve you Matched Ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out. We are not responsible for the effectiveness of, or compliance with, any other parties’ opt out options or programs or the accuracy of their statements regarding their programs.

RoadAssist+: Your rights and choices regarding personal information used by the Road Assist+ app are set forth in the Licensed Product End User License Agreement that LexisNexis Risk Solutions Inc. (“LexisNexis”) provides with the app. You can review LexisNexis’ agreement with you in the Road Assist+ app, or contact LexisNexis directly at 888-530-2769 for further assistance.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Statement.

12. U.S. STATE-SPECIFIC PRIVACY RIGHTS

To the extent you are a resident of certain U.S. states with comprehensive state privacy laws, such as Colorado, Connecticut, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Nevada, Oregon, Tennessee, Texas, Utah, or Virginia, you may be eligible for one or more of the following consumer rights where authorized by applicable U.S. state privacy laws. This section provides an overview of these rights (note that some U.S. state privacy laws use different terminology) which we honor where required by applicable law. If you are a U.S. resident from whom we collect personal information as a controller, you may have certain rights under an applicable such state privacy law. California residents may review our California Notice at Collection and Privacy Disclosures, below.

· Right to Access. Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to know and see what personal information we have collected about you and receive a copy of such information in a portable format, purposes for which we collect your personal information, recipients of your personal information to whom we disclose or share, which in some states may include categories of personal information collected, categories of sources of collection, business or commercial purposes for data processing, and categories of 3^rd parties with whom we disclose that information.

· Right to Correct. Subject to certain conditions and exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal information that we have collected about you.

· Right to Delete. Subject to certain conditions and exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we delete the personal information we have collected about you.

· Right to Opt-Out. Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to opt out of targeted advertising, profiling, the sale or sharing of your personal information, to the extent such instances occur (as defined under applicable state laws). We do not have actual knowledge that we sell personal information of minors under 16 years of age.

· Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of your rights under any applicable U.S. state privacy laws.

· Right to Appeal. To the extent the applicable U.S. state privacy laws provide such rights, you may appeal our denial to act on your consumer rights under the applicable state privacy laws within a reasonable time. We will respond within designated period for responding to U.S. data subject requests and may exercise the right to extend this response period (to the extent authorized by applicable state privacy laws). If your jurisdiction allows you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request, you may do so by using the following links as may be applicable to you. You may submit a complaint to the Attorney General’s Office by selecting the appropriate link: Virginia (www.oag.state.va.us/consumer-protection/index.php/file-a-complaint), Colorado (coag.gov/file-complaint), Connecticut (portal.ct.gov/AG/Common/Complaint-Form-Landing-page), and Texas (https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint).

· Right to Limit Use and Disclosure of Sensitive Personal Information. If any U.S. state privacy laws classify your personal information we collect as “sensitive personal information,” we use such data reasonably necessary to provide and perform our Services as requested by you or as otherwise permitted by law.

If you have questions or concerns regarding this Section or would like to exercise your consumer rights (to the extent available under applicable U.S. state privacy laws), please use the “Contact Us” details at the end of this Privacy Statement.

Sales and Targeted Advertising. We may use your personal information in a way that is considered a “sale” under the state laws applicable to you and may disclose your personal information—including personal identifiers, records, demographic information, customer account details and commercial information, internet or other electronic network activity information, and geolocation data—for targeted advertising purposes. You have the right to opt out of both practices.

As described herein, we may sell or disclose the categories of Personal Data listed above to third parties, including: joint marketing partners and authorized dealers, advertising and digital analytics companies, and social media platforms.

13. LINKS TO THIRD-PARTY WEBSITES

This Privacy Statement does not apply to any third-party websites or applications.

Our Owner Portal and Mobile App may contain links to websites or mobile applications operated and maintained by third parties. These links are to external websites and third parties that have their own privacy policies. If you follow any links that direct you away from the Owner Portal and Mobile App, including links to social media sites or to other websites, this Privacy Statement will not apply to your activity on the other sites you visit. Because of the dynamic media capabilities of the Owner Portal and Mobile App, it may not be clear to you which links are to our Owner Portal and Mobile App and which are to external, third-party websites. If you click on an embedded third-party link, you will be redirected away from the Owner Portal and Mobile App to the external third-party website. You can check the URL to confirm that you have left the Owner Portal and Mobile App.

We cannot (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control the privacy policies or the privacy practices of any third parties regarding their independent collection or use or your personal information, or (iii) endorse any third-party information, products, services or websites that may be reached through embedded links on the Owner Portal and Mobile App.

Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

14. CHILDREN’S PRIVACY

Our Owner Portal and Mobile App are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Owner Portal and Mobile App. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Owner Portal and Mobile App or on or through any of its features/register on the Owner Portal and Mobile App, make any purchases through the Owner Portal and Mobile App, use any of the interactive or public comment features of the Owner Portal and Mobile App or provide any information about yourself to us. If we learn that we have collected personal information from any person under the age of 18 without verification of parental or guardian consent, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and believe your child has provided us with personal information, please contact us via the instructions at the “Contact Us” section below.

15. UPDATES TO THIS PRIVACY STATEMENT

We reserve the right to add to, change, update, or modify this Privacy Statement at any time to reflect any changes to how we treat your information or in response to changes in law. In the event we make changes to this Privacy Statement, such policy will be re-posted on this page. If we make material changes to how we treat your personal information, we may notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home page of our Owner Portal and Mobile App. The date the Privacy Statement was last revised is identified at the top of the page. All changes are effective on the date listed at the top of this page and will apply to all information we have about you.

You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Owner Portal and Mobile App and this Privacy Statement to check for any changes. Your continued use of the Owner Portal and Mobile App and our services after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your personal information according to the terms of the then-current Privacy Statement. If at any point you do not agree to any portion of this Privacy Statement, then you should immediately stop using the Owner Portal and Mobile App.

16. PUBLIC INFORMATION

Certain parts of the technology offerings are designed to help you share information with the world. If you make information public through our Owner Portal and Mobile App or other technologies, other people will have access to it. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information.

17. ROADASSIST+

We have partnered with LexisNexis Risk Solutions Inc. (“LexisNexis”) to bring you the Road Assist + app. The primary purpose of the app is to allow you to request roadside assistance for your vehicle. If you request roadside assistance, the app may share information about you, including your precise location data, with other parties to provide you with the roadside assistance.

The Road Assist+ app integrates with the LexisNexis Telematics program. When you first register through the app, you will be enrolled in the LexisNexis Telematics program.

You will also be automatically opted in to trip recording and given the opportunity to opt in to the public leaderboard. You can opt out of trip recording or the public leaderboard at any time through your app account settings.

Trip recording collects your driving information through your mobile device and analyzes that information to allow you to achieve scores and badges, and level up within the app. For example, if you drive a certain number of miles within a set period of time, you may receive a badge. Once you collect enough badges, you will level up within the app. Your driver score and profile leaderboard alias name will be publicly displayed to other registered users of the Road Assist+ app so please do not provide information or images that you would not want to be public, or make sure to opt out of the public leaderboard through your app account settings.

Your driver score, badges, and levels may qualify you to receive certain discounts, coupons, and other promotions on MMNA and other party's products and services. Your information may be shared with other parties in order to provide you with these promotions, and such promotions may be delivered to you by email or through the app. Additional terms may apply. If you do not want to receive promotions, please opt out of trip recording through your app account settings and unsubscribe from any promotional emails you receive. In addition, if you use trip recording, information about your driving data will be visible to all drivers on your insurance policy who are enrolled in the LexisNexis Telematics program and may be disclosed to the parents or guardians of those drivers who are minors.

When you first register through the Road Assist+ app, you will also have the option to receive insurance quotes. If you agree to this option, you give LexisNexis authorization to share your information with various insurance agents, insurance companies, and related parties (“Insurance Providers”). The Insurance Providers may obtain consumer reports about you from a consumer credit reporting agency and use the information and consumer reports to determine your eligibility for insurance and provide you with quotes. Those reports may include information concerning character, general reputation, personal characteristics, mode of living and driving record. The Insurance Providers may provide your information to their vendors, suppliers and insurance carriers in order to generate price and other information relevant to insurance policies, and the Insurance Providers may use the information to contact you directly including by the phone number you provide if you select that option regarding insurance products. You can revoke your authorization for insurance quotes at any time through your app account settings. Any revocation is prospective, and you may still receive insurance quotes related to data already shared.

We are not responsible for the privacy practices of LexisNexis, the Insurance Providers, or any other parties, and you should review their privacy policies and notices. LexisNexis’ privacy policy is available at https://telematics.lexisnexis.com/privacy.html and its end user license agreement is available at https://telematics.lexisnexis.com/eula.html. For further information on your rights and choices regarding the Road Assist+ app, please see the section entitled “Your Rights and Choices” here in.

18. SWEEPSTAKES, CONTESTS, PROMOTIONS, AND SURVEYS

We may offer you the opportunity to participate in Promotions that may require you to submit information. Participation in these Promotions is completely voluntary. If you choose to enter a Promotion, your information may be disclosed to other parties in connection with the administration of such Promotion, such as in connection with winner selection, prize fulfilment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. MMNA may offer opportunities to enter a Promotion or other feature that we offer jointly with another party. As a result of your participation in such feature, your information may be shared with the other party that is jointly offering the feature, which will be disclosed at the time your information is collected.

19. SOCIAL FEATURES

Certain functionality on the Owner Portal and Mobile App is specifically designed to permit interactions that you initiate between the Owner Portal and Mobile App and unaffiliated websites or services, including social networks (“Social Features”). Examples of Social Features include to “like” or “share” our Owner Portal and Mobile App’s content to other websites or services; and to otherwise connect our Owner Portal and Mobile App to an unaffiliated website or service.

If you choose to use Social Features, information you post or provide access to may be publicly displayed on our Owner Portal and Mobile App or by the provider of the Social Feature that you use. Similarly, if you post information on another party’s platform that references our Owner Portal and Mobile App (e.g., by using a hashtag associated with MMNA in a tweet or status update), your post may be published on our Owner Portal and Mobile App in accordance with the terms of the other party’s website or service. Also, both MMNA and the other party may have access to certain information about you and your use of our Owner Portal and Mobile App and the unaffiliated site or service.

20. CONSENT TO TRANSFER INFORMATION

The Owner Portal and Mobile App are operated in the United States. If you are located outside of the United States, and are accessing or using the Owner Portal and Mobile App, please be aware that information we collect will be collected, processed, and stored in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. By using or accessing the CV Services or providing us with any information through the CV Services , you consent to this transfer, processing and storage of your information in United States and other jurisdictions.

21. CONTACT US

If you have any questions or concerns about this Privacy Statement or our data practices, please contact MMNA:

By email: privacy@mitsubishicars.com.

By mail:

Mitsubishi Motors North America, Inc.

Customer Relations Department

PO Box 689040

Franklin, TN 37068

By phone: 1-888-MITSU2024 (1-888-648-7820)

If you have a disability and would like to access this Privacy Statement in an alternative format, please email us at privacy@mitsubishicars.com.

22. NEVADA RESIDENTS.

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacy@mitsubishicars.com.

23. CALIFORNIA RESIDENTS.

These additional disclosures for California residents (“California CVS Privacy Statement”) supplement the information contained in MMNA’s Connective Vehicle Services Terms of Use and Connected Vehicle Services Privacy Statement and discusses our collection and use of “personal information”, as defined under the CCPA (as defined below). This California CVS Privacy Statement applies solely to all visitors, users, and others who reside in the State of California that use or interact with our Owner Portal and Mobile App (“consumers” or “you”).

MMNA adopted this California CVS Privacy Statement to comply with applicable California data privacy and protection laws and regulations, including the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”), and any implementing regulations adopted by the California Privacy Protection Agency (collectively referred to as the “CCPA”). Capitalized terms not defined herein shall have the same meaning as the CCPA when used in this California CVS Privacy Statement. “Personal Information” in both capitalized and lower-case form shall have the same meaning as “personal information” ascribed to it under the CCPA.

Notice of Collection

Data Categories Collected by Us

We currently collect the following categories of personal information listed in the chart below:

Category of Personal Information	Description	Collected (Yes/No)
Identifiers	Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, or other similar identifiers.	Yes
Personal information described in Cal. Civ. Code § 1798.80(e)	Examples: A name, signature, Social Security number, address, telephone number, employment, employment history, bank account number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law	Examples: Age (40 years or older), gender, race, ethnicity or national origin, marital status, or veteran or military status.	Yes
Commercial Information	Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information	Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
Internet or other similar network activity	Examples: Browsing history, search history, information on a consumer's interaction with our website, application, or advertisement.	Yes
Geolocation data	Examples: Physical location or movements.	Yes
Sensory data	Examples: Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional or employment-related information	Examples: Current or past job history.	Yes
Non-public education information	Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes
Inferences	Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes
Sensitive Personal Information	Examples: Social Security number, driver’s license number, state identification number, passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation information; racial or ethnic origin, religious, or philosophical believes, or union membership; contents of mail, email, and text messages unless the business is the intended recipient of the communication. **We only collect Sensitive Personal Information for legitimate business purposes appropriate for the use and disclosure of Sensitive Personal Information as defined in the CCPA, and not otherwise use it to infer characteristics about you.	Yes**

For more detail on information we collect, including the sources we receive information from, review the "Information MMNA May Collect" section. We collect and use these categories of personal information for the business purposes described in the "How MMNA May Use Your Information" section, including:

To fulfill or meet the reason for which the information is provided;
To provide you with information, products or services that you request from us directly or indirectly;
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
To provide customer service, maintain and servicing accounts, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on behalf of the business;
To improve our website and application, and present its contents to you;
To establish and maintain your user account with us;
To authenticate you;
For short-term, transient use including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business
To detect fraud and prevent loss, or as necessary or appropriate to protect the rights, property, or safety of us, our users and customers, or others;
To audit related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
To debug to identify and repair errors that impair existing intended functionality;
To allow you to contact us and facilitate your communication with us;
To respond to your feedback, requests, questions, or inquiries;
To provide offers to eligible users or customers;
To provide advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.
To provide the CV Services, the Services, and support to you;
To monitor, measure, and report on vehicle and user engagement and CV Services usage;
To communicate relevant messages based on pattern and usage of the CV Services;
To inform you of various features and the CV Services, including to encourage use of certain features;
To facilitate, manage, and personalize your experience online or with the CV Services;
To operate and improve our Owner Portal, Mobile App and other MMNA websites, applications, marketing efforts, products and services;
To provide information about our products and send you related information, including confirmations, brochures, technical notices, updates, security alerts and support and administrative messages;
To notify you of the closest Mitsubishi dealer;
To process and deliver sweepstakes, contests and promotions;
To monitor and analyze trends, usage and activities;
To develop new products and services, including autonomous vehicle and car-sharing products and services;
To administer your account(s) and process your payments for products and services;
To provide customer and vehicle support and service (for example, recall information, servicing and maintenance or warranty service);
To verify eligibility for vehicle purchase or incentive programs;
To generate analytics to improve the Owner Portal and Mobile App and the user experience;
To link or combine with personal information we get from third parties to help understand your needs and provide you with better service;
To send you surveys regarding your satisfaction with customer service agents and our services;
To conduct research and analysis, including focus groups and surveys, on the Owner Portal and other MMNA websites, applications, products and services; and
To prevent fraudulent transactions and monitor against threats.
As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Other Processing Activities: As permitted by applicable law, we may use all of the personal information that we collect in order to:

Comply with federal, state, or local laws;
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
Cooperate with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violated federal, state, or local law;
Cooperate with a government agency request for emergency access to a consumer’s personal information if a natural person is at risk or danger of death or serious physical injury;
Exercise or defend legal claims; and
Collect, use, retain, sell, or disclose consumer information that is deidentified or aggregate consumer information.

To the extent a "sale" or “share” under the CCPA is interpreted to include the activities described in this Privacy Statement, such as those disclosed in the "Cookies and Similar Technologies" section, we will comply with applicable law as to such activities.

MMNA discloses the following categories of personal information for business or commercial purposes:

· Identifiers

· Categories of Personal information described in the California Customer Records statute

· Characteristics of protected classifications

· Commercial information

· Internet or other electronic network activity information

· Geolocation data

· Audio, electronic, visual, thermal, olfactory, or similar information

We use and partner with different types of entities to assist with our daily operations and manage our Owner Portal and Mobile App. Please review the "How MMNA May Share Your Information" section for more detail about the parties with whom we may have shared information.

Retention Period: We will retain and use these categories of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Statement. We will take reasonable steps to delete the personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under the CCPA. We are required to maintain records of Consumer requests submitted under the CCPA, which may include these categories of personal information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.

Additional Data Collection and Uses: We will not collect categories of personal information other than those discussed above and we will not use your personal information for any other purposes that are incompatible with those disclosed above without providing you notice as may be required under the CCPA.

Exclusions from Personal information: Personal information does not include:

Publicly available information or lawfully obtained, truthful information that is a matter of public concern;
Personal information that is deidentified;
Personal information that is aggregated;
Information excluded from the scope of the CCPA including, but not limited to:
- Personal information collected, processed, sold, or disclosed subject to the GLBA or the California Financial Information Privacy Act;
- Personal information bearing on an activity involving the collection, maintenance, disclosure, sale, communication, or use of such information by an agency, furnisher, or user subject to regulation under the Fair Credit Reporting Act (FCRA); or
- Personal information collected, processed, sold, or disclosed subject to the California Financial Information Privacy Act and implementing regulations or the Driver’s Privacy Protection Act of 1994.

Data Practices During Last 12 Months

Personal Information Collected: As described in this California CVS Privacy Statement, we have collected the categories of personal information listed below during the preceding 12 months:

Identifiers

Categories of personal information described in the California Customer Records statute

Characteristics of protected classifications

Commercial information

Internet or other electronic network activity information

Geolocation data

Audio, electronic, visual, thermal, olfactory, or similar information

Categories of Sources: We have collected the categories of personal information identified in this California CVS Privacy Statement from the following categories of sources:

Directly from you. For example, from forms you complete, applications you submit, or products or services you obtain from us.
Indirectly from you. For example, from lead generation companies or cookies.
Service Providers and Contractors. For example, credit reporting agencies or credit and verification providers.
Third parties in connection with financing your vehicle.
Emergency service providers.
Unaffiliated third parties to provide select products and services to you.
Government entities or law enforcement agencies.

Business and Commercial Purpose for Collecting: We have collected the categories of personal information identified for the purposes listed in the “Business or Commercial Purposes” section above.

Categories of Personal information Disclosed for a Business Purpose: We have disclosed the following categories of personal information to service providers or contractors for a business purpose, or upon your consent to third parties during the preceding 12 months:

Identifiers

Categories of personal information described in the California Customer Records statute

Characteristics of protected classifications

Commercial information

Internet or other electronic network activity information

Geolocation data

Audio, electronic, visual, thermal, olfactory, or similar information

Business and Commercial Purpose for Disclosing: We have disclosed the categories of personal information identified for the purposes listed in the “Business or Commercial Purposes” section above.

Prior to disclosing any personal information to a service provider or contractor for a business purpose, we enter into a written contract which describes, without limitation, the specific business purposes which the personal information can be used by the service provider or contractor to perform the services specified in the contract, requires the service provider or contractor to both keep any personal information confidential, prohibits the service provider or contractor receiving the personal information from retaining, disclosing, or using the personal information outside the direct business relationship, prohibits the service provider or contractor from selling or sharing any personal information, provides us the right to take reasonable and appropriate steps to ensure that they use personal information in accordance with contractual terms, among other regulatory requirements.

The categories of personal information identified above were disclosed to the following categories of third-party recipients: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) investors; (4) service providers or contractors (data analytics, data storage, mailing, marketing and advertising, payment processing, website and platform administration, technical support, security monitoring; and operating systems and platforms); and (5) third parties to which you have authorized us to disclose your Personal Information in connection with services, products or online platforms that we made available for your use or access.

To the extent "sale" under the CCPA is interpreted to include the activities described in this Privacy Statement, such as those disclosed in the "Cookies and Similar Technologies" section, we will comply with applicable law as to such activities.

We use and partner with different types of entities to assist with our daily operations and manage our Owner Portal and Mobile App. Please review the "How MMNA May Share Your Information" section for more detail about the parties with whom we may have shared information.

No Financial Incentive: We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.

California Consumer Rights

The CCPA provides consumers with certain rights regarding their personal information. These rights do not apply in all instances and are subject to certain exceptions as a matter of law. By way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold. You may submit these requests to us as described below, and we honor these rights where they apply.

1. Right to Know: As described below, you have the right to request that we disclose personal information that we have collected, sold, or shared about you. This includes a request for the following:

The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
The categories of personal information that we have sold, shared, or disclosed for a business purpose about you;
The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
The specific pieces of personal information we have collected about you;
The business or commercial purpose(s) for which the personal information was collected, disclosed, sold, or shared.

Our response to a Request to Know may be limited to the 12-month period preceding receipt of the request if it would be impossible, involve disproportionate effort, or the request is for data for a specific time period. We are prohibited from disclosing Social Security numbers, driver’s license numbers, other government-issued identification numbers, financial account numbers, health insurance numbers, medical identification numbers, account passwords, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you whether we have collected that type of information. We will respond to requests to know by the same Consumer no more than twice in a twelve (12) month period.

2. Right to Delete: You have the right to request that we delete any personal information that we have collected, sold, or shared about you. However, we are not required to honor a deletion request if an exemption applies under the law.

3. Right to Opt-Out of Sale/Sharing: You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so. To the extent MMNA sells your personal information as the term "sell" is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking [here]. You may also submit a request to opt-out emailing us at privacy@mitsubishicars.com.

4. Right to Non-Discrimination: We will not discriminate against you, in terms of price or services that we offer, if you submit one of the rights requests listed above.

5. Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you. Our goal is to keep your personal information accurate, current, and complete.

6. Right to Limit: In limited circumstances, a Consumer has the right to limit the use and disclosure of Sensitive Personal Information to that use which is necessary to perform our services or as otherwise permitted by law. Our use of your Sensitive Personal Information is solely for Business Purposes, and not for those purposes for which a Consumer may exercise right to limit the use or disclosure under the CCPA. Therefore, we include this disclosure for informational purposes only.

These rights do not apply to personal information collected or disclosed under certain exemptions under CCPA. Rights such as the Right to Know and Right to Delete do not apply to personal information collected, processed, sold, or disclosed pursuant to these exemptions.

How to Exercise your Consumer Rights.

Submission Instructions: You may submit a request to exercise these rights by:

By email: privacy@mitsubishicars.com.

By mail:

Mitsubishi Motors North America, Inc.

Customer Relations Department

PO Box 689040

Franklin, TN 37068

By phone: 1-888-MITSU2024 (1-888-648-7820)

If you have a disability and would like to access this Privacy Statement in an alternative format, please email us at privacy@mitsubishicars.com.

Response Process: Upon receiving a request to know, request to delete, or request to correct, we will confirm receipt of the request within ten (10) business days and provide information about how we will process your request. The information provided will describe our verification process and when you should expect a response from us. In general, we will respond to the request within forty-five (45) calendar days from the day we receive it; but, if necessary, we may take up to an additional forty-five (45) calendar days to respond to your request. If an extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than forty-five (45) calendar days.

Once verification is complete, we will associate the information provided by you in the verifiable consumer request to any personal information previously collected by us about you. We will promptly take steps to disclose and deliver, free of charge to you, the information requested. We will provide an individualized response to requests regarding categories of personal information as required by applicable law, but, we may refer you to our general practices outlined in this California CVS Privacy Statement when our response would be the same for all consumers and all the information that is otherwise required to be in a response is presented here.

Delivery: Except as otherwise provided by applicable law, the information will be provided in writing or through our website. If we do not take action on your request, we will, without delay and, at the latest, within the time period permitted for our response, inform you of the reasons that we did not take action and any rights you may have to appeal the decision.

Verification Procedures: We are required by the CCPA to verify the identity of individuals who submit a request to know, request to delete, or request to correct. In accordance with our internal policies and in compliance with the CCPA, we will take steps to verify your identity before granting you access to such Personal Information or acting on your request to exercise your rights, as outlined below:

To determine whether the individual making the request is the consumer about whom we collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As part of this process, you will be asked to provide your full name, address, and phone number. We will inform you if we cannot verify your identity.

a. If we cannot verify the identity of the person making the request for specific pieces of information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.

b. If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response an explain why we have no reasonable method by which we can verify the identity of the requestor.

If we cannot verify your identity based on the information already maintained, we may request additional information from you. We will try to limit the information collected, and we will only use this information to verify your identity and for security or fraud-prevention purposes. Except as required by law, we will delete any new personal information collected for the purposes of verification as soon as practical after processing the request.

Authorized Agents: You may designate an authorized agent to make requests on your behalf by sending us written authorization in writing. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with written permission to do so; and (2) verify your identity directly with us. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code. We may deny a request from the agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Excessive Requests: If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights including, but not limited to, by:

a. Denying you goods or services.

b. Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

c. Providing you a different level or quality of goods or services.

d. Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

California Shine the Light

Under California’s “Shine the Light" law, Cal. Civ. Code § 1798.83, California customers have the right to request and obtain, once per year, information regarding MMNA’s disclosure of personal information as defined by Shine the Light to third parties (and, in some cases, affiliates) for their own direct marketing purposes. To request a list of the categories of information MMNA has shared, and the names and addresses of such third parties and affiliates, please send your request to:

Mitsubishi Motors North America, Inc.

Customer Relations Department

PO Box 689040

Franklin, TN 37068

Any such request must include “California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

Contact Information

If you have any questions or comments about this California CVS Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to lodge a complaint with us, you may contact us using the information below and we will do our best to assist you.

By email: privacy@mitsubishicars.com

By mail:

Mitsubishi Motors North America, Inc.

Customer Relations Department

PO Box 689040

Franklin, TN 37068

By phone: 1-888-MITSU2024 (1-888-648-7820)

If you have a disability and would like to access this Privacy Statement in an alternative format, please email us at privacy@mitsubishicars.com.