YOUR CALIFORNIA PRIVACY RIGHTS YOUR NEVADA PRIVACY RIGHTS FordDirect Privacy Statement Please note our Privacy Statement is being updated effective July 1, 2021. Click here to view the previous privacy statement. Updated Date: June 22, 2021 Effective Date: July 1, 2021 SUMMARY OF PRIVACY STATEMENT At FordDirect, we care about privacy and believe in providing transparency to consumers about our information handling practices. This Privacy Statement applies to personal information – information that identifies you or reasonably can be linked to information that identifies you – that FordDirect collects through your use or interaction with our websites, applications, social media, software, and other services provided by or on behalf of FordDirect (collectively, the “Services”). We will continue to share your information as described in this notice, even after the end of your relationship with us. FordDirect is a member of the Digital Advertising Alliance (DAA) and adheres to certain DAA principles. Information We Collect tell me more The information we collect through our Services may include: your contact information (name, postal or email address, phone number, etc.); your demographic information; information about the device you use to connect or interact with our Services, including geo-location; details about your online activity, use and interaction with our Services; your vehicle information; your financial information (income, assets, employment information, etc.) your shopping and other personal preferences; and social media details and any other information you choose to share on those platforms. How We Collect Information tell me more We collect information about you from a variety of sources, including: details you choose to provide via our Services; from our affiliates; from our business customers; from outside other sources i.e. suppliers, third parties), and automatically, from devices that you use to connect or interact with our Services. How We Use Your Information tell me more We may use the information we collect to: provide the Services; communicate with you; provide and promote our products and Services; advertise and market to you; operate our business; analyze the use of our products and Services; facilitate employee recruitment; and comply with applicable laws, rules and our policies. Information Sharing tell me more We may share the information we collect: within our enterprise; with our suppliers; with our affiliates, Dealers, Dealer Associations, and business customers; with our marketing partners; as we otherwise may notify you; and if FordDirect or its assets are acquired. INTRODUCTION At FordDirect, we care about privacy, and we believe in providing transparency to consumers about our personal information practices. This Privacy Statement explains how FordDirect collects, uses, discloses, and protects your personal information. FordDirect is dedicated to helping visitors to our websites, including those that use and interact with our Services and connect with Ford and Lincoln dealers (“Dealers”), Ford Dealership Associations (“Dealer Associations”), and Ford Motor Company (and its affiliates and subsidiaries) to learn about Ford and Lincoln vehicles and related products and services. This Privacy Statement applies to the personal information FordDirect collects about you through websites, applications, social media, software, and other services provided by or on behalf of FordDirect. When you use or interact with the Services, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Statement. If a Service is co-branded or developed by another party (such as Dealer.Com) or linked to another party, such other party’s privacy statement may apply in addition to or in lieu of this Privacy Statement. If you have any questions about our privacy practices, please contact us as set out in the “Contacting FordDirect” section below. If you are a California resident or Nevada resident, please see the “Your California Privacy Rights” and “Your Nevada Privacy Rights” sections below. Back to top INFORMATION WE COLLECT Information About You. The information that you provide directly to us and that we obtain from others is what we need to serve you, our affiliates and business customers. This information may include your contact details (such as name, postal and email addresses, phone number, social media handles and other online aliases); information specific to the Service you request (such as financial information when you apply for credit); details about your vehicle (such as performance and location information) and Dealer transactions (including phone calls, chat transcripts, and other details); contact information of individuals with whom you would like to share FordDirect content; social media information; demographic and household information; your responses and engagement with our Services; and other information you may choose to share with us by interacting with our Services or with our affiliates, business customers, suppliers or other businesses that share information with us. Information About Your Device. The information we collect by automated means also helps us, our affiliates and our business customers to provide and tailor various products and services. Examples of information we collect by automated means include the following: Usage Information. We and our suppliers may automatically collect your usage activity, preferences, and browser details (such as your IP address and browser type), as well the ID and type of the device you use to connect or interact with our Services, and other details about your use or interaction with our Services. This may also include the collection of information about your online activities over time and across third-party websites or online services and across devices that you use. FordDirect does not itself respond to web browser-based do-not-track signals since there is not a common understanding of how to interpret the do-not-track signal. However, certain of our websites participate in the AdChoices program. If the website that you are visiting displays an AdChoices icon, you may click on the icon and follow instructions to adjust your privacy preferences. If you opt-out using AdChoices, our websites that participate in the program will no longer collect information about your online activities over time and across third-party websites or online services for behavioral advertising purposes. Location Data. Some of our Services may collect geo-location data to provide or improve our Services and location-related functionality, such as the location of your nearest Dealer, and your precise location while at a Dealer or near a Dealer’s location. We may link location data to other information we have collected about you. Back to top HOW WE COLLECT INFORMATION Information You Provide. We and our suppliers collect the information you voluntarily provide to us in connection with using our Services, including through product inquiries (including phone calls, chat transcripts, and other details), requests for vehicle information, financing requests, technical services or questions, product registration and support, events and promotions, job applications, other inquiries and transactions. Our suppliers also may collect information from you, including, for example, when you participate in our contests, sweepstakes, surveys, and other promotions. Some portions of the Services may allow you to submit comments, reviews, ratings and other content. Information We Obtain from Affiliates, Business Customers, Suppliers and Others. We may obtain information about you from outside sources. For example, our affiliates, Dealers and Dealer Associations that deploy FordDirect products and Services and suppliers may share with us certain information you provided to them or collected by using their website. They may also inform us whether you have been approved for credit and related information. We also may obtain demographic, user preferences, geo-location and other information about you from other parties. If you engage via social media with us, our affiliates, our business customers, or our suppliers, the social media platforms also may share certain information with FordDirect. You may be able to adjust your social media privacy settings to limit the sharing of your social media data. Information We Obtain by Automated Means. We may collect information about your use or interaction with our Services or about the devices you use to connect or interact with the Services by automated means, including tracking technologies. These tracking technologies may include “cookies,” which are small lines of text/data that are written onto your device by a website. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. FordDirect and suppliers acting on our behalf may use cookies, pixel tags, beacons, Bluetooth and Wi-Fi monitoring and other technologies to operate the Services. Cookies we may use may redirect you to other websites. With your consent, we may also use video technologies to capture your demographic information and engagement with our Services in order to present you with a more personalized experience. Browser cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. You can also choose to limit the information shared with social media, advertising, and analytics partners. Mobile advertising ID controls. Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID. Back to top DATA COLLECTION AND USE BY THIRD PARTIES Our Services may include third-party advertising, promotions, co-branded features, links to other websites, and other programs offered by or in collaboration with third-party businesses, such as Adobe, Facebook, Microsoft, and Google. In addition to collecting information directly from you, these third-party businesses may use tracking technology to measure the effectiveness of their ads, personalize or optimize advertising content, and track users who click on the links made available through the Services. We also use Bing Universal Event Tracking (UET) from Microsoft Bing Ads that places a tag on your computer when you visit one of our websites through Bing Ads advertisements. The UET tag is used for user tracking and data sharing with third parties for advertising and marketing purposes, and to measure ad effectiveness. To learn more about the privacy practices of these third-parties, we encourage you to review Adobe’s Privacy, Facebook’s Data Policy, Microsoft’s Privacy Statement, and Google’s Privacy Policy. We, directly or indirectly thorough our affiliates such as Ford Motor Company, participate in the Adobe Experience Cloud Device Co-op. This Co-op allows Adobe to better understand how websites and apps are used by linking various devices that appear to be used by the same person. In turn, it helps companies who are members of the Co-op, including Ford Motor Company, create websites, apps and ads customized for you, across devices. In addition to the other collection methods and usage purposes stated elsewhere in this Privacy Statement, your information may be collected via cookies, web beacons, and other technologies and used for this purpose. You can learn more about the Co-op, how Adobe does this, and how to opt-out at: https://cross-device-privacy.adobe.com When you use or interact with our Services, these third-party businesses may collect information about you, including your online activities over time and across third-party websites or online services. We are not responsible for the privacy practices of these third parties, Dealers, Dealer Associations, and their suppliers, and we encourage you to read their privacy policies, which may apply to these third-party programs. Some of the ads you receive on websites are customized based on predictions about your interests generated from your visits to different websites. This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising. The Digital Advertising Alliance (“DAA”) provides a “Consumer Opt-out” for certain companies (including FordDirect) that have agreed to provide that functionality. Back to top HOW WE USE YOUR INFORMATION A primary use of your information is to serve you, which requires certain sharing with our affiliates and business customers. The following are examples of the types of general purposes for which we may use your information. Provide Products and Services. We may, for example, use your information to complete a transaction you have asked us to do, including e-commerce transactions or “get a quote” or “find a dealer” requests, or to send you communications regarding products, service reminders or vehicle information. We may also, for example, use your information to provide you with an improved experience when interacting with us, our affiliates, Dealers and Dealer Associations. Operate our Business and Develop and Improve Our Products and Services. Examples include using information collected through cookies and similar technology to better understand how our Services are used, develop new offerings, or personalize your experience when using the Services. Customer Service. If you request support or other information, we may use your information to respond to your request. We may follow up with you to notify you periodically about important topics, like Services updates or changes to our Privacy Statement. Advertising and Marketing. We may use your information to let you know about current offers, invite you to participate in those offers and manage your participation in them. We also may use information about you, your use or your interaction with our Services to tailor our offers to your preferences or to offer you products and services that we believe may be of interest to you. Dealers, Dealer Associations and our affiliates may use your information for their own marketing purposes. Among other privacy choices described in this Privacy Statement, you may direct us to not send you email marketing communications by clicking on the unsubscribe link included in the emails you receive from us. Recruitment and Job Applications. We may use the information submitted on resumes and similar documents through FordDirect and our suppliers for the purpose of employment consideration. We may keep your information on file for future consideration. Compliance with Legal Requirements, Rules and Internal Policies. We may be required by law or internal data retention policies to maintain information about you for a certain period of time, or to notify you of a security breach. We also may be required by social media platform rules (such as Facebook) to handle the social media information you or the platform share with us in a certain manner. Back to top INFORMATION SHARING A primary use of your information is to serve you, which requires certain sharing with our affiliates and business customers. This section describes the types of organizations with whom we may share your information. Within FordDirect. FordDirect may authorize access to your information within our enterprise, by our employees and other personnel, to fulfill our obligations to you and to operate our business. Affiliates, Dealers, Dealer Associations and Suppliers. Our affiliates, Dealers, Dealer Associations and suppliers may access and use your information for the purposes we describe in this Privacy Statement, including as necessary to provide functionality, products, and services to us and you in connection with the Services. For example, when you register for a sweepstakes, a supplier may process the sweepstakes entry. FordDirect requires suppliers to process your information under the direction of FordDirect and in accordance with contractual restrictions and applicable law. We also may share data collected through cookies and similar technology with our suppliers to advertise or market to you on other websites as you browse the web. We may also allow our affiliates, Dealers, Dealer Associations and suppliers to have access to your information and to use aggregate statistics – statistics not linked by us to any specific consumer – about consumer behavior, sales, online activity patterns, and related Services information. Except as necessary to provide you with the Services, we will not provide our affiliates with personal financial information that we obtain when you use the Services to submit a request for credit. Marketing Partners. We may share your information with our marketing partners when, for example, we participate in a co-branded promotion with another company. Other than as described in this Privacy Statement, we will not share your information with suppliers for their own marketing purposes. Except as necessary to provide you with the Services, we also will not provide our marketing partners with personal financial information that we obtain when you use the Services to submit a request for credit. Your Public Comments. Some portions of our Services may allow you to submit comments, reviews, ratings and other content. This content may be displayed on the Services and may be viewable by other users of the Services or the public generally. Mergers, Acquisitions or Insolvency. If FordDirect should ever file for bankruptcy or merge with another company, or if FordDirect should decide to buy, sell, or reorganize some part or all of its business, FordDirect reserves the right to disclose your information, including to prospective or actual purchasers in connection with one of these transactions. As Required by Law and Other Disclosures. FordDirect may be required to disclose your information if it: believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority; would potentially lessen our liability in an actual or potential lawsuit or investigation; or is necessary to protect our or others’ rights or property. Back to top INFORMATION SECURITY We take reasonable measures to secure our systems and protect your personal information. When we receive your personal financial information (for example, when you use the Services to submit a request for credit), we securely store and protect your information from unauthorized access and use with security measures that comply with applicable law. These measures include computer safeguards and physical controls. However, data transmissions over the Internet and otherwise can never be guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us and you do so at your own risk. By providing your email address to us or using the Services, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically, as permitted by applicable law. You may have a legal right to receive this notice in writing. To receive a free written notice in the event of a security breach (or to withdraw your consent from receiving electronic notice), or if you want to update the contact information you have previously provided to us, you should contact us by clicking: Webform (you will be taken to a separate webpage). Back to top ACCESS AND CONTROL OF INFORMATION YOU HAVE PROVIDED TO US You may request to access, correct, update or delete the personal information you have provided to us by clicking: Webform (you will be taken to a separate webpage). We may limit or deny access to information where providing such access is unreasonably burdensome or expensive under the circumstances, or as we otherwise deem appropriate. In addition, please note that we may not be able to edit or delete your information stored with our third-party service providers, or we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). You may also opt-out of marketing emails or communications by clicking: Webform (you will be taken to a separate webpage). Choices for Cookies. See the section on “How We Collect Information” and “Data Collected and Use by Third Parties” for cookies and advertising controls. Back to top OTHER INFORMATION We may use or share non-personal information, aggregated information, de-identified or pseudonymized information, and statistical information for any lawful purpose. Any obligations or restrictions contained in this Privacy Statement do not apply to such information. Back to top CHILDREN Our Services are not directed at children or intended to be used by children. Do not send any information about yourself to us if you are under the age of sixteen (16). In addition, if we learn a person under the age of thirteen (13) has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately at dprivacy@forddirect.com. Back to top YOUR CALIFORNIA PRIVACY RIGHTS California Consumer Privacy Act (“CCPA”) If you are a California resident and the processing of personal information about you is subject to the CCPA, you have certain rights with respect to that information. Categories of Personal Information. Below please find the categories of personal information we have collected in the past 12 months: Category Examples Collected Do we disclose for business purpose Do we sell Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address or other similar identifiers. YES YES YES Commercial Information Records of personal property, products or services purchased, obtained, or considered or other purchasing or consuming histories or tendencies. YES YES YES Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e) A name, signature, address, or telephone number YES YES YES Protected classification characteristics under California or federal law Age or sex (gender) information. YES YES NO Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application or advertisement. YES YES YES Sensory data Audio or similar information (from phone calls). YES YES NO Geolocation data Physical location or movements about an individual or device. YES YES YES Professional or employment-related information Current FordDirect employment or performance evaluations. YES YES NO Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, predispositions, behavior, or attitudes. YES YES YES For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section above. Purposes for Collecting and Using Personal Information. Generally, FordDirect may use some or all of the above categories of personal information for its business and commercial purposes. For more information with respect to how we use your information, review the “How We Use Your Information” section above. Categories of Third Parties with which We Share Personal Information. In the past 12 months, FordDirect has d isclosed the personal information to the following categories of third parties: social media (e.g. Facebook, etc.) website analytics providers (e.g. Google, Adobe etc.) marketing and advertising partners Dealers Note that the CCPA defines “sell” very broadly, and some of our data sharing described in this Privacy Statement may be considered a “sale” under that definition. To the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in this Privacy Statement, we will comply with applicable law as to such activity. Categories of Personal Information We Have Sold. In the past 12 months, FordDirect has sold the following categories of personal information: Identifiers; commercial information; personal information categories listed in the California Customer Records statute; protected classification characteristics under California or federal law; internet or other similar network activity; geolocation data; and inferences drawn from other personal information. Access/Right to Know. You have a right to request that we provide you with the following information, the: specific pieces of personal information that we have collected about you; categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of personal information that we sold or disclosed for a business purpose about you; categories of third parties to whome the personal information was sold or disclosed for a business purpose; and business or commercial purpose for collecting or selling personal information. Right to Delete. You also have a right to request that we delete your personal information under certain circumstances, subject to a number of exceptions. Right to Opt-Out. To the extent we sell your data as the term “sell” is defined under CCPA, you also have a right to opt-out from the sales of personal information, which you can exercise by clicking the “Do Not Sell My Personal Information” link on the homepage of our website and completing the webform. In addition to clicking “Do Not Sell My Personal Information” link, you will need to separately opt out of cookies on each of our websites to stop tracking. For more information see the section on “How We Collect Information” and “Data Collection and Use by Third Parties” for cookies and advertising controls to learn how to opt out of analytics and ad targeting. How to Exercise Your CCPA Rights. You can exercise your CCPA rights by submitting your request(s) to us using the webform located at www.ford.com/help/privacy/ccpa. You can also exercise your CCPA rights by calling Ford Motor Company, toll-free, at 1-888-459-1291, Monday through Friday from 5:00 am until 8:00 pm Pacific time or Saturday from 5:00 am until 5:00 pm Pacific time. Our call center will be closed on Sundays and on New Year’s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, the day after Thanksgiving, and Christmas Day. If you want to exercise more than one of your CCPA rights, please submit a separate request for each CCPA right, which will help us handle your requests more effectively. Please be aware that we will process your requests in the order they receive them. We will endeavor to respond to verified and valid requests within 45 calendar days. Please be aware there might be circumstances where we will not honor your request, as permitted under the CCPA. For example, if we are not able to verify your identity or you are not a California resident, we may not honor your access or deletion request. In addition, we may not delete your personal information if an exception under the CCPA applies. If personal information about you has been processed by us as a service provider on behalf of a Dealer and you wish to exercise any rights you have with such personal information, please inquire with the Dealer directly. If you wish to make your request directly to us, please provide the name of the Dealer on whose behalf we processed your personal information. We will refer your request to the Dealer and will support them to the extent required by applicable law in responding to your request. Verification Process. Whether you use the webform or call, Ford Motor Company will need information from you to process your request so that we can confirm you are a California resident, determine if we have personal information about you, and, for access and deletion requests, verify your identity. Ford Motor Company may also need to contact you about your request, and you can choose the contact method you would like them to use. Authorized Agents. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, Ford Motor Company will require the agent to provide proof you have authorized he/she to act on your behalf, and they may need you to verify your identity directly with them. If you want an authorized agent to submit a right to know or deletion request on your behalf, the authorized agent must provide proof of their registration with the California Secretary of State, as well as proof that you gave the authorized agent written permission to submit the request(s) on your behalf. Ford Motor Company may also require you to verify your identity with them. If you want an authorized agent to submit an opt out of sale request on your behalf, the authorized agent must provide proof of their registration with the California Secretary of State, as well as proof that you gave the authorized agent written permission to submit the instruction on your behalf. California Minors. FordDirect does not knowingly sell the personal information of minors under 16 years of age without affirmative authorization. Non-Discrimination. FordDirect will not discriminate against you for exercising your rights under CCPA, including: denying you goods or services; providing a different level of goods or services; or charging you different prices or rates for goods or services. Disability Notice. If you have a disability and would like to access this Privacy Statement in an alternative format, please contact us at dprivacy@forddirect.com. Annual CCPA Metrics. As of July 1, 2021, the following metrics for consumer requests to Ford Motor Company and FordDirect cover January 1, 2020 through December 31, 2020 and are located in this link. California “Shine the Light” Law. Under California’s “Shine the Light” law, California residents may also request that we provide to you: a list of the categories of personal information about you that FordDirect has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request; and a list of the categories of third parties to whom we disclosed such personal information. To submit your request, please email dprivacy@forddirect.com and reference “Shine the Light” in the subject line or write us at the postal address in the section below entitled “Contacting FordDirect.” FordDirect will provide the requested information to you via email or mail. Back to top YOUR NEVADA PRIVACY RIGHTS If you are a Nevada resident, you have the right to opt-out of the sale of personal information to third parties that is collected by FordDirect. To submit your request, please click: Webform (you will be taken to a separate webpage). Back to top NON-U.S. USERS This is a U.S. website, and this site and our Services are subject to U.S. laws, including those governing the privacy and security of your information. If you use or interact with the Services, you are transferring your information to FordDirect in the United States. By using the Services or providing your information to us through the Services you consent to the transfer of your personal information to the United States, and our handling of your information in accordance with applicable U.S. requirements. Back to top CHANGES TO THIS PRIVACY STATEMENT In the future, we may change our Privacy Statement, and we will post the new Privacy Statement on www.forddirectprivacy.com and provide a link to the previous version of the Privacy Statement. You agree to the new Privacy Statement by continuing to use or interact with the Services unless prohibited by law. Back to top RETENTION OF YOUR INFORMATION We retain your information for as long as it is necessary and relevant for the purposes described in this Privacy Statement. The information we retain about you will be handled in accordance with this Privacy Statement. Back to top CONTACTING FORDDIRECT If you have any questions, comments, or concerns about our information practices or this Privacy Statement, please email us at dprivacy@forddirect.com or write to us at: FordDirect Legal and Compliance Department Attn: Data Privacy 4 Parklane Blvd, Suite 140 Dearborn, MI 48126 Back to top