PRIVACY POLICY

As your Connected Vehicle Services provider, ATX Group, Inc. ("ATX") takes your privacy very seriously. The following Privacy Policy ("Policy") governs the information gathering and dissemination practices related to the provision of Connected Vehicle Services to system subscribers. This Policy supplements any Subscriber Agreement you have with ATX, and any privacy provisions contained therein. Please read this Policy carefully. Please note that this Policy may be changed from time to time, and that any changes will supersede the current Policy.

1. The Information We Collect

Our primary goal in collecting personal information from you is to facilitate the provision of Connected Vehicle Services. As a general rule, Connected Vehicle Services are activated if you place a call to our Response Center or to the Mercedes-Benz Customer Assistance Center via the Information or Roadside Assistance buttons, if an airbag or seat belt emergency device in your vehicle deploys, if the response center receives an alarm notification from your vehicle or if you or someone you authorize on your behalf reports to us that your vehicle has been stolen (and a stolen vehicle police report has been filed. In addition to the information you provided with your Subscriber Agreement, when the Connected Vehicle Services are activated, we may collect and/or develop, and retain, the following information: your location, direction, and other parameters, caller identification, date and time of call and any operator comments. From time to time, we may also randomly monitor or record any conversation you have with our Response Center for quality assurance purposes.

2. Use of Your Information

It is our policy to use the information we collect from you for purposes of delivering the Connected Vehicle Services to you. We may also use your information for a statistical analysis of service usage, to improve our product offerings, to customize the services and to maintain contact with you directly or through your Mercedes-Benz dealer. We do not sell, rent or trade your information to others.

3. Disclosure of Your Information

To Provide the Connected Vehicle Services ATX shares your information with Mercedes-Benz Customer Assistance Center, roadside assistance providers, emergency service providers (e.g., 9-1-1) and other service providers (e.g., concierge services) only for the purpose of delivering the services to you. We may share information about activations of the services with your Mercedes-Benz dealer in order to allow the dealer to contact you. We also share pertinent information with the authorities in cases of stolen vehicle tracking.

For Other Purposes. We may also provide aggregate statistics about our subscribers and related Connected Vehicle Services information to third-party vendors, but these statistics will not include any personal identifying information. When required we may release information to comply with the law or orders of courts or other governmental authorities, or to enforce or apply the terms of our agreements with you. For example, we may be legally compelled to provide location data and other information to law enforcement agencies, pursuant to validly issued subpoenas or court orders.

4. Updating or Changing Your Account Information

You may modify, correct, change or update the information you provide upon activation of the Connected Vehicle Services, or at any other time upon request. To modify this information, please send an email with your new information to customercare@vehicleresponsecenter.com or write to the Response Center at ATX Group, Inc., 8550 Freeport Parkway, Irving, TX 75063, Attn: Customer Care.

5. Protection of Subscriber Information

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

6. Security on the Cellular Telephone Network.

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

7. Your Consent

By using Connected Vehicle Services, you agree to the practices and procedures described in this Policy. We may change this Policy at any time by posting a notice on the Owner’s web site located at www.vehicleresponsecenter.com. You can access the current Policy at that web site, or by requesting a copy from ATX at customercare@vehicleresponsecenter.com or 1-800-756-9018. Your continued use of Connected Vehicle Services after any such change is made constitutes acceptance of the terms of the modified Policy. You also consent to our contacting you in your vehicle or at your address on file for the purpose of delivering Connected Vehicle Services to you and to discuss your account.

8. Your Comments

We welcome feedback concerning this Policy. Please send your comments and questions to privacyofficer@vehicleresponsecenter.com or 972-753-6230.