mbrace Privacy Notice
Effective: January 1, 2020
VZC and MBUSA may share with each other, and with their affiliates and service providers, the information obtained from you or from your vehicle, or derived from your use of mbrace.
VZC, MBUSA and their affiliates and service providers will use such information to provide the mbrace service to you and to occupants of your vehicle.
VZC, MBUSA and their affiliates and service providers may also use and disclose such information to provide other services, and to send you messages about other offerings.
1. INFORMATION WE COLLECT OR RECORD AND WHY IT IS COLLECTED
Our primary goal in collecting information is to facilitate the provision of mbrace services such as convenience services, entertainment services such as Wi-Fi, as well as safety and security services, including emergency crash notification, airbag deployment notification and stolen vehicle location services.
For example, to subscribe to the mbrace service, you must provide certain information in connection with the activation of your account and agreement to the Terms of Service, including your contact information (such as your name, address, email and emergency contact), your billing information, a credit card number, information about the purchase or lease of your Mercedes-Benz vehicle (the "Vehicle") and various other information.
We use this information in order to deliver mbrace services, for a statistical analysis of mbrace service usage, to improve our product offerings, to customize the mbrace services, to send you messages about new services, or to send you special offers. We also share your information with your dealer to assist it in servicing your car and to maintain contact with you directly, or through your Mercedes-Benz dealer.
We monitor and/or record conversations you have with our customer service representatives, emergency personnel, or the police. We also record your use of any automated services offered by us for various purposes, such as to assess, maintain or improve the quality of the services, for issue resolution, training purposes, or to promote and to provide the services.
Additionally, to provide the mbrace services, we collect information about your Vehicle including:
Information concerning your Vehicle's operation, performance and feature utilization to enable MBUSA and VZC to, among other things, improve its products and services. Such information includes diagnostic trouble codes, maintenance conditions, such as tire pressure and fuel economy.
Information about accidents involving your Vehicle, such as whether air bags deployed to notify emergency personnel, and for other services for which you've subscribed.
We do not regularly or continuously monitor or track the location of your Vehicle or estimate its speed unless such information is specifically required for a service for which you've subscribed. Such services include, among other things, to provide you with directions from a location, automatic collision notification, and vehicle location services in the event your Vehicle is stolen.
If you've agreed in a lease agreement, retail installment contract or other vehicle finance arrangement that vehicle location services may be used to facilitate the location and/or repossession of your Vehicle, we may collect and/or develop, and retain information concerning the location, direction, speed, and other parameters relating to your Vehicle, caller identification, date and time of call and any operator comments, and we may share such information with each other and our affiliates and service providers as described below in the Disclosure of Your Information section.
2. DISCLOSURE OF YOUR INFORMATION
We may share information about activations of the services with your Mercedes-Benz dealer in order to allow the dealer to contact you. We will also share pertinent information with the authorities in the event the stolen vehicle location assistance service has been requested.
MBUSA and VZC use vendors and partners to deliver the mbrace services to you on our behalf. These vendors and partners help us offer, provide, repair, restore, and bill for services we provide. For example, we share your information with roadside assistance providers and emergency service providers (e.g., 9-1-1). We may provide your credit card information and billing address to our payment processing company solely for the purpose of processing payment for a transaction you have requested. We require that these vendors and partners protect the customer information we provide to them and limit their use of MBUSA and VZC customer data to the purposes for which it was provided. We do not permit these types of vendors and partners to use this information for their own marketing purposes.
MBUSA also shares information with third parties who provide marketing services on their behalf. For example, MBUSA may provide your email address in order to send you information about vehicle products and services that may be of interest to you.
Except as explained in this Policy, in the mbrace Terms of Service, or in agreements with our customers, we do not sell, license, or share information that individually identifies you with others outside the MBUSA or VZC family of companies that are not performing work on MBUSA or VZC’s behalf without the consent of the person whose information will be shared.
We may be required to disclose personally identifiable information to a government entity to comply with valid legal process such as warrants, court orders, or subpoenas.
3. UPDATING OR CHANGING YOUR ACCOUNT INFORMATION
It is your obligation to correct or update the information you provide upon activation of the mbrace services when that information changes. You may modify this information by contacting us using the information provided below.
4. PROTECTION OF INFORMATION
MBUSA and VZC use commercially reasonable technical, administrative and physical safeguards to protect against unauthorized access to, use or disclosure of customer information we collect or store. Employees are trained on the importance of protecting customer privacy and on the proper access to, use and disclosure of customer information. Under our practices and policies, access to sensitive personally identifiable information is authorized only for those who have a business need for such access. Personally identifiable and other sensitive records are retained only as long as reasonably necessary for business, accounting, tax or legal purposes.
Although we work hard to protect personal information that we collect and store, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal information. VZC maintains security and incident response plans to handle incidents involving unauthorized access to private information we collect or store.
5. YOUR CONSENT
By using mbrace services, you agree to the practices and procedures described in this Policy. You also consent to our contacting you in your Vehicle or at your address, email address or phone number on file for the purpose of delivering mbrace services to you and to discuss your account services, features and benefits. From time to time, we may also send you information about selected products, services or offers we think may be of interest to you. Each email you receive from us for offers will provide a link to unsubscribe to future offers about that product. Alternatively, if you do not want to receive emails about our offers or products, just contact us using the information provided below. Please note that even if you choose not to receive marketing emails from us, you may still hear from us regarding the status of the mbrace services and any other service issues and order status updates that will allow us to provide you with the optimal user experience.
We or our partners or affiliates may also use your name, postal delivery information and phone number to contact you about products, services or offers that we think would be of interest to you. If you do not wish us to contact you offline please contact us using the information provided below.
By giving us your e-mail address and/or obtaining products and/or services through our web sites, you agree to receive e-mail marketing and/or telemarketing calls from us and our third-party advertising partners. You may always opt-out of receiving promotional calls from us by contacting us using the information provided below.
6. NEVADA PRIVACY RIGHTS
Nevada customers can opt out of the sale of their personally identifiable information. Nevada law defines “sale” as the exchange of certain personally identifiable customer information for money, where the recipient also intends to sell that information. Personally identifiable information includes name, address, phone number, Social Security Number or any identifier that can be used to contact you electronically.
VZC and MBUSA do not sell personally identifiable information today. However, Nevada customers have the right to opt out of the sale of their personal information, even if their information is not currently being sold. To opt out of any future sale of information covered by this Policy by VZC or MBUSA please email VZC at email@example.com.
7. CALIFORNIA PRIVACY RIGHTS
If you are a California resident, the California Consumer Privacy Act (CCPA) gives you the right to know what information companies collect about you and the right to access and delete that information within certain limitations. You also have the right to tell companies not to sell personal information about you. Companies may not discriminate against you for invoking these rights.
The categories of personal information we collect are: identifiers and contact information associated with your account; commercial information about the products, services and vehicles purchased; financial information such as your credit card or bank account used to pay for this service; internet or electronic network activity including vehicle operation, performance and feature utilization; geolocation information; audio information such as recordings of conversations you have with call center reps; inferences and insights about you; and protected classifications.
How we use these categories of personal information. We and our service providers use the categories of personal information we collect consistent with the relevant business and commercial purposes as they are defined under CCPA. These include:
- Providing service to you;
- Communicating with you and providing customer service;
- Improving services;
- Providing marketing and advertising;
- Auditing our processes and services;
- Short-term transient uses;
- Security, fraud and legal compliance purposes.
- Personalizing your vehicle experience
Your Rights to Access
Your Right to Delete
The CCPA gives you the right to request that we delete your personal information unless we need it for specific reasons described by the CCPA. For those categories of data, such as what is needed for security, legal, or other business or commercial purposes, we retain the information in accordance with our records retention policies and then securely delete it.
Your Right to Say “Do Not Sell”
The CCPA gives you the right to say no to the sale of personal information.
As noted above, we do not provide your personal information in exchange for money. However, some of our disclosures to our marketing partners may qualify as a sale under California law. That is because California law broadly defines a sale to include any selling, renting, releasing, disclosing, disseminating, making available, and transferring of a consumer’s personal information for money or other valuable consideration. The following personal information may be disclosed to our marketing partners:
- E-mail address
If you wish to opt out of MBUSA’s sale of your information, you may submit an opt out request here or by calling 1-833-808-5050.
VZC does not sell your personal information, as that term is defined based on our understanding of the CCPA. Specifically, we do not sell information that directly identifies you such as your name, telephone number, mailing address or email address, except as required by law. We also do not provide customer personal information to third parties for monetary or other valuable consideration.
We share certain information with third parties doing work on our behalf for business and commercial purposes and for other reasons, such as legal compliance and credit and collection purposes, with your consent and as further described in other sections of this policy.
Your Right to Not Be Discriminated Against
If you exercise any of the rights described here, we do not and will not discriminate against you by denying goods or services, charging different prices or rates for goods or services, or providing you a different level or quality of goods and services. You also have the right to receive information about any financial incentives we offer to you.
Where to Exercise Your Rights
If you or your authorized agent would like to exercise any of these rights, you may:
- E-mail firstname.lastname@example.org
- Call our dedicated Privacy Toll-Free Number at 1-866-990-9007.
You will be required to verify your identity before we fulfill your request.
8. SALE OF OUR CORPORATION
As in any business venture, the sale, merger or declaration of bankruptcy of a company is always a possibility. Should we ever declare bankruptcy or should our assets ever be acquired by or merged into another organization, all customer information we have collected will be treated as an asset and may be transferred to a third party.
9. CONTACT US
If you have questions, concerns or suggestions related to this Policy or our privacy practices please contact the mbrace customer service line at 1-866-990-9007 or the VZC privacy office at email@example.com
Verizon Privacy Office
1300 I Street, NW
Suite 500 East
Washington, DC 20005