PORSCHE PASSPORT/DRIVE PRIVACY NOTICE

Important Notice: We have updated our Privacy Notice to provide additional details regarding certain new rights provided under California law for consumers in California. For information about what has changed, please contact us as described in the Contact Us section below.

Your privacy is important to us. This privacy notice (“Privacy Notice”) describes how Porsche Smart Mobility, Inc. (“Porsche” or “we” or “us” or “our”) collects, uses, and shares information we obtain about you when you use the Porsche Passport/Drive website, download the Porsche Passport/Drive mobile application to your phone or other internet-connected device (your “Device”), and when you use the services available through the Porsche Passport/Drive mobile application (collectively, the “Porsche Passport/Drive Services”).



Scope



This Privacy Notice applies to information collected about you by or on behalf of Porsche as set forth in the below “Information We Collect” section, including through the Porsche Passport/Drive Services or other online services or programs where this Privacy Notice is posted or linked. This Privacy Notice does not apply to any of our affiliates, other Porsche companies, or Porsche dealers which are independent third parties.



As used in this Privacy Notice, “Personal Information” means information that identifies or can reasonably be linked to a specific individual, such as name, address, e-mail address, phone number, driver’s license number, or credit card number. “Information” is collectively used herein to refer to both Personal Information and information that does not identify and cannot reasonably be linked to a specific individual.



Information We Collect

When you use the Porsche Passport/Drive Services, we may collect certain information about you or the vehicle you reserve (“Vehicle”) from a variety of sources, including Personal Information you provide directly to us, and Information we collect about you when you access and use Porsche Passport/Drive Services. We also collect your Personal Information from independent Porsche dealers and from other third parties. We may combine any of the Information collected about you for the purposes described in this Privacy Notice.

When you register for the Porsche Passport/Drive Services or otherwise use the Porsche Passport/Drive website, we may collect:

• Contact Information, such as name, address, city, state and ZIP code, email address, and telephone number;

• Driver’s License Information, such as driver’s license number, the driver’s license expiration date, date of birth, gender, and the state and date of issuance;

• Payment Information, such as credit card number, credit card type, expiration date and CVV number; and

• Aggregate Data, based on your interaction with the Porsche Passport/Drive website, see Cookie/Tracking Section below for additional detail.



When you install and use the Porsche Passport/Drive mobile application, we collect:

• Location Information, if you permit the Porsche Passport/Drive mobile application to access location-sharing services. For example, we will collect your precise location when you reserve an available Vehicle. We may also collect the precise location of your Device when the Porsche Passport/Drive mobile application is running in the foreground or background. We may also derive your approximate location from your Internet Protocol (IP) address when you use the Porsche Passport/Drive website;

• Device information, such as Device type, Device operating system, IP address, unique identifier, type of browser, Internet service provider, and phone number;

• Information about your use of the Porsche Passport/Drive application, including screen view time, scrolling, specific actions to activate features and/or otherwise navigate the application, reactions to alerts, searches, and your interactions with in-application marketing offers;

• Information about your use of Porsche Passport/Drive Services, such as information about Vehicle reservation requests, date and time services were provided, amount charged, distance traveled, Vehicle-related information; and

• Aggregate data on your use of the Porsche Passport/Drive mobile application; see Cookie/Tracking Section below for additional detail.

Restricting the Collection of Location and Other Information

You can restrict our access to, as well as the collection and sharing of, the location of your Device by disabling location-sharing on your Device, if that feature is available on your Device. You should ensure that you have deleted all personal information from the Vehicle’s systems before returning the Vehicle. Please be aware, some of the Porsche Passport/Drive Services require access to and collection of the location of the Vehicle.

Global Positioning System Data

Passport/Drive vehicles may be equipped with vehicle tracking and other technology. We implement Global Positioning Systems (GPS), a network of satellites that allows us to determine the location of our vehicles. As permitted by law, this information is transmitted to us and can be stored for extended periods. We use this information for a variety of important purposes. For example, we use GPS data to help you find our vehicles, to provide roadside assistance, to ensure that a vehicle is available at the place and time you have reserved, to ensure that the vehicle is not driven to unauthorized locations and to locate a lost or stolen vehicle. We also maintain in-vehicle and in-equipment technologies to track and monitor performance of our vehicles and to assist us with ensuring that our vehicles are used only in accordance with applicable laws and our rules and policies. Disabling, disconnecting or destroying any such technology device or equipment is strictly prohibited.

Use of Your Information

When you use the Porsche Passport/Drive Services, we use the information we collect to:



• Provide Porsche Passport/Drive Services, including to facilitate reservation services, payments, and send receipts for services you request;

• Communicate with you about your account or the Porsche Passport/Drive Services;

• Provide you with marketing offers that may interest you;

• Improve, troubleshoot, and evaluate the use of our products and services (including the Porsche Passport/Drive mobile application);

• To create De-identified Information such as aggregate statistics relating to the use of the Service;

• Provide Vehicle support and service;

• Evaluate Vehicle performance and safety;

• Comply with legal requirements; and

• Conduct research.

Protective and Legal Uses

We may use, share and disclose your personal information for legal reasons as we believe necessary or appropriate, including:

• under applicable law, including laws outside your state or country of residence;

• to process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage;

• to enforce our policies and rules and the terms and conditions of your subscription;

• to recover our vehicles, equipment or any monies due, such as through debt collection agencies;

• to comply with legal process and to respond to requests from public and government authorities;

• to protect our operations, rights, privacy, safety or property, and/or that of our subsidiaries, you or others; and

• to allow us to pursue available remedies or limit the damages that we may sustain.

Sharing of Information

We will only share your Payment Information with our service providers to provide Porsche Passport/Drive Services.

We may share all other information we collect about you as follows:

• As required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution, or similar legal process;

• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a law enforcement request;

• With our services providers who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them;

• With emergency service providers;

• With third parties for research and development purposes (such as university research institutes for improving highway safety);

• In connection with the sale, transfer, or financing of a significant part of a Porsche business or its assets, including any of those activities associated with a bankruptcy proceeding;

• Within the Porsche family, including Porsche Cars North America (which shall be subject to its Privacy Notice located at https://www.porsche.com/usa/privacy-policy/) and its authorized Porsche dealers, for providing the Porsche Passport/Drive services and for their own marketing purposes;

• In connection with a Vehicle repossession to facilitate Vehicle recovery; and

• Those you ask us to share this information with.

We may also share non-personally identifiable information and aggregate information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) for other business purposes. For instance, we may share aggregate reports with interested third parties to help them understand the usage patterns for the Passport/Drive Services or website.

De-identified Information

“De-Identified Information” herein means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual. We may use De-Identified Information created by us without restriction. After we delete personally identifiable information, we may retain and continue to use De-Identified Information in accordance with applicable law.

Cookies/Tracking Technologies

Tracking on the Porsche Passport/Drive Website and Emails

The Porsche Passport/Drive website may use “cookies” to remember your preferences and to maximize the performance of our website and services. Using cookies on our websites provides benefits to you, such as allowing you to maintain your account login information.

Similarly, we may also place web beacons in our emails to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system, and browser used to deliver the email and any URL accessed through our email message. This information may also be used to evaluate our online advertising campaigns or to tailor promotions and other marketing messages to you.

To measure site activity and provide a better user experience, we may allow our service providers or business partners to compile information from the cookies, web beacons, or other technologies on our websites which may include information about your visit (such as demographic data, browser type, IP address, pages visited, activities conducted on the page and the day and time of your visit).

We may also allow third-party advertising and personalization partners to use this information to develop personalized content and appropriate advertising based on your visits over time on the Porsche Passport/Drive website and other non-Porsche affiliated websites.

At this time, we do not honor “do not track” signals from a website browser. However, you may

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

Tracking on the Porsche Passport/Drive Application

To help us understand how the Porsche Passport/Drive mobile application is being used, we use a third-party tracking service that uses cookies and similar technologies to obtain non-personally identifiable information about you. The non-personally identifiable information obtained may include information related to the Porsche Passport/Drive mobile application’s crashes, and your use of the Porsche Passport/Drive mobile application, including the functionality you use within the Porsche Passport/Drive mobile application, and how frequently and how long you use the Porsche Passport/Drive mobile application.

We do not track, or allow third parties to track your behavior over time and across third-party

applications or websites via the Porsche Passport/Drive mobile application. At this time, the Porsche Passport/Drive mobile application does not currently honor “do not track” signals from a website or device browser.

To opt out of the third-party tracking, you may uninstall the Porsche Passport/Drive mobile application by using the standard uninstall process available as part of your mobile device or via the Porsche Passport/Drive mobile application marketplace or network you used to download the Porsche Passport/Drive mobile application.

Social Media Sharing

The Porsche Passport/Drive Services may also include functionality that will allow you to share on social media platforms such as Facebook and Twitter. Depending on your privacy settings on these social media platforms, you understand and agree that when you post content or information, you may be allowing: a) access to that content and information; b) use of that content or information; and c) the ability for others to associate that content or information with you. In addition, these social media platforms may collect information about you in connection with the content you post. All content you post on these social media platforms is subject to their specific terms and conditions and privacy statement. Porsche is not responsible for that information collection. We recommend that you check the terms and conditions and privacy statement of these social media platforms prior to using this functionality.

Limiting Marketing and Promotional Communications

You may choose to limit the marketing and promotional communications we send you. You can do this by contacting us at info@porschepassport.com or 1-888-369-9904, and selecting your contact preferences.

How We Protect Your Information

We utilize technical, administrative, and physical safeguards designed to protect the security of Personal Information. As you may be aware, however, there is no completely secure method of transmitting or storing information and data.

Additional Notice for California Consumers



This part of our Privacy Notice applies to consumers who reside in the State of California.



Personal Information We Collect about California Consumers



We describe the Personal Information we have collected from consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled “Information We Collect.” The information we collect includes the following:



• Identifiers such as name, address, e-mail address, phone number, date of birth, driver’s license number, driver’s license expiration date, and the state and date of issuance, Internet Protocol address, and MAC address.

• The following categories of Personal Information described in California Civil Code § 1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” (2) vehicle identification numbers (VINs) (when linked to identified persons), vehicle information such as model and year, vehicle registration information, information about your use of Porsche Passport/Drive Services, such as information about Vehicle reservation requests, date and time services were provided, amount charged, distance traveled, odometer readings provided by you, (3) payment information such as payment card number or portion thereof, expiration date and CVV number, bank information, and payment amounts, (4) information you provide or that we record in connection with customer support calls or complaints, (5) demographic information such as birthdate, gender, language preference, and occupation, and (6) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe in “Information We Collect” above.



• Characteristics of protected classifications under California or federal law, such as language preference and gender.



• Commercial information, including information about orders, purchases, or leases of, or interest you have expressed in, any of our products or services, registration information for any Porsche event or program, including Porsche driving experiences and the Porsche Travel Club, or web specials; and information you provide or submit to us when you participate in any event, program, contest, surveys, or other promotion that we may offer from time to time.



• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, screen view time, scrolling, specific actions to activate features and/or otherwise navigate the application, reactions to alerts, searches, and your interactions with in-application marketing offers, and other information regarding your interaction with our websites, mobile apps, advertisements that we display on our websites or mobile apps or on third party sites and apps, or Porsche pages or accounts on any third-party social media platforms such as Facebook or Twitter.



• Geolocation data relating to your computer or device when you interact with Porsche Passport/Drive Services, Porsche Web sites and mobile apps that post this Privacy Notice.

• Audio information from calls placed with customer service and accounting centers which may be recorded, and electronic information in the form of Internet or other electronic network activity information as described above.



• Global positioning and other telematics data (as described above in more detail) relating to your use of our vehicles.



• Inferences drawn from (1) the information we collect when you visit our websites, use Porsche Passport/Drive Services or other Porsche apps, our social media apps, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, or behavior.



We collect this Personal Information from sources that include Porsche vehicle drivers, buyers and lessees, independent Porsche dealers, our affiliates, Porsche clubs, third parties such as Facebook if you access our online services through such third parties, and third-party marketing or analytics providers or providers of publicly available information. For more information, please see “Information We Collect”.



For information regarding the purposes for which we collect and use the Personal Information we collect, please see “Use of Your Information”.



Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes

We have disclosed the following categories of Personal Information to other businesses or third parties for monetary or other valuable consideration within the twelve (12) months preceding the effective date of this Privacy Notice:



Identifiers and Commercial Information. Name, address, VIN, employer (if known), current vehicle information, if known, and phone number. We share this information with independent Porsche dealers for marketing purposes.



Identifiers and Inferences. Pseudonymous identifiers for individuals who visit our Web sites and mobile apps and the devices such individuals use to visit our Web sites and mobile apps, data relating to usage of our Web sites and apps and inferences drawn from such usage data, and data acquired from third party marketing and digital advertising providers. We share this information with third party vendors that provide consumer behavioral analytics, social media, and digital advertising services to Porsche, and where applicable these vendors may use the information for their own purposes.



We have disclosed Personal Information in all or substantially all of the categories identified in this Additional Notice for California Consumers for various business purposes. For more information about the categories of Personal Information we have disclosed, the categories of entities with which we have disclosed this information and the purposes for which we have disclosed the information, please see “Sharing of Information”.



Your California Privacy Rights



If you are a California consumer, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.



Right to Access and Information regarding Personal Information. You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

• the categories of Personal Information we have collected about you;

• the categories of sources from which the Personal Information is collected;

• our business or commercial purpose for collecting or selling Personal Information;

• the categories of third parties with whom we share Personal Information;

• the specific pieces of information we have collected about you;

• the categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and

• the categories of Personal Information about you that we disclosed for a business purpose.



We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you through your account, if you maintain an account with Porsche, or, if not, electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information from one entity to another without hindrance.



Right to Deletion of Personal Information. You have the right to request that we delete Personal Information about you that we have collected from you.

Right to Opt Out. You have the right to opt out of the disclosure of Personal Information about you to third parties for monetary or other valuable consideration. To opt-out, please visit: Do Not Sell My Personal Information 

To opt-out from the sale of personal information for valuable consideration to analytics, social media, and advertising partners, please use the following links:

https://optout.aboutads.info/

https://optout.networkadvertising.org

• Google Advertising opt-out: https://support.google.com/ads/answer/7395996 

• Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout

• Trade Desk opt-out: https://www.adsrvr.org/

• Verizon Media opt-out: https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/controls/index.html

Right to Non-Discrimination. We may not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act, including by:

• Denying you goods or services;

• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Providing you a different level or quality of goods or services; or

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



We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to Porsche by your Personal Information.



Requests to Exercise Your Rights



You may request to exercise the foregoing rights by:



• Submitting a request through porsche.com/usa/privacy-policy/contact/

• Calling us toll-free at 1-800-PORSCHE.



Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.



Data Sharing for Direct Marketing Purposes



California Civil Code Section § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us as specified below. To make such a request, please tell us your preference by contacting us as specified below.

Do Not Track



At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, our online services are unable to respond to Do Not Track Signals.

Changes to This Privacy Notice

Porsche reserves the right to modify this Privacy Notice at any time so you should review it frequently for changes. Your continued use of Porsche Passport/Drive Services and/or the provision of your Personal Information after such posting constitute your acceptance of such changes. Please contact us as described in the Contact Us section if you would like information regarding any changes.

Contact Us

If you have any questions or comments about this Privacy Notice or our privacy practices or any requests with respect to the Personal Information we collect about you, you may contact us at info@porschepassport.com or 1-800-PORSCHE.

Your Consent

By using the Porsche Passport/Drive Services, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing” means using cookies on a computer/hand-held device or using or touching your information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the U.S., your information will be transferred to the U.S., and processed and stored there under U.S. privacy standards.

By using the Porsche Passport/Drive Services, you also give us your consent to call you or send text messages to your mobile telephone/device. You also consent to our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers. We will not charge you for such calls or texts, although you may be charged by your mobile service provider to which you subscribe.

Effective Date: January 1, 2020

Copyright © 2019 Porsche Smart Mobility, Inc.