Rolls-Royce Motor Cars Assist

Privacy Policy

ROLLS-ROYCE MOTOR CARS of North America, LLC offers location-based Automatic Collision Notification, Direction Services, Emergency Response, and Roadside Assistance Services (“Telematics”), collectively called “ROLLS-ROYCE MOTOR CARS Assist” to owners having the ROLLS-ROYCE MOTOR CARS furnished with Telematics equipment. This service is extended for a defined time period from the date of retail delivery to the owner, as defined in the Subscriber Agreement executed by owner.

ROLLS-ROYCE MOTOR CARS of North America, LLC and its telematics service provider, ATX Technologies, Inc. (“ATX”), takes your privacy very seriously. This Telematics Privacy Policy (“Policy”) governs the information gathering and dissemination practices related to the provision of telematics services to our subscribers. This Policy supplements any Subscriber Agreement you have with ROLLS-ROYCE MOTOR CARS and/or ATX, and any privacy provisions contained therein. Please read this Policy carefully. Please note that this Policy as it relates to telematics information and not personally identifiable information collected through the website may be changed from time to time, and that any changes will supersede this Policy.

1. The Information We Collect Our primary goal in collecting personal information from you is to facilitate the provision of the telematics services. As a general rule, telematics services are activated if you place a call to the ROLLS-ROYCE MOTOR CARS Assist Response Center or, if an airbag in your vehicle deploys. In addition to the information you provided with your Subscriber Agreement, when the telematics services are activated, we may collect and/or develop, and retain, the following information: your location, direction, and other parameters, caller identification, date and time of call and any operator comments. From time to time, we may also randomly monitor or record any conversation you have with our Response Center for quality assurance purposes.

2. Use of Your Information It is our policy to use the information we collect from you for purposes of delivering telematics services to you. We may also use your information for a statistical analysis of telematics service usage, to improve our product offerings and to customize the telematics services. We do not sell, trade or rent your information to others.

3. Disclosure of Your Information To Provide the Telematics Services. ATX, as a contractor of ROLLS-ROYCE MOTOR CARS, shares your information with roadside assistance providers, emergency service providers (i.e., 9-1-1) and other service providers (i.e., concierge services, individuals requested by you to be contacted in an emergency), as well as ROLLS-ROYCE MOTOR CARS dealers only for the purpose of delivering the telematics services to you. For Other Purposes. We may also provide aggregate statistics about our subscribers and related telematics service information to third-parties, but these statistics will not include any personal identifying information. When required, we may release information necessary to (i) comply with the law, or (ii) enforce or apply the terms of our Agreements. For example, we may be legally compelled to provide location data and other information to law enforcement agencies. Concierge Services. Circle Company Associates, Inc. (Circles), as a contractor of ROLLS-ROYCE MOTOR CARS, may in turn use other service providers to provide the products and services that you request when you use the Concierge Services. By utilizing the Concierge Services, you acknowledge that personal information necessary to provide any products and services you request may be given to such third-party service providers, and that the ROLLS-ROYCE MOTOR CARS Assist Privacy Policy does not govern these providers.

4. Updating or Changing Your Account Information You may modify, correct, change or update the information you provide upon activation of the telematics services at any time or upon request. To modify this information, please send a letter with your new information to: ROLLS-ROYCE MOTOR CARS Assist Response Center, P.O. Box 3523, Coppell, TX 75019-9827. You may also fax the information to the ROLLS-ROYCE MOTOR CARS Assist Response Center at (888) 226-9492 or by calling the ROLLS-ROYCE MOTOR CARS Response Center Customer Care at (800) 803-4658.

5. Protection of Subscriber Information We have security measures in place to protect the loss, misuse, and alteration of the information under our control. For example, depending upon the applications, we employ encryption technologies and user authentication systems such as passwords and personal identification numbers. All information is stored under secure measures with access limited only to authorized ATX employees. Although we take your privacy very seriously and we use industry standard practices to protect the privacy of your information, we cannot guarantee that your information will always remain private.

6. Security on the Cellular Telephone Network. In providing the Services to you, voice and data are transmitted between the response center and your vehicle over the cellular telephone network. This network is complex and not necessarily secure. Therefore, the privacy and security of conversations or data transmitted to and from the vehicle cannot be guaranteed.

7. Your Consent By using the telematics services, you agree to the practices and procedures described in this Policy. We may change this Policy, as it relates to telematics information, at any time by posting on the ROLLS-ROYCE MOTOR CARS website located at http:// www.rolls-roycemotorcarsassist.com/privacy_policy. You can access the current Policy at that website, or by requesting a copy from ATX by calling ROLLS-ROYCE MOTOR CARS Assist Customer Care toll free at (800)803-4658. Your continued use of the telematics services after any such change is made constitutes acceptance of and agreement to be bound by the terms of the Policy as modified. You also consent to our contacting you in your vehicle or at your address on file for the purpose of delivering telematics services to you.

8. Your Comments We welcome feedback concerning this Policy. Please send your comments and questions by contacting the ROLLS-ROYCE MOTOR CARS Assist privacy officer at privacyofficer@atxna.com or by calling (972)753-6230.