PRIVACY POLICY
for Dealer App
Last updated: January 15, 2015

Why Are We Providing This Policy?
Federal law requires us to tell you how we collect, share, and protect your personal information. This Privacy Policy provides you with information about what data we collect about you here at Sirius XM Radio Inc. (“Sirius XM”, “us” or “we”), what we do with it, and your options if you download and use our Dealer App.

What Information Is Covered By This Policy?
If you download and use our Dealer App for the purpose of performing a satellite radio signal refresh or for any other reason, the information we collect will include the Vehicle Identification Number (“VIN”) and the Radio ID (“RID”) of the vehicle which is the object of the App’s collection tools.
  You can choose the method for our collection of the VIN or RID. The App will collect the VIN or RID (1) by directing the device with the App at the VIN plaque on the vehicle and following instructions to initiate the collection; and (2) by typing the VIN or RID into the fields of the App and following prompts to submit it to us.
  The information we collect will also include the Device ID if you enable “push notifications,” the type of device with which you are accessing our Dealer App such as the smartphone make and model, and the operating system version for the device you are using with our Dealer App (i.e., the “OS” as well as the version).
  We will also collect information on how the Dealer App is being used, the user “flow,” and whether you were able to successfully refresh the satellite radio identified by the VIN or RID. This anonymous information will be kept in a secure database and will not be shared with any other party.
  We will collect no personal information whatsoever, no anonymous information other than described above, and no location information related to the VIN or RID.


Your Location
When you download or use apps created by SiriusXM or our subsidiaries, we will not receive information about your location.

How Is Information Shared?
We may share the VIN or RID with third parties in the course of refreshing the satellite signal to the satellite radio identified inside the VIN or RID submitted to us. These entities will have no rights to use your VIN or RID for marketing purposes.

Privacy Complaints
Your privacy concerns are important to us. We are committed to resolving complaints about your privacy in a timely manner. We request that all privacy-related complaints be made first through our internal complaint resolution process by submitting a written complaint via direct mail to:

Privacy Officer
Sirius XM Radio Inc.
1500 Eckington Place, N.E.
Washington, D.C. 20002
Or via email to: privacy@siriusxm.com
Sensitive, personal information should not be sent via email.


Governing Law
We control and operate the Dealer App from the United States. The Dealer App is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the Dealer App is appropriate for use in any particular jurisdiction. Those who choose to access the Dealer App do so at their own initiative and are responsible for complying with all applicable laws, rules and regulations. The interpretation and enforcement of this Privacy Policy shall be governed by the rules and regulations of the State of New York and other applicable United States federal laws.

Notification of Changes
Please make a note of the Effective Date of this Privacy Policy for our Dealer App. We may revise and update this Privacy Policy at any time without notice for any or no reason, including if our practices change, if technology changes, or as we add new features or change existing ones. These privacy practices apply to past, current and potential future vehicle dealerships which use our Dealer App. If we make material changes to our Privacy Policy, you will know because the Effective Date of the Privacy Policy will change. By using the Dealer App after the Effective Date, you are deemed to consent to our then-current Privacy Policy. We recommend that you visit this Privacy Policy on a regular basis to ensure that you are familiar with its current terms. If, as a result of a change in applicable law, it becomes a requirement to notify you of a material change in the use or handling of your anonymous and/or personal information, you will receive a notice.

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