Canada Privacy Notice
Effective Date: February 2, 2024
CNH Industrial Canada, Ltd., 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”). We adopt this Privacy Notice to comply with the Personal Information Protection and Electronic Documents Act (the “PIPEDA”) and applicable Canadian provincial privacy legislation (each a “PIPA”), as they may be amended or superseded from time to time, and any terms defined in the PIPEDA have the same meaning when used in this Privacy Notice.
1. SCOPE OF THIS CANADIAN PRIVACY ADDENDUM
This Privacy Notice applies to information that we collect that may be made available to you through one of our authorized dealers that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (“Personal Information”).
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”).
It does not apply to information collected by:
us offline or through any other means, through any telematics installed on your equipment;
us in relation to any financial relationship you or your employer/company may have with the Company, including through a Company loan or credit account;
except for our Online Parts Store, any other website operated by the Company or any third party (including our affiliates and subsidiaries);
us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
any third party (including our independent dealers, and their affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from on or through our Products and Services.
Personal Information does not include publicly available information from government records, deidentified or aggregated Your information, or other similar information excluded from the scope of the PIPEDA or applicable PIPA.
This Privacy Notice also does not apply to certain Personal Information that is excluded from the scope of PIPEDA or applicable PIPA, like Personal Information covered by certain sector-specific privacy laws, including Bank Act and laws governing credit unions. We may collect this type of Personal Information when you apply for our credit cards or apply for a loan from us, and our collection and use of such Personal Information are governed by our obligations under the applicable law.
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
2. CONSENT
WE WILL ONLY COLLECT, USE OR DISCLOSE YOUR PERSONAL INFORMATION WITH YOUR CONSENT, EXCEPT IN LIMITED CIRCUMSTANCES. BY YOUR RECEIPT OF OUR PRIVACY NOTICE AND THIS PRIVACY NOTICE, WE WILL ASSUME, UNLESS WE HEAR FROM YOU OTHERWISE, THAT YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION BY OUR COMPANY IN ACCORDANCE WITH THE TYPES OF INFORMATION, COLLECTION METHODS AND PURPOSES OF USE AND DISCLOSURE DESCRIBED IN THE INFORMATION WE COLLECT ABOUT YOU, HOW WE COLLECT IT AND HOW WE USE YOUR INFORMATION SECTIONS OF OUR PRIVACY NOTICE AND THIS PRIVACY NOTICE.
WE WILL NOT USE OR DISCLOSE YOUR PERSONAL INFORMATION AT ANY TIME, SUBJECT TO ANY LEGAL OR CONTRACTUAL RESTRICTION AND REASONABLE NOTICE. WE WILL NOT USE YOUR PERSONAL INFORMATION WITHOUT YOUR CONSENT EXCEPT IN THE FOLLOWING CIRCUMSTANCES:
WHEN REQUIRED BY LAW OR LAW ENFORCEMENT PURPOSES
FOR AN EMERGENCY THAT THREATENS LIFE, HEALTH OR SECURITY
FOR THE PURPOSE OF COLLECTING ON A DEBT OWED TO OUR COMPANY
IF THE INFORMATION IS PUBLICLY AVAILABLE
3. RESPONSIBLE PERSON FOR PROTECTING PERSONAL INFORMATION
CNH Industrial Canada Ltd. is primarily responsible for processing your Personal Information, but may use the other subsidiaries and affiliates within the Company to carry out the purpose described in the Privacy Notice. Company has appointed the North America Data Privacy Manager to be responsible for protecting Personal Information in Company’s possession in compliance with PIPEDA and/or the applicable PIPAs. Company and/or this responsible person may be contacted in any manner set forth below in the “Contact Information” Section of this Canada Privacy Addendum.
4. COLLECTION OF PERSONAL INFORMATION
The type of Personal Information we collect may vary depending on your relationship with us. We may collect the following categories of Personal Information from You:
A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address; email address; account name; driver’s license number; and other similar identifiers; signature; address; telephone number. If you make a purchase through the Online Parts Store: credit or debit card number (Company only receives a tokenized version of your credit or debit card information from our payment processor), or any other financial information that you use to pay for the Products and Services; Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; Browsing history; search history; information on your interaction with a website, application, or advertisement; IP-based physical location or movements that may identify your general geographic location to town, city, and state; Electronic information obtained by a dealer from your equipment when as part of service and maintenance, including fault codes and similar information.
The Company will not collect other categories of Personal Information without providing you notice at or before the time the information is collected.
5. SOURCES OF PERSONAL 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.
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.
6. USE OF PERSONAL INFORMATION
We use information that we collect about you or that you provide to us, including any Personal Information:
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, 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 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 Information 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. Company will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
7. DISCLOSURE OF YOUR PERSONAL INFORMATION
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 accomplish the business purposes described in Section 6.
The Company may also disclose your Personal Information to third parties for one or more of the following business purposes:
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Helping to ensure security and integrity of our Products and Services and IT infrastructure to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality in our Products and Services.
Short–term, transient use, including, but not limited to, depersonalized advertising shown as part of your current interaction with us. Our agreements with third parties prohibit your Personal Information from disclosure to another third party and from using your Personal Information to build a profile about you or otherwise alter your experience outside your current interaction with us.
Performing services on behalf of us, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar services on behalf of us.
Providing advertising and marketing services, except for cross-context behavioral advertising, to you.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
In addition to the above, we may disclose any or all categories of Personal Information to any third party (including government entities and/or law enforcement entities) as necessary to:
comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;
comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury; or
exercise or defend legal claims.
When we disclose Personal Information to non-affiliated third parties for business purposes, we enter into 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 for performing under the contract or to otherwise comply with the requirements of the PIPEDA and applicable PIPA.
Company may disclose Personal Information for one or more of the business purposes described above to the following categories of third parties: Service Providers; advertisers and advertising networks; dealers; affiliates, parents, and subsidiary organizations of Company; government entities (for registration); social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.
8. YOUR RIGHTS AND CHOICES
The PIPEDA and the PIPA’s provide you with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights.
If you are a resident of Canada, you have the following rights regarding your Personal Information: (1) the right to request access to the Personal Information we hold about you; (2) the right to challenge the accuracy and completeness of such information; and (3) the right to have such information deleted.
Right to Know. You have the right to request that the Company disclose certain information to you about our collection and use of your Personal Information (a “Right to Know” Privacy Request). This includes details about: (a) the collected Personal Information; (b) the categories of people within the organization with access. The amount of time that we will retain your Personal Information and the contact information for the person within the Company who is responsible for protecting Personal Information are each described below.
Access to Specific Pieces of Information. You have the right to request that the Company confirm that we have collected Personal Information concerning you and provide you with a copy of the specific pieces of such Personal Information that we have collected (a “Data Portability” Privacy Request). You may also request that we provide you a copy of this Personal Information in a structured, commonly used, and machine-readable format. We may not comply with a Data Portability Privacy Request when the disclosure would be likely to reveal personal information about a third person (unless the third person consents or in the case of emergency that threatens the life, health, or safety of the person concerned).
Correction. You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. You may review and correct some Personal Information about yourself by logging into the Websites and visiting your “Account” page. You may also request that we correct the Personal Information we have about you as described below under Exercising Your Canadian Privacy Laws Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also 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 or if the Personal Information is subject to another exception under the Canadian Privacy Laws.
Deletion. You have the right to request that the Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. This includes the right to request that we stop disseminating your Personal Information or de-index any hyperlink attached to your name that gives access to your Personal Information if such dissemination causes you harm or contravenes the law or a court order. Once we receive and confirm your Privacy Request (see Exercising Your Canadian Privacy Laws Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to PIPEDA or an applicable PIPA. However, we cannot delete all of your Personal Data except by also deleting your user account when there is no current balance. 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 or impede our ability to service or collect on any account you currently have or guarantee. In addition, we cannot completely delete your Personal Information as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
Withdrawal of Consent. To the extent that our processing of your Personal Information is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Information.
(a) Exercising Your Canada Privacy Rights
To access, update or correct inaccuracies in your Personal Information or if you have a question or complaint about the manner in which we treat your Personal Information, please submit a Privacy Request (a “Privacy Request”) to us by:
Filling the online form available HERE; or
Writing an email to Privacy-NA@cnhind.com.
If you fail to make your submission in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.
Only you may make a Privacy Request related to your Personal Information. We may request additional information so we may confirm any Privacy Request related to your Personal Information.
Your Privacy Request must:
Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We are unable to fulfill your request or provide you with Personal Information if we cannot verify your identity or authority to make such request and confirm the Personal Information relates to you. Making a Privacy Request does not require you to create an account with us. We will only use Personal Information provided in a Privacy Request to verify the requester’s identity or authority to make the request.
(b) Verifying Your Identity
Before completing your request to exercise your rights, we will verify that the request came from you by comparing the identifying information provided by you in your request with any Personal Information we maintain about you at that time.
To protect the privacy and security of your Personal Information, we may also request additional information from you to help us verify your identity and process your request. This information may include your driver’s license or other government-issued identification number. We may also contact you to ask you for further information in relation to your request to speed up our response. We may also ask you to complete and provide a signed declaration under penalty of perjury that you are the individual who is the subject of the request in certain circumstances. We will only use Personal Information provided in a Privacy Request to verify the requester’s identity or authority to make the request.
(c) Response Timing and Format
We will respond to a Privacy Request within thirty (30) days of its receipt. We do not charge fees to process or respond to your Privacy Request.
9. STORAGE OF YOUR PERSONAL INFORMATION; CONSENT TO PROCESSING OF PERSONAL INFORMAITON IN OTHER COUNTRIES OUTSIDE OF YOUR JURISDICTION
We may store your Personal Information on servers and computing systems that are under our possession, custody, or control, or that we otherwise license.
In order to carry our purposes as described in the Privacy Notice, we may send and store your Personal Information outside of your jurisdiction, including to the United States. Accordingly, your Personal Information may be transferred outside Canada and the province where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Information. Your information may be processed and stored in the United States and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using the Online Store, or our Products and Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Information outside your jurisdiction, including in the United States. To ensure your Personal Information is treated in accordance with our Privacy Notice, when we transfer your Personal Information to a third-party, Company uses written data protection agreements between Company and all other recipients of your data in other countries to mitigate the risks identified in the PIA.
The purposes for which we have authorized the third-party service providers outside of your jurisdiction to collect, use, or disclose your Personal Information on our behalf are found in Section 7 above.
10. 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.
11. DATA SECURITY
We have implemented measures designed to secure your Personal Information 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 Information, we cannot guarantee the security of your Personal Information transmitted to our Online Parts Store or to our other Products and Services. Any transmission of Personal Information 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.
12. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Privacy Notice from time to time. When we make material changes to this Privacy Notice, we will notify you by email to the email address we have on file for you. The date this Privacy Notice was last revised is identified at the top of this Privacy Notice. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you.
13. CONTACT INFORMATION
If you have any questions or comments about this Privacy Notice, the ways in which the Company collects and uses your information described in this Privacy Notice or Company’s Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under the laws of Canada, please do not hesitate to contact us at:
To Contact the Company
CNH Industrial America LLC
Attn: North America Data Privacy Manager
711 Jorie Blvd
Oak Brook, IL 60523
To Contact the Person Responsible for our Privacy Program
CNH Industrial America LLC
Attn: North America Data Privacy Manager
711 Jorie Blvd
Oak Brook, IL 60523