Privacy Notice
Last modified: October 2024
1. INTRODUCTION
CNH Industrial America LLC, its subsidiaries and affiliates (“Company,” “we,” “our,” or “us”) respect your privacy and are committed to protecting it through our compliance with this privacy notice (the “Privacy Notice”). This Privacy Notice describes the types of Personal Data (as defined below) we may collect, use, maintain, protect, disclose, or otherwise process about you when you use, inquire about, or obtain our products and services and our practices for collecting, using, maintaining, and disclosing that Personal Data.
This policy applies to information we collect:
when you visit one of our independent dealers to learn more about our products and services;
when you visit our online store located at https://mycnhistore.com (the “Online Parts Store”);
when you purchase equipment, parts, accessories or make any other transaction at one of our independent dealers or through our Online Parts Store;
when you get your equipment serviced or seek other maintenance and support for your equipment;
when you register for our Parts Perks loyalty program or register to be included on our mailing list; and
in email, text, and other electronic messages between you and the Company.
(Collectively, our “Products and Services”).
Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. In some cases you may opt out of our collection and use of Personal Data, but if you do not agree with our policies and practices, your choice is to opt out when this option is provided to you or not to use our Products and Services. By accessing or using our Products and Services, you agree to this Privacy Notice and hereby consent to our collection and use of your Personal Data as described in this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice section). Your continued use of our Products and Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates. This Privacy Notice also applies to residents of Puerto Rico. If you are a resident of California, please see the California Privacy Annex.
PROCESSING OF DATA BY CNH INDUSTRIAL ITALIA AS PLATFORM PROVIDER
This website is managed and administered by CNH Industrial Italia S.p.a. as technical provider. For this reason, CNH Industrial Italia SpA, with registered office at Lungo Stura Lazio, 19 - 10156 Turin - Italy, is the data controller of the personal data processed for the purposes detailed below:
administrator the website, provide and improve the website as well as resolve any issues related to its use, provide you with access to the tools and the relevant services;
ensure asset and information security, to maintain the safety, security, quality, and integrity of our website, databases and other technology assets, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality. To this end, if you have a registered account, you could also receive from us certain messages asking you the reason why you have not completed the checkout process, asking you for feedbacks on any problem you could have experienced in placing the order or during the check out, to verify that you simply did not forget to check out and that you can actually receive the purchased products, or any other reason why your shopping kart has been forsaken.
use data, “cookies,” and other similar tools to understand how you and the Authorized Dealers use the website, produce aggregate statistics in order to apport improvements to the website, and analyze sales performance and the product offerings made by CNH Industrial group through the website.
For the purposes described under (i) and (ii) the data are processes as per the controller legitimate interest consisting in the management and in providing a platform that can facilitate the matching of supply and demand in the various markets and in improving the Company's business relationships with its network of Authorized Dealers and the relevant selling performance. You will always have the right to object to such data processing activities.
The information contained in this Privacy Notice shall also apply to the data processed by CNH Industrial Italia S.p.a. for the purposes detailed under this section.
2. CHILDREN UNDER THE AGE OF 18
Our Products and Services are not intended for children under 18 years of age. No one under age 18 may provide any information related to their use of the Products and Services. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information related to your use of our Products and Services, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us through the contact information listed below.
3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a particular device (including any equipment). However, Personal Data does not include any deidentified or aggregated information.
Generally
We collect Personal Data from various sources, including:
directly from you when you provide it to us;
automatically as you interact with our ecommerce website;
information that we create about you when you provide us with your Parts Perks number when you make a purchase or otherwise use our Products and Services, including at an independent dealer or through our ecommerce website; and
From third parties, for example, our independent dealers.
Information You Provide to Us
We collect the following types of Personal Data directly from you when you access or use our Products and Services: real name, alias, postal address, email address, telephone number, username and password, tokenized credit or debit card number or financial information, and any other identifier by which you may be contacted online or offline. In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us.
We collect Personal Data from you when you use our Products and Services through the following ways:
information that you provide by filling in forms on our Online Parts Store. This includes information provided at the time of searching for our Products and Services on the Online Parts Store, registering to use or making a purchase on our Online Parts Store and at the time of registering to participate in our Parts Perks rewards program (which is optional). We may also ask you for information when you report a problem with our Products and Services;
if you contact us, records and copies of your correspondence, either in writing, by person, by phone, or electronically, or other means (including email addresses);
details of transactions you carry out through our Online Parts Store and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Online Parts Store; and
your search queries on the Online Parts Store.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Online Parts Store, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Online Parts Store, including information about your equipment, browsing actions, and patterns. This includes:
details of your visits to our Online Parts Store. This includes: browsing history, search history, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Online Parts Store, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with on the Online Parts Store; and
Information about your computer and internet connection, i.e., your IP address, operating system, and browser type.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Products and Services and to deliver a better and more personalized service by enabling us to:
estimate our audience size and usage patterns;
store information about your preferences;
customize our Products and Services according to your individual interests;
speed up your searches; and
recognize you when you return to our Online Parts Store.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Online Parts Store may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Online Parts Store. Unless you have adjusted your browser setting so that it will refuse cookies, or used our cookie consent manager to restrict the types of cookies used by the Online Parts Store, our system will issue cookies when you direct your browser to our Online Parts Store. You may refuse all or some non-essential cookies through the use of our cookie consent manager, which you may access by clicking the “Cookies” link at the bottom of our Online Parts Store. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting, you may be unable to access certain parts of our Online Parts Store. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Online Parts Store, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Online Parts Store and track which pages of the Online Parts Store you access. Session cookies are essential cookies and are required to use the Online Parts Store and may not be disabled through our cookie consent manager, but may be disabled if you set your browser to refuse cookies. By setting your browser in this way, you may not be able to use all features of our Online Parts Store, including to make purchases or to access your account.
Web Beacons. Pages of our Online Parts Store and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Online Parts Store are served by third parties, including advertisers, ad networks and servers, content providers, analytics providers, social media companies, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Online Parts Store. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information section.
Information We Create About You
We may also create certain information about you. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our Online Parts Store, and your Parts Perks number.
Information We Collect from Third Parties
We may collect Personal Data from third parties, such as our independent dealers. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: real name, billing address, shipping address, email address, telephone number, Parts Perks number (if you choose to provide it to the dealer), records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories, and information your equipment, such as its serial number, brand and model, and service or repair history.
Personal Data Provided by Dealers and other Third Parties
Although we may collect Personal Data about you in connection with your visit to an authorized Company dealer or from another third party, this Privacy Notice does not apply to how these dealers or other third parties collect, use, or otherwise process your Personal Data. Please be aware that we are not responsible for the privacy practices of such dealers or other third parties. The privacy practices of these dealers and other third parties, including details on the information they may collect about you, are subject to their respective privacy policies. You should access these third parties directly if you have a question about their use of your Personal Data.
4. HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any Personal Data:
to provide and personalize our Online Parts Store and its contents to you;
to provide you with information, Products and Services that you request from us;
if you participate in the Parts Perks program, to provide you with the Parts Perks program benefits and maintain your Parts Perks account;
to support, develop, troubleshoot, and debug our Online Parts Store and other Products and Services;
to create, maintain, customize, and secure your Online Parts Store and Parts Perks accounts with us;
to provide you with notices about your Online Parts Store and Parts Perks accounts, including expiration and renewal notices;
to personalize your Online Parts Store experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Online Parts Store, from authorized dealers, third-party sites, and via email or text message (with your consent, where required by law);
to help maintain the safety, security, and integrity of our Online Parts Store, Products and Services, databases and other technology assets, and business;
for internal testing, research, analysis, and product development, including to develop, improve, or demonstrate our Online Parts Store and/or our other Products and Services;
to notify you about changes to our Online Parts Store, Products and Services, and the Parts Perks program and any other products and services we may offer through them;
to directly, or indirectly through authorized dealers and other third parties, market our products and services to you and provide you with promotions, including special deals and discounts;
debugging to identify and repair errors that impair existing intended functionality in any of our Online Parts Store or any other Products and Services;
to process your requests, purchases, transactions, and payments, to administer your warranty coverage as applicable, and prevent transactional fraud;
to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses, and to contact you, directly or indirectly, about any survey responses as part of our customer service experience program;
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to respond to your inquiries and request for information;
in any other way we may describe when you provide the information;
to fulfill any other purpose for which you provide it; and
for any other purpose with your consent.
We may use Personal Data that has been aggregated or deidentified such that it no longer reasonably identifies you without restriction. We may also use your Personal Information to contact you about our Online Parts Store and our other (and our dealers) Products and Services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your Online Parts Store or Parts Perks account profile by checking or unchecking the relevant boxes (if applicable) or by sending us an email stating your request at the contact information below. For more information, see Choices About How We Use and Disclose Your Personal Data section.
5. DISCLOSURE OF YOUR PERSONAL DATA
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice and in the jurisdiction-specific privacy addendums. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or that you provide as described in this Privacy Notice:
to our affiliated entities within the Company family of companies;
to our independent dealers, when necessary to provide you the Products and Services provided by them;
to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them, such as IT and infrastructure support services, shipping and receiving services, payment processing services, analytics companies, marketing organizations, organizations that help us manage our Parts Perks program, and similar organizations;
to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Company about users of our Online Parts Store and/or our Products and Services is among the assets transferred;
to fulfill any other purpose for which you provide it;
for any other purpose disclosed by us when you provide the information; and
with your consent.
We may also disclose your Personal Data:
to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our ecommerce terms of use or terms of sale, the Parts Perks program terms and conditions, our Products and Services terms and conditions, and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our Dealers, our or our Dealers’ customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We do not control the collection and use of your Personal Information or other information collected by third parties described above in the Disclosure of Your Information section. These organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
Tracking Technologies and Advertising. You may refuse all or some non-essential cookies through the use of our cookie consent manager, which you may access by clicking the “Cookies” link at the bottom of our Online Parts Store. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Online Parts Store may then be inaccessible or not function properly.
Promotional Offers from the Company through email. If you do not want us to use your email address or physical address to promote our Products and Services, you can opt out at any time by clicking the unsubscribe link in the body of that email or other marketing communications you receive from us or emailing Privacy-NA@cnhind.com to be omitted from future email distributions. This opt-out does not apply to information collected by the Company or our communications with you as a result of a Product or Service purchase, warranty registration, Product and Services experience, or other transactions.
Promotional Offers from the Company through Voice and Text. We will only use your telephone number to contact you about our Products and Services with your consent. If you do not want us to use your phone number to promote our Products and Services, you may do so at any time by replying STOP to any promotional text message you receive from us or email Privacy-NA@cnhind.com. This opt-out does not apply to information provided to Company as a result of a Product or Service purchase, warranty registration, Product and Services experience, or other transactions. The Company does not charge for receiving text message alerts, but message and data rates may apply. Supported carriers include AT&T, Verizon, MetroPCS, Sprint, Boost, T-Mobile, Alltel, Virgin Mobile, and U.S. Cellular. Neither Company nor such carriers are not liable for delayed or undelivered messages.
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 learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
The state in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see the Jurisdiction-Specific Privacy Rights section for more Information.
7. ACCESSING, CORRECTING, AND DELETING YOUR PERSONAL DATA
If you use our Online Parts Store, you can review and change some of your Personal Data (such as your address or phone number) by logging into the Online Parts Store and visiting your account profile page. Doing so will also change your Personal Data if you are a participant in our Parts Perks program.
You may also send us an email at Privacy-NA@cnhind.com to request access to, correct or delete any Personal Data that we process. We cannot delete your Personal Data except by also deleting your Online Parts Store account and Parts Perks membership (if applicable). We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.
The state in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see the Jurisdiction-Specific Privacy Rights section for more Information.
8. JURISDICTION-SPECIFIC PRIVACY RIGHTS
The law in some states may provide you with additional rights regarding our use of your Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Notice.
Your California Privacy Rights.
If you are a resident of California, you have the additional rights described in the California Privacy Annex.
9. DO NOT TRACK SIGNALS
When you use our Online Parts Store, we also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
10. DATA SECURITY
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All payment transactions on or through the Online Parts Store are processed by a third-party payment processor, who is responsible for the security of your cardholder information. Company only receives tokenized payment information that may be used only between us and our payment processor for the purposes of future payments.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access our Online Parts Store, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Online Parts Store or to our other Products and Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Online Parts Store or other Products and Services.
11. CONSENT TO PROCESSING OF PERSONAL DATA IN THE UNITED STATES
In order to provide our Online Parts Store, Parts Perks program, and other Products and Services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Products and Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.
Your Personal Data is transferred by Company to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice when we transfer it to a third party, Company uses Data Protection Agreements between Company and all other recipients of your Personal Data.
12. CHANGES TO OUR PRIVACY NOTICE
We may change this Privacy Notice at any time. We will publish any update on this website and it will be effective upon posting. We encourage you to periodically review this Privacy Notice to learn how we process and protect your Data.YOUR CONTINUED USE OF OUR PRODUCTS AND SERVICES FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.
13. CONTACT INFORMATION
If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us with regard to how we process your Personal Data, you may contact us at the contact information below or through the “Contact” page on our Online Parts Store.
CNH Industrial America LLC
711 Jorie Blvd.
Oak Brook, IL 60523
Email: Privacy-NA@cnhind.com