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Subaru Privacy Policy
Last Updated October 14, 2020.
Your privacy is important to Subaru of America, Inc. ("Subaru", “we”, “us” or “our”). This Privacy Policy explains how Subaru collects, uses, shares and endeavors to protect your information. Subaru reserves the right to change this Privacy Policy from time to time, and such changes will be effective immediately upon posting to this website. We suggest periodically visiting this page to review our policy.
This Privacy Policy applies when Subaru collects information from and about individuals, including through Subaru-controlled websites or applications, and through Subaru-controlled applications and services accessed or used on a mobile, handheld or other device, and in and through your vehicle (collectively, the “Service”). It also applies to information individuals voluntarily provide to us "offline," such as at events. This Privacy Policy explains the privacy practices of Subaru including: (1) how Subaru uses the personal information you share with us, that we collect, and that we learn about you from third parties; (2) how Subaru uses "cookies" and similar technology; (3) what personal information Subaru may share about you and in what circumstances; (4) what kind of security measures Subaru takes to protect your information and what steps Subaru will take in the event of a security breach; and (5) your rights and choices regarding your personal information including the process through which you can change the Personal Information that Subaru retains in its records and to modify your preferences.
"Personal Information" includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. By disclosing your Personal Information to us, using our Services or interacting with us offline, you consent to our collection and use of your Personal Information in a manner that is consistent with applicable law and this Privacy Policy, as well as our Terms of Service. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If you are a California resident please see the “Additional Disclosures for California Residents” section.
INFORMATION WE COLLECT AND HOW WE USE IT
Subaru collects and uses the information you provide to us. We may also obtain information about you from outside sources. For the specific categories of information Subaru collects, please see the chart detailed under the California Notice of Collection below, which identifies the categories of information Subaru collects from you, regardless of whether you are a California resident. In addition, we automatically collect the following categories of information in the last 12 months: when you use our Service.
- Cookies. Cookies are small lines of text/data that are written onto your computer by a website. Subaru or others acting on our behalf may use cookies, pixel tags, web beacons or other similar technologies in connection with the operation of our Service. These technologies may collect and store information. We utilize these technologies to research and understand how our Service is used, to develop our products and services, to personalize your online experience with Subaru and for general advertising and marketing purposes. For example, we track such information as the time and the length of visit of our Service, the web pages you view or download and the name of your Internet Service Provider. It is possible that cookies placed by Subaru or its vendors or suppliers (as applicable) in connection with the operation of the Service may remain stored on your computer until you remove them. Most browsers accept cookies by default.
- Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
- App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include tracking mechanisms, which is code that sends information about your use to a server.
- Log Files, which are files that record events that occur in connection with your use of the Service.
- Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location.
- Device Profile, which is the process of analyzing and combining sets of information elements from your device’s browser in order to create a “profile” of your device and uniquely identify your browser and device. When multiple devices are used by the same person to access Subaru-controlled websites and/or applications, we may link those devices. For more information about device linking or for information on how to opt-out of this linking, please go to https://cross-device-privacy.adobe.com.
- Online Behavioral Advertising. Subaru may use information collected through the use of its Service for online behavioral advertising purposes, that is, to customize ads to you when you visit other (non-Subaru) sites.
- Notwithstanding any other provision in this Privacy Policy, we may also engage a third party partner for the purpose of recognizing users and delivering to them interest-based content and advertisements. Our partners also may collect information from you, such as your IP address and information about your browser or operating system; may combine our personal and non-personal offline information about you with information from other partners in data sharing cooperatives in which we participate; and may place or recognize a unique cookie on your browser. These cookies contain no personally identifiable information; but they may contain demographic or other data in de-identified form. To opt-out of third party cookies, please go to http://www.aboutads.info/choices.
We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:
- Liking, Sharing, and Logging-In. We may embed a pixel or other tracking mechanism on our Service that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
- Brand Pages. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Subaru in a tweet or post), we may use your reference on or in connection with our Service.
Use of Information
We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for using information, including but not limited to in the last 12 months, include the following:
- As a general matter, we may use or share your Personal Information where it is necessary for us to manage our Service, including your registration and account (for example on MySubaru.com), complete a transaction or do something that you have asked us to do, such as provide customer support or respond to your comments, questions, and requests.
- MySubaru.com is a vehicle owners' personalized webpage on Subaru.com that owners can use to keep track of their vehicle service records, receive maintenance reminders, recall notices and overall communications from Subaru. Personal Information provided on MySubaru may be used to carry out the request or service for which the information is submitted. We may also use the information you provide in online registration forms to notify you periodically about important matters like Service updates, a change to our Privacy Policy or notice of a security breach, and to provide information about new Subaru products and services, and special offers and promotions that may be of interest to you.
- Processing Your Requests. When you interact with us (for example, to request a brochure or locate a retailer) you will be asked for information needed to complete your request. The information you provide is used to process your transactions, to create and share reports about these transactions, and/or to provide related customer service. When you request a quote or other information, these requests may be conducted through retailers or Subaru vendors and suppliers.
- Events and Promotions. We may use your information as required if you elect to participate in events and promotions. You may be asked to provide an email address or other Personal Information at an event or for entry into a particular promotion (including sweepstakes and contests). The information we collect from you during the course of the promotion will be used as described in the Official Rules or the Terms for that promotion and may also be used by us for marketing purposes. Certain promotions may be run by a Subaru service provider or vendor or co-branded with one of our partners or run on a third party site like Facebook. In these instances a third party, rather than Subaru, may collect your Personal Information. The promotion will state the policies governing the collection of such information if they should differ from this Privacy Policy or if a third party will be collecting such information.
- Website or Application Usage. We, and our service providers, may observe your activities, preferences, and transactional data (such as your IP address and browser type) as well as pages you have viewed during your use of our Website or Application. We may use this data for any purpose unless we tell you otherwise in connection with a particular Website or Application. While we may collect or log this information, we do not identify you except if we believe doing so will help us better respond to a request you have made such as for a quote, identification of a local retailer, or similar request. Where such non-Personal Information is linked to your Personal Information we will treat such information as Personal Information.
- Location Data. Some parts of our Service may capture and record certain location-data regarding your use of our Service and your travels in order to provide location-related functionality ("Location Data"). We may link that Location Data to other information that you provide to us or that may be accessed in connection with your use of such a Subaru Website or Application. Your use of, and our ability to offer location based functionality is then enabled through our use and disclosure to third parties of Location Data and associated information.
- We may communicate with you to provide you with information we think may be of interest to you as well as technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- We may also use your information for our internal research purposes as we develop our products and services.
- We may use Personal Information and data collected for our advertising or marketing purposes including on other websites or media.
WHEN SUBARU MAY SHARE INFORMATION
Subaru may share aggregated non-personal information about the users of its Service (in a form that does not reasonably identify users or households) with service providers, vendors, suppliers and other third parties.
In addition, Subaru may disclose and share users’ Personal Information in accordance with the practices described in this Privacy Policy. The categories of entities to whom we disclose information, including in the last 12 months include the following:
- Service Providers, Vendors, and Suppliers. Service providers, vendors and suppliers are companies who perform services for Subaru and its retailers, including in connection with the functionality of the Service. To the extent it is necessary for these entities to provide their products and services to us and provide products and services you have requested, these entities may have access to your Personal Information, but they are prohibited by us to use your Personal Information on their own behalf or for any purpose other than performing services for us. Subaru may sometimes permit authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, and related Service information. These transfers of aggregate statistics do not include your Personal Information.
- Retailers. Certain requests or questions that you direct to us are more appropriately answered by a retailer, such as a request for a price quote on a particular vehicle. In those instances, we will provide your Personal Information, along with your request or question, to a retailer or retailers for a response. The retailer(s) will have the right to use your Personal Information for purposes of responding to your request and for its/their own marketing purposes that may not relate to your requests or questions. Retailers' use of your Personal Information will be subject to the retailers' own privacy policies.
- Marketing Partners. Subaru occasionally partners with trusted third parties for promotions, events and other activities, and may share your Personal Information with such third parties for Subaru's marketing purposes and for the third parties' own marketing purposes unless you opt out of such sharing. The use of your Personal Information by such third parties will be subject to their own privacy policies.
- Public Areas. Any information disclosed in public areas of a Subaru Service or third party website (for example, through Facebook, YouTube, Twitter or other sites) will become public information. We cannot control the use of information disclosed in public forums, such as social media platforms, blogs, forums, wikis, chat rooms, and networking functions of mobile-device applications. You should exercise caution when disclosing information in these public areas, especially your Location Data, and be careful how you disclose your Personal Information.
- Mergers, Acquisitions, and Insolvency. If Subaru should ever file for bankruptcy or merge with another company, or if Subaru should decide to buy, sell, or reorganize some part or all of its business, Subaru may disclose your Personal Information, including to prospective or actual purchasers in connection with one of these transactions.
- As Required by Law and Other Extraordinary Disclosures. Subaru may be required to disclose your Personal Information if it: (i) 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, (ii) would potentially mitigate our liability in an actual or potential lawsuit or investigation, (iii) is otherwise necessary to protect our rights or property, or (iv) is necessary to protect the legal rights or property of others.
YOUR RIGHTS AND CHOICES
A. Account Information.
If you are a registered user of MySubaru, you may change or delete certain information in your profile by logging on to http://www.subaru.com/my-subaru/account.html or you may disable your account by going to the "Contact Us" form at Subaru.com. If you are a registered user of Meet An Owner, you may change or delete certain information in your profile by logging onto www.MeetAnOwner.com and following the prompts on your user page. You may disable your Meet an Owner account by sending an email to help@meetanowner.com. All other users may change or delete the Personal Information that is stored by Subaru by contacting the Subaru Customer Service Department at 1-800-782-2783 or by logging on to Subaru.com/contactus. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as permitted by law.
All users may opt-out of receiving marketing emails and newsletters at any time by changing their preferences (if registered), or by contacting the Subaru Customer Service Department at 1-800-782-2783 or by using the opt-out link located at the bottom of our emails.
Please note that we cannot change or delete information in the databases of third parties with whom we have already shared your Personal Information.
B. Communications
- Emails. All users may opt-out of receiving marketing emails and newsletters at any time by changing their preferences (if registered), or by contacting the Subaru Customer Service Department at 1-800-782-2783 or by using the opt-out link located at the bottom of our emails.
- Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.
Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
C. Tracking Technology Choices.
- Cookies and Pixels. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. Our service providers or vendors may also use cookies and related technologies in order to personalize your experiences and adapt a particular part of our Service's functionality to your preferences and other purposes. You may set your browser to notify you when you receive a cookie or to refuse receiving it. You should be aware that this may interfere with or make you unable to use certain functionality on websites using cookies. For example, many websites will ask your permission to use a cookie that will enable you to automatically log onto the website. Disabling or removing cookies may require you to manually log on each time you wish to visit that website. When multiple devices are used by the same person to access Subaru-controlled websites and/or applications, we may link those devices. For more information about device linking or for information on how to opt-out of this linking, please go to https://cross-device-privacy.adobe.com.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
D. Your Nevada Rights.
Nevada law (NRS 603A) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. Subaru does not engage in sales as defined under Nevada law.
CHILDREN
Subaru’s Service is intended for a general audience and not directed at children under (13) years of age.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If a person under 13 submits information through any part of a Subaru Service, and we learn the person submitting the information is a child, we will attempt to delete this information as soon as possible. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us as set out in the “Contact Us” Section below. We will remove the data to the extent required by applicable laws.
SECURITY AND DATA RETENTION
Transmission of data over the Internet is not 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. Subaru uses secure server software and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.
If Subaru learns of a breach in its security system that results in a disclosure of users' information, we may attempt to notify you electronically so that you can take appropriate protective steps. By providing Personal Information to us or using our Service, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. Subaru may post a notice on our Service if a security breach occurs. Subaru may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Subaru endeavors to retain the information that collects from and about its users only as long as necessary to fulfill a legitimate business need or as required by law.
LINKS TO THIRD-PARTY WEBSITES AND CO-BRANDED WEBSITES
Our Websites and Applications may contain links to third-party websites or may be co-branded. Please be aware that Subaru is not responsible for and cannot control the privacy practices of other websites or third parties. We encourage you to read the privacy policies for these other websites, as they may differ from ours. Our Websites and Applications may also be created and maintained by service providers or may contains links to co-branded websites that may display Subaru's logo and trademarks but which are maintained by third parties. Such websites may be identified by the fact that they do not display a Subaru (or Subaru brand) URL or they may have information identifying a third party as the host of the particular Website or Application. Please read the privacy policy on the co-branded website for the applicable privacy practices relating to personal information collected via that website, as it may differ from this Privacy Policy.
US MARKET ONLY
All information posted on our Service is intended for the US market only and will be interpreted and governed solely by US law. If you access this site from a location outside the US, you are responsible for compliance with all applicable non-US laws and regulations. Subaru distributes vehicles only in the United States (and excluding Hawaii). If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.
ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information including rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notice of rights California residents have and can exercise. This section describes the CCPA rights of California residents and explains how to exercise those rights.
A. California Notice of Collection
Within the past twelve (12) months, Subaru has collected the following categories of personal information from its consumers:
Category |
Examples |
Collected |
Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number or other similar identifiers. |
Yes |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, address, telephone number, driver’s license or state identification card number. |
Yes |
Protected classification characteristics under California or federal law. |
Medical condition, physical or mental disability |
No |
Commercial information |
Records of personal property, products or services purchased, obtained, or considered |
Yes |
Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
No |
Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
Yes |
Geolocation data. |
Physical location or movements. |
Yes |
Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
No |
Professional or employment-related information. |
Current or past job history or performance evaluations |
No |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
No |
Inferences drawn from other personal information. |
Profile reflecting a person’s preferences, characteristics, predispositions, behavior, or attitudes |
Yes |
For more information on information we collect, including the sources we receive information from, review the Information We Collect and How We Use It Section. We collect and use these categories of personal information for the business purposes described in the Use of Information section, including to provide and manage our Services.
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales as described below.
A. Disclosure of Personal Information for a Business Purpose
In the preceding twelve (12) months, Subaru has disclosed the following categories of personal information for a business purpose:
- Identifiers.
- California Customer Records personal information categories
- Protected classification characteristics under California or federal law
- Commercial information
- Internet or other similar network activity
- Geolocation data; and
- Inferences drawn from other personal information
We disclose these categories of personal information for a business purpose to the following categories of third parties:
- Service providers.
- Legal service providers and entities as required to comply with the law.
B. Sales of Personal Information
To the extent “sale” under the CCPA is interpreted to include any of our transfers and/or other data sharing described above as a “sale,” we will comply with applicable law as to such activity.
In the preceding twelve (12) months, we have sold or otherwise disclosed the following categories of personal information for commercial purposes:
- Identifiers.
- California Customer Records personal information categories
- Commercial information.
- Geolocation data
We sell these categories of personal information to the following categories of third parties:
- Third parties for marketing of third party’s own goods and/or services
C. Consumer Requests
You have the right to request that we disclose certain information to you about our collection of your personal information over the past 12 months, including: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information; (v) the specific pieces of personal information we collected about you. If we sold, or disclosed your personal information for a business purpose, you have the right to request that we disclose to you the personal information, by category, for each type of third party to whom such information was sold or disclosed.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. To exercise the access and deletion rights under the California Consumer Protection Act, please submit a request to us by either:
- Calling us at 1-800-782-2783; or
- Visiting CCPA Request
To the extent Subaru sells your personal information as the term “sell” is defined under the CCPA, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by either:
- Calling us at 1-800-782-2783; or
- Visiting Do Not Sell My Personal Information
We may require specific information from you to help us verify your identity and process your request, which may include, but may not be limited to, your name, contact information and Vehicle Identification Number, if applicable. Generally, when an authorized agent makes a request to know or a request to delete on behalf of the consumer, the following is required: (i) signed permission by the consumer that the consumer has authorized the agent to act on behalf of the consumer; (ii) the consumer must verify the consumer’s identify directly with SOA; and (iii) the consumer must directly confirm with SOA that the consumer has provided the authorized agent permission to submit the request. However, if the consumer has provided the authorized agent with power of attorney pursuant to Cal. Probate Code sections 4121 to 4130, the verification process is as follows: the authorized agent must provide written verification of such power of attorney and the agent must confirm the agent's identity in order to verify the request.
We will not discriminate against you for exercising any of your CCPA rights.
D. California Minors
We do not knowingly sell information of minors under 16 who are residents of California without their affirmative authorization, or the affirmative authorization of their parent or guardian for minors under 13.
California residents who are under 18 years of age and registered to use the Service may request removal of any content posted by them on the Service. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Minor” request. We may require additional information from you to allow us to verify your identity as well as details about where the content is posted. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
“SHINE THE LIGHT LAW”
Under California Civil Code Section 1798.83, also known as California's "Shine the Light Law," residents of California may request and receive, free of charge, a copy of Subaru's California Information Disclosure Notice for the previous calendar year. This Notice lists the third party entities with which Subaru shared Personal Information for the third parties' direct marketing purposes. To request this Notice, please go to the Contact Us page on this site.
QUESTIONS?
We are committed to protecting your privacy and to being transparent about how we use your information. We use the information we gather from this site to enhance your overall experience with Subaru. If you have any questions or concerns about our Privacy Policy, please contact us at 1-800-782-2783 or Subaru.com/contactus and we'll be happy to help in any way we can.
