LAST UPDATE: January 1, 2020

This Policy describes the privacy practices of the Indian Motorcycle brand. We respect your privacy and value our relationship with you.

This Indian Motorcycle Privacy Policy (“Policy”) describes how we collect, use, and share your information when you use or interact with us through: our website, mobile application, or online services (the “Sites”); our retail stores; and other offline methods, such as in person, by telephone, or at events. It also covers information we receive from our dealers, distributors, service providers, business partners, and other third-party sources.

1. INFORMATION WE COLLECT
We may collect the following types of information:
Contact and identification information, such as name, address, email address, telephone number, account login information (including, if applicable, social media account information for login purposes), signature, driver’s license information, and social security number.
Demographic information, such as gender, age or date of birth, marital status, military or veteran status, race or national origin, household composition, professional, education, or employment-related information, and information about your interests.
Financial information, such as payment card information (e.g. credit or debit card number, CVV code, expiration date), financial account information, payment history, and information related to your creditworthiness, assets, income, or liabilities.
Information about your vehicles, products, and relationship with us, such as vehicle license plate number, VIN, make, model, and year; selling and servicing dealers; date of purchase, rental, or lease; financing, rental, or lease term; serial number or other unique product identifiers (e.g. part number, UPC); service history; mileage, oil/battery status, fuel or charging history, electrical system function, gear status, and diagnostic trouble codes; purchase information and history; loyalty program information; and information about how you interact with us, including how you interact with our vehicles, products and services.
Internet or other network or device activity, such as information about the browsers and devices you use to access our Sites, emails, and advertisements (e.g. device type, browser type and language, hardware model, operating system version, unique device identifiers, and IP address) and how you interact with our Sites, emails, and advertisements (e.g. features used, content viewed, addresses of referring websites, and the dates and times of your interactions).
Location information. When you use our Sites and services we may collect and process location information, including precise geolocation information, as described below.
Audio, electronic, visual or similar information, such as your communications with us; photos, videos or other content you submit to us or post on our Sites or services, for example, in connection with a sweepstakes or contest; and footage from cameras in our retail stores and facilities, collected as described below.
Other information that identifies or can be reasonably associated with you.
2. HOW WE COLLECT INFORMATION
We generally collect your information in three ways: (1) when you provide it to us; (2) when we collect it automatically; and (3) and when we receive it from other sources.

Information you provide to us. Some examples of when you provide us information include when you: submit information on our Sites; participate in an event, sweepstakes, contest, other or promotion; purchase vehicles, products, or services on our Sites or in our retail stores; and communicate with us. Some examples of the types of information you provide us include: contact and identification information; demographic information; financial information; information about your vehicles and products; and audio, electronic, or visual information.

Information collected automatically. Some examples of information we collect automatically include:

Device and usage information. We may collect technical data about the browsers and devices you use to access our Sites, emails, and advertisements, such as, device type, browser type and language, hardware model, operating system version, unique device identifiers, IP address, device event information (e.g. hardware settings, date and time of your request, referral URL, crashes, and system activity). We may also collect information about how you interact with our Sites, emails, and advertisements, such as features used, content viewed, and the dates and times of your interactions. This information is collected automatically as you access the Sites, emails, and advertisements.

Cookies and similar technologies. Cookies and similar technologies are pieces of information stored directly on the device you are using.
Cookies allow us to collect information such as browser type, time spent on the Sites, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your online experience and our marketing and advertising efforts. In addition, we use cookies to gather statistical information about usage of the Sites in order to improve their design and functionality, understand how they are used, and assist us with resolving questions about them.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. If you set your browser to reject cookies, parts of the Sites may not work for you.

Pixel tags, web beacons, clear GIFs, or other similar technologies. These may be used in connection with some of our Sites, emails, or advertisements, to, for example, track the actions of Site users, compile statistics about Site usage and response rates, determine whether you have opened and acted upon our emails, and assess the effectiveness of our marketing.

Analytics and advertising. We use third-party analytics services that use cookies and similar technologies to better understand how users engage with our Sites, including services provided by Google and Adobe. Please visit http://www.google.com/policies/privacy/partners/ and http://www.adobe.com/privacy/marketing-cloud.html for more information about how Google and Adobe collect and use data when you use their partners’ websites or mobile applications.

We also use third-party advertising services to provide advertisements for Indian Motorcycle products or services that may be of interest to you when you visit websites or other online services. We allow select third parties, including these analytics and advertising services, to place cookies on our Sites. These third parties may collect information about your online activities over time and across third-party websites, and they may be members of industry self-regulatory groups such as the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), and European Digital Advertising Alliance (eDAA). The websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.

Do Not Track requests. Some browsers may transmit “Do Not Track” (“DNT”) signals to the websites you visit. Because there is not common agreement about how to interpret DNT signals, we do not take action in response to them.

Location information: We may collect information about the location of your device, including precise geolocation information from your device and imprecise location from, for example, your IP address.

When you participate in one of our demo rides, or an Indian Motorcycle Meeting, or similar rental experience, the vehicle that you use may be equipped with GPS-tracking and other technology that may collect information related to the state of the vehicle, including, for example, the vehicle’s location, speed, and rate of braking or acceleration. Indian Motorcycle may use this information to provide roadside assistance, to locate lost or stolen vehicles, and as otherwise described in this Policy.

Facility cameras: We may use cameras in and around our retail stores and other facilities for security purposes and operational purposes such as measuring traffic patterns, tracking in-stock levels, and helping us to better design our stores and facilities and serve our customers.

Purchase information and history: We may collect information about your transactions in our stores and on our Sites, including, for example: the vehicles, products and services you purchase, and how frequently you purchase them; the price and any promotions or rewards associated with a purchase; and the items you have placed on your “wishlist” or saved for future purchases.

Information we receive from other sources. We may combine the information that you provide us and that we collect automatically with information that we collect from other sources, such as our dealers, distributors, the business partners we work with to make certain products and services available to you (as described below), consumer data resellers, and other third-party sources.

For example, we receive information from our dealers, distributors, and business partners, such as contact and identification information; financial information; and information about vehicles, products, and website content or services that you have viewed, inquired about, or purchased. Our independent dealers, third-party distributors, and business partners are separate legal entities with their own privacy practices. For questions about the privacy practices of a dealer, distributor, or business partner you interact with, please contact them directly.

We may also obtain demographic and other information about you from consumer data resellers and other third-party sources. This information allows us to enhance our existing information for accuracy, security, and other purposes, such as increasing the relevance of our marketing, improving our communications with you, personalizing your experience with our Sites and services, and detecting fraud.

Some information we collect from third-party sources is publicly available. For example, we may collect information that you or others submit in a public forum, such as a blog, social network, or chat room.

We also create information ourselves when we analyze the information we have collected about you. And we combine information that we collect about you, as described above, with information that we collect in other contexts, such as information we collect through our Ride Command services, which are subject to a separate privacy notice.

3. HOW WE MAY USE INFORMATION WE COLLECT
We may use the information we collect to:
Provide, maintain, protect, and improve our vehicles, products, services and Sites. This may include, for example, customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; analyzing how they are used; and evaluating, maintaining, and improving their performance, effectiveness, security, and safety.

Develop new vehicles, products, services, and Sites.

Process payments and transactions.

Promote our vehicles, products, services, and Sites. This may include, for example, developing and providing promotional and advertising materials about the Indian Motorcycle brand that may be of interest to you; analyzing the effectiveness of those materials; and customizing and improving them.

Communicate and manage our relationship with you. This may include, for example, providing you information about our vehicles, products, services, and Sites, and your transactions with us; responding to questions, inquiries, and service requests that you make; customizing and improving our communications with you and analyzing their effectiveness; communicating with you about, and administering your participation in, sweepstakes, contests, surveys, promotions, events, and similar activities.

Address warranty claims and provide vehicle and product service and support. This may include, for example, investigating, validating, responding to, and administering warranty claims; providing vehicle and other product service and maintenance information and support; and providing recall and safety bulletin information.

Address legal issues. This may include, for example, obtaining legal advice and establishing, exercising, or defending legal claims; complying with laws, regulatory requirements, contractual obligations, court orders, other legal process or obligations, or lawful requests from public and government authorities; detecting, preventing, and responding to fraud, intellectual property infringement, security issues, violations of our agreements, violations of law, or other misuse of our vehicles, products, services, or Sites; and protecting the safety, rights, welfare, or property of Indian Motorcycle, you, or others.
We may also use your information for other internal Indian Motorcycle business operations, as permitted by applicable law, and other uses consistent with the context in which the information was collected or with your consent.

We may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

Communications. Communications with you in connection with these uses may be via different methods, such as mail, telephone, email, text message, social media, or other electronic messages, or via our Sites.

4. HOW INFORMATION WE COLLECT MAY BE SHARED
We may share your information as follows:
Indian Motorcycle company. We may share your information among the Indian Motorcycle company, including Indian Motorcycle Co. subsidiaries and affiliates, which may be located in other countries. We may share your information among the Indian Motorcycle company for various purposes, including, for example, to promote vehicles, products, and services from the Indian Motorcycle company, and for research and development purposes.

Vendors. We may share your information with third parties who provide services to us, such as Site hosting; data analysis; IT services; payment processing; fraud monitoring; services related to product development and maintenance; and communications, marketing, and online and offline advertising services.

Dealers and distributors. We may share your information with our dealers and distributors for various purposes, including, for example, to provide you information about vehicles, products, services, or promotions that may be of interest to you; to help our dealers and distributors serve you better; and to provide you with warranty, recall, and service information. Our independent dealers and third-party distributors are separate legal entities with their own privacy practices. For questions about the privacy practices of a dealer or distributor you interact with, including how to opt out of marketing communications from them, please contact them directly.

Business partners. To make certain products and services – such as Indian Motorcycle Rentals, online prequalification for vehicle or product financing, and financing for vehicle or product purchases – available to you, we work closely with independent business partners. When you schedule and use services provided by these business partners, we may share your information with them or you may provide it to them directly. We may also share your information with independent business partners when we work with them to sponsor sweepstakes, contests, events, and other promotions. This Policy does not address, and we are not responsible for, the privacy, information, or other practices of these business partners. We encourage you to review the privacy policies of any third-party business partners whose services you reserve or obtain through our Sites or services.

Legal reasons. We may share your information with third parties when we have a good faith belief that disclosure is necessary to: obtain legal advice or establish, exercise, or defend legal claims; comply with laws, regulatory requirements, contractual obligations, court orders, or other legal process or obligations, or lawful requests from public and government authorities; detect, prevent, or respond to fraud, intellectual property infringement, security issues, violations of our agreements or law, or other misuse of our vehicles, products, services, or Sites; protect the safety, rights, welfare, or property of Indian Motorcycle, you, or others, as required or permitted by applicable law.
Business transfers. We may share your information with third parties in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
When you post information to our Sites. When you post or share information on our Sites, the information you post or share, including information that may identify you, may be seen by other visitors to our Sites, including the public when those Sites are publicly available.

Otherwise with your consent. We may share your information with third parties when we have your consent to do so.
We may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.

5. THIRD PARTY SITES AND PLUGINS
Our Sites may contain links to external websites, mobile applications, or third-party services that are not operated by Indian Motorcycle, and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a service and do not imply any endorsement of the related websites, mobile applications, third-party services, or social media platforms (“Third-Party Sites”), nor any association with their operators, and we are not responsible for the privacy or other policies or practices of those Third-Party Sites. To learn about the information collected by Third-Party Sites, please visit their privacy policies.

6. INFORMATION SECURITY
We maintain technical and organizational security measures designed to help protect your personal information from unauthorized access, disclosure, alteration, or destruction. Unfortunately, no data transmission or storage system is 100% secure or error free, and we cannot guarantee the security of the information we collect.

7. DATA RETENTION
We retain your personal information as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law.

To determine the period for which your personal information will be retained, Indian Motorcycle considers criteria such as: (i) the nature of our relationship with you and the types of vehicles, products, or services we have provided to you, or you have requested; (ii) the sensitivity of the information and the purposes for which it was collected; (iii) the nature and timing of your interactions with us (including with our Sites, communications, etc.); (iv) any applicable legal or contractual requirements to retain information for a certain period of time, including any retention obligations related to actual or potential litigation or government investigations; and (v) the impact on the vehicles, products, and services we provide if the relevant information were deleted.

8. CHOICES
You have certain choices about the information you provide and how it is used and shared. For example, you can:
Choose not to provide certain information requested. Please note that not providing such information may limit the functionality or benefits of our Sites or services.

Review and control certain types of information tied to your account(s) with us.

Choose to opt out of marketing communications from us. Depending on applicable law where you live and your relationship with us, you may be automatically subscribed to marketing emails or need to sign up for them to receive them. You may opt out of receiving marketing emails by using the unsubscribe information in the marketing emails you receive. You may also opt out of receiving marketing communications by submitting a request at http://indianmotorcycles.ro/contact-us

In your request, please include your first and last name, the brand and types of marketing communications you would like to opt out of, and your contact information relevant to those communications (e.g. mailing address for postal mail or email address for email). Please note that you may not opt out of receiving non-marketing communications. Some examples of non-marketing communications include: communications about an order or transaction; customer-service communications; and service or recall information.
When our mobile applications use your device’s location information, you can adjust the location settings of your mobile device at any time to control whether your device communicates this information, and you may have the option to adjust the permissions in the app. Please note that device location may be derived from your device’s Wi-Fi, Bluetooth, and other device settings. See your device settings for more information.

When our mobile applications allow for the delivery of “push notifications,” you may choose to receive or stop them at any time by adjusting the settings on your mobile device, and you may have the option to adjust the permissions in the app.
9. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA
The controllers for personal data covered by this Policy are ASP Group East Ltd., 307-309 Odaii Road, District 1, Bucharest RO 013604.
The contact information for Indian Motorcycle data protection officer is:

By mail: ASP Group East Ltd., 307-309 Odaii Road, District 1, Bucharest, Romania 013604
Attention: EU Data Protection Officer
By email: info@indianmotorcycles.ro

Indian Motorycle’ Lawful Basis for Processing Your Personal Information
Our lawful basis for processing personal data covered by this Policy will depend on the purposes of the processing. To the extent we process personal data because it is necessary to perform a contract with you, our legal basis for that processing is that it is necessary for the performance of a contract with you.
When we are required to share personal data with law enforcement agencies or other governmental bodies, or we otherwise process personal data to comply with our legal obligations, we do so on the legal basis that we are under a legal obligation to do so.
We use consent as our basis for processing to the extent required by applicable law, or as we otherwise deem appropriate, for example, before we collect geolocation information from your mobile device.
We also process personal data on the lawful basis that it is necessary for Indian Motorcycle’ legitimate business interests, which may include: providing, improving, developing, and promoting our vehicles, products, services, and Sites; communicating with and otherwise managing our relationship with you; enhancing the safety and security of our vehicles, products, services, Sites, employees, and others; and protecting Polaris and our business partners from wrongful conduct.

Your Individual Rights
In accordance with applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances, and may be limited by local law: (i) right of access, (ii) right to correction, (iii) right to erasure, (iv) right to restriction of processing, (v) right to data portability, (vi) right to object to certain types of processing, and (vii) right to withdraw consent to certain types of processing. Most of these rights are not absolute. You may exercise these rights by submitting a request to us using this request form. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. Please note that we may ask for additional information to verify your request before responding to it.
We will seek to address any complaints submitted to us using the contact information listed in the “Contacting Us” section below. In addition, you have the right to lodge a complaint with your local supervisory authority or regulator.

10. WHERE WE PROCESS INFORMATION
We may process your information in Romania and other locations around the world. Those countries may not have the same level of protection for your personal information as your country. By using our Sites or services or otherwise providing us your information, you acknowledge and understand that your information will be transferred to and processed in Romania and these other countries.

11. MINORS
We do not intentionally collect information from children under the age of 14, or the relevant minimum age under applicable local law. The Sites are not directed to or intended to be used by children under the age of 14, and we request that children under the age of 14 not provide personal information through the Sites.

12. UPDATES TO THIS POLICY
We may change this Policy. Please review the “Last Updated” legend at the top of this Policy to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. We encourage you to look for updates and changes to this Policy by checking this date when you access our Sites and services.

13. CONTACTING US
If you have any questions about this Policy, please contact us using the contact information below:
For residents of the European Economic Area, our contact information is:

By mail: ASP Group East Ltd., 307-309 Odaii Road, District 1, Bucharest, Romania 013604
Attention: EU Data Protection Officer
By email: info@indianmotorcycles.ro

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