PRIVACY POLICY

This is the privacy policy of Stellantis (Australia and New Zealand) Pty Ltd (ACN 125 956 505) trading as Leapmotor (Leapmotor) (we, us, Leapmotor, Stellantis Australia). It applies to all personal information we collect and use in connection with our business. Stellantis Australia is an affiliate of the Stellantis group of companies.

We comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles, which regulate how we may collect, use, disclose and store personal information. This privacy policy is intended to keep you informed of the ways we collect, use, disclose, store and protect your personal information and help you to understand your rights (and our obligations) under the Privacy Act.

Changes to this privacy policy

We may change this privacy policy from time to time. The updated privacy policy will be posted on our website, with the date of the update shown.

Information we may collect about you

Personal information generally means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and it is not possible to connect the data to the individual. We may collect and use different kinds of personal information related to our business activities and when it is necessary and relevant to our relationship with you. Our business functions and activities primarily involve the manufacture and distribution of vehicles and associated products and services. If you make an enquiry with us, or ask us to provide you with any of our products or services, we may collect the following types information about you:
• your name, email address, telephone number and postal address;
• your Drivers' Licence details;
• your age, gender and occupation;
• your purchase history and products and services purchased;
• information on your vehicle including VIN, warranty, make, model, registration plate etc;
• your vehicle's repairs and service history;
• your IP Address;
• location data;
• device type (iPhone, laptop etc);
• domain name;
• web browser;
• date and time of access to the website and which website you came from;
• content of emails;
• information you post on our webpage and social media pages;
• other information and material that we reasonably need to collect to administer our business; and
• data we collect automatically about how you use and interact with our website, social media pages and applications.

Connected vehicles

Connected vehicles collect and process data relating to the vehicle itself and its surroundings. Some of this data may be regularly overwritten while other data may be stored for a certain period or aggregated in statistical form. This 'vehicle‐generated data' may relate to:
• safety and security (e.g. crash event data such as whether airbags have been triggered or whether doors and windows are locked or open);
• vehicle functionality status (e.g. engine injection, transmission behaviour, fuel level, battery charging level, driver assistance systems, on‐board diagnostic malfunctions);
• driving (e.g. fuel consumption, speed, use of brake and accelerator pedals, steering wheel movement, general vehicle operating parameters to inform predictive maintenance or repair);
• location of the vehicle: (e.g. navigation, providing locally relevant information, locating vehicles);
• enabling remote vehicle operations: (for example: remote engine start, remote climate control operation, remote lock/unlock);
• data that has been introduced by customers themselves. This 'user introduced data' may be collected and stored through certain features of the vehicle, including but not limited to:
• infotainment settings (e.g. preferred radio station);
• convenience settings (e.g. seat & mirror positions);
• navigation destinations; and
• mobile phone address book.

How we collect information about you

Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:
• when you enter personal information directly into our websites, social media or Leapmotor controlled applications;
• when you communicate with us, such as when you contact us by telephone or email, or send an enquiry through our website or socialmedia;
• apply for employment with us through the application process, including through third parties such as your referees and previous employers;
• from your vehicle where it has connected services enabled, including from in-vehicle sensors, GPS sensors, cameras, and other data collection methods;
• enter our websites our third party Internet Host provider records your server address, domain name, the date and time of your visit and the pages viewed and we may also obtain information about you from Google analytics;
• enter into written agreements with us, our dealers, agents or third party service providers;
• purchase a vehicle or service a vehicle and become a customer;
• supply goods or services to us;
• answer a survey or respond to requests from a market research agencies engaged by us;
• fill in a competition form;
• post a comment on our websites, social media pages, send us an email or make a telephone enquiry;
• ask to be placed on a mailing list;
• provide your information to a third party that we supply or provide services to, such as our Leapmotor related body corporates, dealers and distributors, contractors and regulatory authorities.

In certain cases we may collect personal information about you from publicly available sources and third parties. You must only provide us with the personal information of someone else if you have that person's consent to disclose that information to us and for us to use that information in accordance with this privacy policy.

As noted above, for connected vehicles, some personal information may be collected through a vehicle.

Unsolicited information

If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under the Privacy Act if we had requested it, we will destroy or de-identify the information (if it is lawful and reasonable to do so). If we collect your personal information in an unsolicited manner, we will take reasonable steps to inform you of such collection and also how we use, disclose and secure your personal information. Such reasonable steps may include referring you to this privacy policy.

Do I have to provide you with my personal information?

You can deal with us anonymously (without giving us your name and contact details) or by using a pseudonym in some limited circumstances. If you contact us by phone or other means and ask to remain anonymous, you may do so and we will try to answer your request without seeking identifying details. However, if you choose to deal with us anonymously, there are some things we cannot do and it may be impractical or impossible to provide you with our goods or services. For example, we will not be able to enter into an agreement with you to provide you with any of our products or services or answer queries related to specific vehicles without identifying you as the owner of the vehicle.

Purpose for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. We collect, hold, use and disclose personal information to:
• provide you with the goods and services (including connected car services) you have purchased from us or our dealers, and administer our dealing with you, including sending you invoices and receipts;
• respond to feedback, complaints or comments;
• to pass on enquiries, complaints or comments made by you regarding our products, sales or services to a dealer or a related Stellantis group company, who can assist with your enquiry or complaint;
• communicate with you and provide you with relevant information, including effecting recalls, service reminders and marketing information (unless you have requested not to receive marketing information from us);
• conduct customer surveys and market research activities;
• provide our websites, social media and applications and associated functionality to you;
• provide services, features and information related to your connected vehicle, including delivering over-the-air updates to your vehicle, or as otherwise necessary to provide information or services requested by you;
• monitor and improve the performance and safety of your connected vehicle;
• assess your needs and preferences so that we can refer you to relevant products and services;
• improve our service and product offerings;
• comply with legal and regulatory obligations; and
• otherwise manage our business.

We may use your personal information for activities in support of our primary business functions such as processing payments, administration, employment, management, marketing, contracting, IT, legal, and customer support.

Disclosure of personal information to third parties

We may disclose your personal information to the third parties set out below for any of the purposes set out above. The types of third parties with whom we disclose personal information include:
• our service providers, including providers of campaign, promotion, accounting, auditing, legal, banking, payment, delivery, data processing, data analysis, document management, mail houses, research, investigation, technology services, retailers, market research agencies, and training providers;
• government agencies for reporting and compliance purposes;
• various third party suppliers and partners, which provide services and support for our programs and operations;
• our related bodies corporate, authorised dealers and aftersales partners (including their respective bodies corporate) and
• to a third party organisation in the event we sell or transfer all or a portion of our business or assets.

Protection of your personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers. We maintain appropriate physical, procedural and technical security for our information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information. We further protect personal information by restricting access to personal information to only those who need access to the personal information do their job, and we will destroy or de-identify your personal information once it is no longer needed for a valid purpose or required to be kept by law.

Direct marketing

Like most businesses, marketing is important to our continued success. We may use your personal information (such as your contact details) to provide you with information about products and services that we consider may be of interest to you. We will not disclose your personal information to third parties for marketing purposes without your consent. You may opt out at any time if you no longer wish to receive marketing
information from us. You can do this by contacting marketingau@fcagroup.com or by mail to Direct Marketing Manager, Leapmotor, 437 Plummer Street, Port Melbourne, Victoria, 3207 or by using the 'unsubscribe' function included in our marketing emails.

Cookies and related information collection

We or others acting on our behalf may use cookies, pixel tags, web beacons or other similar technologies in connection with the operation of our websites or applications. These technologies may collect and store non-personal information. We may share data collected from you on our websites with our third party vendors or suppliers to advertise or market to you on other sites as you browse the web. A cookie is a small text file stored in your computer's memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing our website. This information will help to better adapt our website to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser's manual.

Overseas disclosures

As at the date of this privacy policy, we are likely to disclose your personal information to overseas recipients for the purpose of those overseas recipients providing you and us with services. We will disclose your personal information to service providers in Europe, the United States, Asia and China. Leapmotor, as part of the Stellantis group of companies including its newly established joint venture subsidiary Leapmotor International B.V. (a joint venture established together with Zhejiang Leapmotor Technology Co., Ltd.), has internal reporting requirements to other Stellantis entities and the joint venture subsidiary. Other Stellantis entities, and the joint venture subsidiary may also provide a range of technology, operational (such as database storage services) and customer service functions on our behalf, which may involve the transfer of your personal information to other Stellantis entities, and the joint venture subsidiary, located overseas. If you are a contractor, your personnel records, which may contain sensitive information may be sent overseas to other Stellantis entities and the joint venture subsidiary and/or database storage services.

Accessing and correcting your personal information

You may contact our Privacy Officer using the contact details below to request access to, or a correction of, the personal information that we hold about you. We will deal with your request within a reasonable time. On the rare occasion that we refuse access, we will provide you with a written notice setting out the reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. We will also provide you with avenues to complain about our refusal to provide you with access to the information. We are not obliged to correct any of your personal information if we do not agree that it requires correction. If we refuse a correction request, we will provide you with a written notice with our reasons for refusing. We may recover reasonable costs in relation to a request for access to personal information.

Resolving personal information concerns

If you have any questions, concerns or complaints about this privacy policy, or how we handle your personal information, please contact our Privacy Officer by emailing privacyaus@stellantis.com. We take all complaints seriously, and will respond to your complaint within a reasonable period. You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or

email: enquiries@oaic.gov.au.

This privacy policy was last updated on 16 July 2024.

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