LIVEWIRE DIGITAL PRIVACY POLICY
Last Revised: October 16th, 2023
At LiveWire EV, LLC (“LiveWire”) your privacy is important to us. Our Privacy Policy describes the information we collect, how we collect information, and the reasons we collect information. This Privacy Policy also describes the choices you have regarding the information LiveWire collects, including how you can manage, update, or request to delete information.
Please take a moment to review this Privacy Policy. You may scroll through this Privacy Policy or use the headings below. It is important that you understand this Privacy Policy. By using our Platform, you are agreeing to the terms of this Privacy Policy. If you have any questions or concerns about this Privacy Policy, you may Contact Us at any time.
CONTENTS
- Key Terms & Definitions and Our Privacy Policy
- Personal Information
- Children’s Privacy
- Data Security
- Supplemental Disclosures and Rights Based on State Law
- International Users
- Changes to our Privacy Policy
- Contact
- Glossary
1. Key Terms & Definitions and Our Privacy Policy
It is helpful to start by explaining some of our key terms and definitions used in this Privacy Policy.
“App(s)”: Our mobile application(s) available in the major app stores.
“Vehicle(s)”: Our connected motorcycles, charging devices, accessories and peripherals that connect to or interact with our Platform, including LiveWire ONE and S2 Del Mar bikes.
“Personal Information” or “Personal Data”: Information identifying, relating to or about an identified or identifiable individual, as described more fully in this Policy.
“Platform”: Our Website(s), App(s), Vehicle(s), and related functionality and online services, as applicable.
“Privacy Policy” or “Policy”: This privacy policy.
“Products”: Any parts, accessories, merchandise, apparel and other products available for purchase on or through our Platform, or that we otherwise provide or sell to you.
“Services”: Any services (including data, telematics, connected and related services) provided through our Platform, which may be for purchase at a charge, or included at no charge as part of our Platform, or that we otherwise provide or sell to you.
“Website”: Our website located at www.livewire.com.
“LiveWire,” “we,” “us”: LiveWire EV LLC.
Please refer to our Glossary for additional explanations of terms and phrases used in this Policy.
When does our Privacy Policy apply?
This Privacy Policy describes the types of information we may collect from you when you visit or use our Platform or any components of our Platform, and when we communicate with you electronically, such as through our Platform, email, text message and other electronic messages between LiveWire and you. Visitors to and users of our Platform who reside in the European Union should review our European Privacy Policy for additional information about how we collect, use, share, and otherwise process personal data of EU residents. (In the event of a conflict or inconsistency between the terms of this Privacy Policy and our EU Privacy Notice for Telemetry Data, the terms of the EU Privacy Notice for Telemetry Data will apply to residents of the EU.)
When does our Privacy Policy not apply?
This Privacy Policy does not apply to information (a) we collect from you through any in-person or face-to-face interactions we have with you, or through an audio-only telephone conversations; (b) by any other websites or platforms operated by us, unless the website or platform is listed above or links to this Privacy Policy; (c) collected by any third party website that we may provide a link to or that is accessible from our Platform; or (d) covered in part or in whole by a separate privacy policy provided by us (e.g., relating specifically to health information, financial information, other special information, etc.).
Terms of Use
This Privacy Policy is incorporated into and, for the Website, governed by our Terms of Use, which also apply when you use our Platform.
2. Personal Information
What is Personal Information?
Personal Information is information that you provide to us which personally identifies you, such as your name, email address, or billing information, or other data that can be reasonably linked to such information by LiveWire, such as information we associate with your LiveWire account.
What types of Personal Information do we collect?
As described in more detail throughout this Policy, we collect and use Personal Information in order to operate and provide our Platform to you including Products and/or Services. You may provide Personal Information to us, and we may collect Personal Information from you automatically as you use and navigate through our Platform.
How do we collect your Personal Information?
Information you provide to us. You may provide Personal Information to us through our Platform. For example, you may be able to register to use our Platform or create an account with us, which allows or requires you to provide certain information to us (e.g., contact information such as your name, email address, telephone number, etc.). You may also be able to purchase Products or Services, or make payments to us, through our Platform. In these situations, we collect your credit card, debit card or other payment card information or bank or other financial account information. We use third-party payment processors to collect and process your payment information. You provide Personal Information and other information to us when you contact us through our Platform.
Information we collect as you use our Platform. We collect Personal Information and information about the computers, devices, browsers and your Internet activity as you use and interact with our Platform. The information we collect includes Unique Identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, device type, crash reports, system activity, wireless carrier name (when you use a wireless or mobile device), and the date, time, and referrer URL of your request.
Online Activity. We collect information about your activity on our Platform, Internet, network, and other online activity information, such as browsing history, search history, and information regarding your interaction with our Platform and other websites. We use various technologies to collect and store location information, including cookies, pixels or pixel tags, local storage, such as browser web storage or application data caches, databases, session replay, and server logs.
Location. We collect information about your location when you use our Platform, which helps us provide our Platform Services, features and functionality. Your location can be determined with varying degrees of accuracy by:
- GPS
- IP address
- Sensor data from your device
- Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices
The types of location data we collect depend in part on your device and account settings. For example, you can turn your mobile device’s location on or off using the device’s settings app. You may also be able to turn on location history if you want to create a private map of where you go with your devices.
Third Party Sources. In some circumstances, LiveWire also collects information about you from publicly accessible sources. We may collect information about you from trusted partners, such as marketing partners who provide us with information about our potential customers, and security partners who provide us with information to protect against fraud and abuse of our Platform.
INFORMATION COLLECTED FROM VEHICLES, VEHICLE OWNERS AND MOBILE APP USERS
Personal Information Collected from Vehicles
LiveWire motorcycles are fully connected vehicles and collect specific data elements relating to the usage of your Vehicle. The following table provides an overview of data collected from your Vehicle, the App and/or your mobile device:
| Data Category | Description |
|---|---|
| Model Information | Make, platform, model, model year, vehicle identification number, propulsion type, wheel size, entitlement(s), enablement(s) |
| Vehicle Telemetry | Vehicle telemetry relating to vehicle performance, vehicle use, location data, elevation, speed, ride mode, high-voltage battery data, odometer value. |
| Charging Information | Charging network, charging station, charge type (where applicable), high-voltage battery analytics during charging and performance, charging status, and onboard charger performance |
| Diagnostics | Software and hardware data, data logs, and service-related events, and specific fault-related information, including whether bike has been immobilized, or software is mis-matched. |
| Stolen Vehicle Tracking | Vehicle identification number, subscription status, stolen vehicle status, location, immobilization status, alarm status |
| Geo-Location | Latitude and Longitude of the vehicle during different power or command states. |
Model Information
Model information provides LiveWire the ability to maintain a repository to enhance the accuracy of fleet distribution throughout multiple regions. Model information is used for several purposes, including to allow LiveWire to satisfy the requests of the customer in tracking enabled features and functionality where applied, software packages, hardware assignments, serial number assignments, and Vehicle configuration.
LiveWire will use this model information data for maintaining Vehicle AS BUILT and AS MAINTAINED databases. In addition, model information will be used to support the S2 mobile application, Vehicle software development, Vehicle software delivery and firmware over the air (FOTA) updates, and general periodic reporting.
Vehicle Telemetry
To support the optimum performance and steady operation of your LiveWire motorcycle, LiveWire will periodically collect specific information relating to usage, operation, and overall health of your LiveWire motorcycle. Such telemetry could include but not limited to odometer, high-voltage battery status, electric Vehicle range, component performance, and cellular network. In the event your LiveWire motorcycle encounters a service-related event, additional telemetry data may be collected. A service-related event may be defined as but not limited to:
- In the event your LiveWire motorcycle is involved in a collision
- In the event your LiveWire motorcycle encounters a software or hardware related issue
- In the event your Stolen Vehicle Tracking system is enabled (see sub-section Stolen Vehicle Tracking)
LiveWire Vehicle Telemetry Data Use will include use of diagnostic data for purposes of troubleshooting and the development of enhanced software to remedy potential issues. Additional data from connected LiveWire motorcycles will be aggregated for purposes of metric tracking. Examples include frequency of SPORT mode being engaged and days of the week LiveWire motorcycles are frequently and infrequently ridden. As LiveWire connected Vehicle technology continues to expand, key features (such as eCall in the EU) will become a standard in the event a LiveWire motorcycle is involved in an accident.
Charging Information
Charging information may be collected regarding location, charge level type (where applicable), high voltage battery data, and charging system performance. This useful data allows LiveWire to continuously improve the performance of your LiveWire motorcycle by means of delivering improved software to your Vehicle’s high voltage charging system. Location enables LiveWire to enhance our mobile application(s) and assist users in properly planning a route or simply locate the nearest public charging station.
LiveWire Charging Information Data will be used to gain intelligence of both Vehicle and user charging behavior. Key data elements will be observed by our engineering team to assure the Vehicle On-Board Charging (OBC) system is operating as designed. Other such use cases will involve gathering data from the Rechargeable Energy Storage System (RESS) to analyze for possible performance improvements and/or lifecycle management studies. Additional information will be used to support dealer technical support and customer support services whereby a customer encounters issues with their LiveWire motorcycle charging system. Such information may be used including but not limited to determining the location of the charger and charging characteristics such as charge start/stop state-of-charge (SOC), intended operation (charger fault), and charge plug behavior.
Diagnostics
LiveWire may collect specific information related to the performance of your LiveWire motorcycle. This level of specific data is utilized for remote troubleshooting and performance enhancements. LiveWire may also use this data for technical, engineering, and customer support. Such information will be utilized on dashboards for means of metric tracking, where metric tracking may aid in understanding model and model year overall state-of-health. State-of-health shall be viewed as a Vehicle’s electronic control systems and the level of effectiveness in which these systems operate. A Vehicle with 100% state-of-health would suggest a Vehicle that operates without fault or event that may impair the use of a Vehicle.
Stolen Vehicle Tracking
The Stolen Vehicle Tracking system is integrated into all LiveWire Apps. To activate the Stolen Vehicle Tracking service, you should place your vehicle in "Stolen Vehicle" mode through the LiveWire App. When Stolen Vehicle is activated, Vehicle positioning/location will be collected more frequently.
LiveWire may be use Vehicle positioning/location information in the event a customer reports their LiveWire Vehicle as stolen to authorities and/or LiveWire Customer Service. With appropriate verification and/or law enforcement requests, LiveWire may aid in locating the Vehicle if the App is unable to track the last known and/or current location.
Geo Location
To provide you with the Apps and Vehicle Integration Services, our systems will collect and use your vehicle location for all location-enabled features and functionality that requires geo location to operate properly and as intended (e.g., ride mapping, directions, roadside assistance, stolen vehicle tracking, and other features described in the mobile app data collection activities below). Cancellation of your Apps and Vehicle Integration Services will result in all Apps and Vehicle Integration services, including any location data services, being unavailable.
LiveWire Geo Location Data Usage may include an anonymized identification of a LiveWire Vehicle. Such examples include understanding specific Vehicle usage, regional based service-related event cases, and various performance related metrics within specific locations.
PERSONAL INFORMATION AND OTHER DATA COLLECTED THROUGH AND FROM MOBILE APP
| Data Category | Description |
|---|---|
| User Profile | Email, first/ last name, acceptance of Terms & Conditions, app country, app locale, user preferences, date email was last modified, email selected as preferred means of contact, language |
| Bike Profile | VIN, make, model, year, type, name, model number, primary bike |
| Roadside Assistance | Policy number, company name, policy contact number, VIN |
| Maintenance History | Odometer reading, maintenance completed on mileage, service description, service date |
| Bike Details | Bike ID, color, color code, model number |
| Bike Pairing | Pairing code, number of attempts, device ID, user ID, pairing date |
| FOTA Schedule | Schedule date/ time, VIN |
| Bike Ride Details | Ride name, ride description, ride duration, ride length, bookmark ID, bookmark status, modified date, modified time, transport mode |
| Ride Location History | Address, altitude, course, horizontal accuracy, latitude, longitude, speed, time stamp, vertical accuracy |
| Ride Avoidances | Avoid ferries, avoid highways, avoid tolls, avoid tunnels, avoid unpaved roads |
| Ride Session | Altitude maximum, altitude minimum, bike make, bike model, bike name, bike VIN, bike year, created time, elevation gain, finished time, location record count, moving time, speed max, speed moving average, stopped time, user agent |
| Ride Waypoints | Address, category, dealer ID, Here® ID, latitude, longitude, name, type |
User Profile
The User Profile details allow the user to create a profile thus enabling the use of the Apps. We may monitor how frequently User Profile is accessed and modified within the Apps for purposes of metric counts, as described below.
Bike Profile
The Bike Profile details are necessary to pair the user’s bike to the mobile application to enable the full user experience of the Apps. We may monitor how frequently Bike Profile is accessed and modified within the Apps for purposes of metric counts, as described below.
Roadside Assistance
Roadside assistance details are required for the accessibility to roadside assistance information directly from the mobile application. We may monitor how frequently Roadside Assistance is accessed within the Apps for purposes of metric counts, as described below, but we will not access any information the user enters into this section of the Apps.
Maintenance History
Maintenance history details provide the user the opportunity to access maintenance history of their bike. We may monitor how frequently Maintenance History is accessed within the Apps for purposes of metric counts, as described below, but we will not access or share any information the user enters into this section of the Apps.
Bike Details
Bike details provide the user with the ability to view their LiveWire vehicle(s) as a detailed representative model in the mobile application. We may monitor how frequently the Bike Details section is accessed within the Apps for purposes of metric counts, as described below.
Bike Pairing
Bike pairing details are required data elements which work in conjunction with User Profile and Bike Profile. In addition to monitoring how frequently the Bike Pairing section of the App is accessed for purposes of metric counts, as described below, we may also monitor how many mobile devices are pairing with a LiveWire vehicle, the success or failure of pairing, and the reason for any failure to pair.
FOTA Schedule
FOTA Schedule details provide the users an opportunity to schedule FOTA (firmware-over-the-air) installs to the associated vehicle. The FOTA schedule will work directly with Bike Profile and User Profile. We may monitor how frequently the FOTA Schedule section of the App is accessed and how it is used for purposes of metric counts, as described below.
Bike Ride Details
Ride details allow the user to configure a specific route within the mobile application and deploy to the instrument. We may monitor how frequently the Bike Ride Details section of the App is accessed for purposes of metric counts, as described below.
Ride Location History
Location history provides a user the opportunity to review previous rides with limited metrics available for review. We may monitor how frequently the Bike Ride Location History section of the App is accessed and how it is used for purposes of metric counts, as described below, but we will not view actual ride location history unless the user initiates Stolen Vehicle Tracking.
Ride Avoidances
Ride avoidances will work in unison with the navigation and/or route mapping which allow the opportunity for S2 mobile app users to select preloaded avoidances, for example, ferries, toll roads, and unpaved roads. We may monitor how frequently the Ride Avoidances section of the App is accessed and what selections are made for purposes of metric counts, as described below.
Ride Session
The Ride Session feature allows the user to review specific elements recorded from a previous ride, outlined in the above table. We may monitor how frequently the Ride Session section of the App is accessed and how the feature is used for purposes of metric counts, as described below.
Ride Waypoints
Ride Waypoints allow the operator of the Apps to set specific locations during the ride that may be visited at any time. We may monitor how frequently the Ride Waypoints section of the App is accessed and how the feature is used for purposes of metric counts, as described below.
What is a metric count and how is a metric count used at LiveWire?
A metric will consist of a data element from the Apps. The count of the data element will be used for means of analysis. For example, LiveWire will use the metrics from Ride Avoidances and see how many users select “Avoid Tolls.” LiveWire may also use geography of these metric counts to further understand if trends are by region, state, county, or country.
ADDITIONAL INFORMATION ABOUT THE COLLECTION, USE AND SHARING OF PERSONAL INFORMATION
Why and how do we use your Personal Information?
Provide our Platform and Related Services. We use your Personal Information to operate, maintain, supervise, administer, improve and enhance our Platform and related Services, features and functionality. We use your contact information to communicate and interact with you, such as to send you emails and text messages about our Platform. We use the IP address assigned to your device to send you the data you request to display on your device. We use Unique Identifiers stored in cookies on your device to help us authenticate you as the person who should have access to certain areas and features of our Platform. We also use your information to ensure our Platform is working as intended, such as tracking outages or troubleshooting issues that you report to us. And we use your information for research and development for our business, and to make improvements to our Platform.
We use data collected from you and your devices for analytics and measurement to understand how our Platform is used. For example, we analyze data about your use of our Platform to accomplish tasks such as optimizing our Services and Product designs. We use a variety of tools to do this, such as Google Analytics and similar third-party online data analytics services.
We use personal information to offer, provide and support Services (including data, telematics, connected and related services) through our Platform, which may be for purchase at a charge, or included at no charge as part of our Platform.
When you purchase Products or Services from us, you may provide us information such as your payment card or bank account information, shipping address or delivery instructions. We use this information for things such as processing, fulfilling, and delivering your order, and to provide support in connection with the Products or Services you purchase.
Security and Legal Purposes. We use your information to help improve the safety and reliability of our Platform. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm LiveWire, our users, or the public. Information may also be used for legal purposes, such as to comply with applicable law, regulation, legal process, or enforceable governmental request; to enforce our Terms of Use, including investigation of potential violations; and to detect, prevent, or otherwise address fraud, security, or technical issues; and to protect against harm to the rights, property or safety of LiveWire, our users, or the public as required or permitted by law.
We may also use Personal Information to:
- Carry out our legal and contractual obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
- Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others.
- To administer surveys and questionnaires.
- To provide you information about products and services that may be of interest to you, including through newsletters.
- Any other purpose with your consent.
Personalized and interest-based advertising. To serve interest-based ads, we may use information such as your interactions with our Platform, Services and related content. We partner with third party advertising networks that collect IP addresses, unique device identifiers, browser type, operating system, time zone, country, referring pages, and other information through the use of cookies, pixel tags, and server logs on our Platform. They use this information to provide you with interest-based advertisements that are customized to your particular preferences, including for companies that are not affiliated with us. You may see these interest-based advertisements on our Platform, as well as on third party websites and apps, and across different devices you use. We may use this process to help us manage and improve the effectiveness of our marketing efforts. It also allows us to display ads to our users about LiveWire after they leave our Platform, and to track users after they see or click on an advertisement, keep track of users who access our Platform or advertisements from different devices, and better provide advertisements to our target audiences. The data collected through these tracking technologies is also saved and processed by our advertising and marketing service provider partners. We do not use information which on its own identifies you, such as name or e-mail address, to serve interest-based ads.
Why and how do we share your Personal Information?
We share Personal Information with third parties under certain circumstances and for certain purposes described throughout this Policy, including:
- Service providers and others to operate our Platform and Services. We share your Personal Information with our affiliates, vendors, service providers, and business partners, including providers and vendors we use for operating and maintaining our Platform, and its features, functionality and Services. These third parties include data hosting and data storage partners, analytics, ad network, advertising (including interest-based advertising), technology services and support, and data security.
- Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including providers and vendors we use for our business activities and operations generally, such as data hosting and data storage partners, analytics, ad network, advertising, technology services and support, and data security. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
- With your consent. We may share your Personal Information if you request or direct us to do so.
- Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
- Business transfers. We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
- To enforce our rights. We may share your Personal Information to enforce our Terms of Use and any other agreement, terms and conditions relating to your use of the Platform. We also may share information as needed to ensure the safety and security of our Platform and our users, and to detect, prevent, or otherwise address fraud, security, or technical issues.
- De-identified information. We may also share de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
Your choices for how we collect, use and share your Personal Information
We offer you choices as to how you can opt out of certain uses and sharing of your Personal Information. As a general rule, you cannot opt out of our collection, use and sharing of Personal Information to the extent it is necessary to provide the Platform or related Services, features and functionality to you.
You can change the cookie settings that will be placed when you use our Platform by changing the settings on your Internet browser. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access or use all or certain areas and aspects of our Platform.
You can generally opt out of receiving interest-based advertisements from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out pages on the NAI website and DAA website. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website. You can learn more about interest-based advertisements and your opt out rights and options on the NAI website and DAA website.
If you do not wish to have your email address used by LiveWire to send you advertising messages and content, you can opt out at any time by clicking the unsubscribe link at the bottom of any marketing emails you receive from us. You may have other options with respect to marketing and communication preferences through our Platform.
How do I access and correct my Personal Information?
Access, Corrections and Deletion. In addition to any data access capabilities available through the Platform, please Contact Us if you have any questions about your Personal Information, and please inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. You may also have certain deletion rights in accordance with applicable law. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Copies and Retention of Data. In addition to any capabilities available through the Platform, if you need to export or obtain a copy of your data, please let us know and we will assist you with your request. We retain the data we collect for different periods of time depending on what it is, how we use it and applicable legal requirements. We may retain some data for longer periods of time than other data when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.
3. Children’s Privacy
Our Platform is not intended for children under 16 years of age. We do not knowingly collect or sell Personal Information from children under the age of 16. If you are under the age of 16, do not use or provide any information on or to the Platform or through any of its features. If we learn we have collected or received Personal Information from a child under the age of 16 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 16 years of age whom you believe might have provided us with their Personal Information, you may Contact Us to request the Personal Information be deleted.
4. Data Security
We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.
The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Platform, in your operating system, or mobile device.
5. Supplemental Disclosures and Rights Based on California on Other State Laws
In addition to the disclosures and rights set forth elsewhere in this Policy, you and other users may have certain rights based on applicable state law (e.g., California’s Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA)). Our California Privacy (CCPA) Notice can be found here. Other states have passed consumer privacy laws that may be applicable to LiveWire and your use of this Site. These supplemental disclosures and rights apply to you and your use of our Platform to the extent applicable state law applies to LiveWire and your use of our Platform. Please contact us if you have any questions regarding your rights under applicable state law.
Categories of Personal Information Collected
As described in more detail in other areas of our Privacy Policy, we collect and/or disclose Personal Information about you when you visit our Website or use our Services, including information about you that you provide to us, and information that we automatically collect from you or your computer or device as you use our Services.
Personal information does not include information that is: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) certain information excluded from the scope of applicable state law (e.g., medical and other information may be covered under HIPAA and other state laws).
Categories of Sources From Which We Have Collected Personal Information
We collect Personal Information directly from you, for example when you provide it to us, when you contact us through our Services, when you create a LiveWire account; and indirectly from you automatically through your computer or device as you use our Services. We may also collect Personal Information about you from our advertising partners and service providers.
Use of Personal Information
We do not sell your Personal Information and have not done so in the prior 12 months from the effective date of this Policy. We may use or disclose the personal information we collect for our business purposes described elsewhere in this Privacy Policy.
Sharing Personal Information
LiveWire may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for Business Purposes
We may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and Unique Identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising. We disclose your Personal Information to certain third parties such as our vendors, business partners, service providers, including companies that assist us with marketing and advertising.
Access Request Rights
You may have the right to request that LiveWire disclose certain information to you about our collection and use of your Personal Information over the past 12 months for the above business and commercial purposes. To submit an access request, see Exercising Access and Deletion Rights, below. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You may have the right to request that LiveWire delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by one of the following methods:
- Email: DataPrivacy@LiveWire.com
- Regular Mail:
LiveWire EV, LLC
Attn: Chief Privacy Officer
3700 W. Juneau Avenue
Milwaukee, WI 53208
Only you, or your authorized legal representative authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under applicable state law. Unless permitted by applicable law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. International Users
LiveWire is the data controller of the Personal Information you provide on the Platform and/or through the Services. While LiveWire and its service providers maintain servers and various locations in jurisdictions throughout the world, primarily LiveWire stores and processes your Personal Information on servers located in the United States. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this Privacy Policy. We also comply with certain legal frameworks relating to the transfer of data, such as the use of standard contractual clauses.
Visitors to and users of our Platform who reside in the European Union should review LiveWire’s Privacy Notice for Telemetry Data applicable to the European country of residence for additional information about how we collect, use, share, and otherwise process personal data of EU residents. (In the event of a conflict or inconsistency between the terms of this Privacy Policy and our Privacy Notice for Telemetry Data for the applicable European country, the terms of the Privacy Notice for Telemetry Data for the applicable European country will apply to residents of the EU.)
7. Changes to our Privacy Policy
We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Platform. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by email to the email address specified in your account and/or through a notice on the Platform. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing our Platform and reviewing this Privacy Policy to check for any changes.
8. Contact Us
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy you may contact us using one of the following methods:
- Email: DataPrivacy@LiveWire.com
- Regular Mail:
LiveWire EV, LLC
Attn: Chief Privacy Officer
3700 W. Juneau Avenue
Milwaukee, WI 53208
9. Glossary
Browser Web Storage enables websites to store data in a browser on a device. When used in "local storage" mode, it enables data to be stored across sessions. This makes data retrievable even after a browser has been closed and reopened.
A Cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
A Pixel or Pixel Tag is a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. Pixel tags are often used in combination with cookies.
An Application Data Cache is a data repository on a device. It can, for example, enable a web application to run without an internet connection and improve the performance of the application by enabling faster loading of content.
Interest-based Advertising is sometimes referred to as personalized or targeted ads. Interest-based ads are used to display features, products, and services that might be of interest to the user.
Server Logs. Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.
Session Replay provides the ability to replay a visitor's journey on a web site or within a mobile application or web application. Replay can include the user's view (browser or screen output), user input (keyboard and mouse inputs), and logs of network events or console logs. Session replay is used to help improve customer experience, analyze usability and help identify obstacles in conversion processes on websites. It can also be used to study a website's usability, customer behavior, interests, and the handling of customer service questions as the customer journey, with all interactions, can be replayed. It can also be used to analyze fraudulent behavior on websites.
A Unique Identifier is a string of letters, numbers and characters that can be used to uniquely identify a computer, device, personal device, browser or app.
Different identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed. Unique Identifiers can be used for various purposes, including security and fraud detection, syncing data from your device(s) to our Platform, remembering your preferences, and providing personalized advertising. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. See your browser documentation for additional information.
On other platforms besides browsers (e.g., personal devices), Unique Identifiers are used to recognize a specific device or app on that device. For example, a Unique Identifier can be used to provide relevant advertising on mobile devices and can be managed in your device’s settings. Unique Identifiers may also be incorporated into a device by its manufacturer (sometimes called a universally unique ID or UUID), such as the IMEI-number of a mobile phone. For example, a device’s unique identifier can be used to customize our Platform and Services to your device or analyze device issues related to our Platform and Services.