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Effective Date: December 1, 2023

1. Introduction

This Privacy Notice Addendum for California Residents (the "California Privacy Addendum") supplements the information contained in the Privacy Notice for CNH Industrial Capital America LLC, CNH Industrial Capital Canada Ltd., and New Holland Credit Company, LLC (collectively, "Company," "we," "our,' or "us") and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies solely to all visitors, users, and others who reside in the State of California ("Data Subject" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA") and any terms defined in the CCPA have the same meaning when used in this notice.

2.Scope of this California Privacy Addendum

This California Privacy Addendum applies to information that we collect when you apply for or obtain a financial product or service for your business or any other business for which you are authorized to obtain such financial products (in each case, "Your Business") from the Company, either directly or indirectly through an authorized equipment dealer, including for commercial lending, leasing, insurance, and revolving charge accounts (each, a "Financial Product or Service"), or when you access your Financial Product or Service account through, or you visit, https://myaccount.cnhindustrialcapital.com, https://www.cnhindustrialcapital.com, or any other Company-branded or affiliate website that allows you to pre-qualify or apply for a Financial Product or Service from the Company for Your Business (each such website, a "Website") 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"). However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as described in the CCPA) are not considered Personal Information and this California Privacy Addendum does not apply to such information.

This California Privacy Addendum does not apply to employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals ("Personnel"). Please contact your local human resources department if you are part of our California Personnel and would like additional information about how we process your Personal Information.

This California Privacy Addendum also does not apply to our collection and use of your Personal Information related to you as an individual customer of any product and service offered by Company or our affiliates. Please see the applicable privacy notice for more information about our privacy practices related to you as an individual customer.

3. Information We Collect About You and How We Collect It

We collect, and over the prior twelve (12) months have collected, the following categories of Personal Information about Data Subjects:

Identifiers: A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address; email address; account name; Social Security number; driver's license number; passport number; and other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name; signature; Social Security number; address; telephone number; passport number; driver's license or state identification card number; insurance policy number; employment; bank account number; credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law: Age (40 years or older); race; color; ancestry; national origin; citizenship; religion or creed; marital status; sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions); sexual orientation; veteran or military status; genetic information (including familial genetic information). Providing this type of Personal Information may be optional in some cases.

Commercial information: Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or using histories or tendencies, together with commercial credit bureau information that may reflect a Data Subject's credit score or may otherwise be considered Personal Information.

Internet or other similar network activity: Browsing history; search history; information on a Data Subject's interaction with a website, application, or advertisement.

Geolocation data: IP based physical location or movements that may identify a Data Subject's general geographic location to town, city, and state. We may also collect information that may identify the precise geolocation of a Data Subject's equipment that is the subject of a Financial Product or Service within a radius of less than 1,850 feet.

Professional or employment-related information: Current or past job history.

Sensitive Personal Information ("Sensitive Personal Information"):

• Government identifiers (social security; driver's license; state identification card; or passport number)
• Complete account access credentials (user names, financial account numbers, or debit card numbers combined with required access/security code or password)
• Precise geolocation (within an area of less than 1850 feet)
• Racial or ethnic origin
• Health; sex life; or sexual orientation information
  
  Company will not collect additional categories of Personal Information without providing you notice. As further described in To Whom Do We Sell or Share Your Personal Information, our use of cookies on the Websites may be considered a "sale" of Personal Information for monetary or other valuable consideration or a "sharing" of Personal Information for cross-context behavioral advertising. 

4. Sources of Personal Information

We collect Personal Information about you from the sources described in our Privacy Notice.

5. Purposes for Our Collection of Your Personal Information

We may use, "sell" for monetary or other valuable consideration, "share" for the purposes of cross-context behavioral advertising, or disclose the Personal Information we collect and, over the prior twelve (12) months, have used, "sold" for monetary or other valuable consideration, shared for the purpose of cross-context behavioral advertising, or disclosed the Personal Information we have collected, for the purposes described in our Privacy Notice as well as the following additional purposes:

• Short-term, transient use, provided the Personal Information that is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction; and
• Performing services on behalf of the Company or another service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

Company will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

6. Third Parties to Whom Do We Disclose Your Personal Information for Business Purposes

Company may disclose your Personal Information to third parties for one or more business purposes. We disclose Personal Information for a business purpose to non-affiliated third-parties, which are under contractual obligation to use it solely for the fulfilment of the purposes described in this Privacy Notice.

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for one or more of the business purposes described below to the following categories of third parties:

Identifiers: Service providers; affiliates, parents, and subsidiary organizations of Company; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company; Internet cookie information recipients, such as analytics and behavioral advertising services; government entities (including for registration and title purposes); insurance companies; equipment dealers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Service providers; affiliates, parents, and subsidiary organizations of Company; government entities (including for registration and title purposes); actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company; insurance companies; equipment dealers.

Protected classification characteristics under California or federal law: Service providers; affiliates, parents, and subsidiary organizations of Company; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company.

Commercial information: Service providers; affiliates, parents, and subsidiary organizations of Company; government entities (including for registration and title purposes); actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company; insurance companies; equipment dealers.

Internet or other similar network activity: Service providers; affiliates, parents, and subsidiary organizations of Company; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.

Geolocation data: Service providers; affiliates, parents, and subsidiary organizations of Company; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company; equipment dealers.

Professional or employment-related information: Service Providers; affiliates, parents, and subsidiary organizations of Company; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company.

Sensitive Personal Information ("Sensitive Personal Information"):

• Government identifiers (social security, driver's license, state identification card, or passport number): Service providers; affiliates, parents, and subsidiary organizations of Company; government entities (including for registration and title purposes); insurance companies; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company.
• Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password): Service providers; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company.
• Precise geolocation (within an area of less than 1850 feet). Service providers; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company; equipment dealers.
• Racial or ethnic origin. Service providers; government entities; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company.
• Health; sex life; or sexual orientation information. Service providers; government entities; actual or potential buyer or successor in interest of one or more Financial Product or Service accounts, the Company's account portfolio, or of the entire Company.
  
  We disclose your Personal Information to the categories of third parties listed above for the following business purposes:

• Helping to ensure security and integrity of our Website and Financial Products or Services 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.
• 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 financing, providing analytic services, providing storage, or providing similar services on behalf of us.
• 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 (including our Website and Financial Products or Services), 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 (including for required regulatory reporting), 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. 

7. To Whom Do We Sell or Share Your Personal Information

"Sale" of Your Personal Information for Monetary or Other Valuable Consideration

As noted in our Privacy Notice, we do not sell Personal Information as the term "sell" is commonly understood to require an exchange for money. However, the use of advertising and analytics cookies on our Websites is considered a "sale" of Personal Information as the term "sale" is broadly defined in the CCPA to include both monetary and other valuable consideration. Using this broad definition, our "sale" is limited to our use of third-party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our Websites. Our "sales" of your Personal Information in this matter is subject to your right to opt-out of those sales (see Your Choices Regarding our "Sale" or "Sharing" of your Personal Information). The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

"Sharing" of Your Personal Information for Cross-Context Behavioral Advertising

Company may "share" your Personal Information for the purpose of cross-context behavioral advertising, subject to your right to opt-out of that sharing (see Your Choices Regarding our "Sale" or "Sharing" of your Personal Information). Our "sharing" for the purpose of cross-context behavioral advertising would be limited to our use of third-party advertising cookies and their use in providing you cross-context behavioral advertising (i.e., advertising on other websites or in other mediums). When the recipients of your Personal Information disclosed for the purpose of cross-context behavioral advertising are also permitted to use your Personal Information to provide advertising to others, we also consider this disclosure as a "sale" for monetary or other valuable consideration under the CCPA.

In the preceding twelve (12) months, Company has "sold" for monetary or other valuable consideration, or "shared" for the purpose of cross-context behavioral advertising, the following categories of Personal Information to the following categories of third parties:

Identifiers: We sell and share this category of Personal Information for advertising and analytics purposes to the following categories of third parties: business partners; advertisers and advertising networks; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): We do not sell or share this category of Personal Information.

Commercial information: We do not sell or share this category of Personal Information.

Internet or other similar network activity: We sell and share this category of Personal Information for advertising and analytics purposes to the following categories of third parties: business partners; advertisers and advertising networks; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.

Professional or employment-related information: We do not sell or share this category of Personal Information.

L. Sensitive Personal Information:

• Government identifiers (social security, driver's license, state identification card, or passport number): We do not sell or share this category of Personal Information.
• Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password): We do not sell or share this category of Personal Information.
• Precise geolocation (within an area of less than 1850 feet): We do not sell or share this category of Personal Information.
• Racial or ethnic origin: We do not sell or share this category of Personal Information.
• Health; sex life; or sexual orientation information: We do not sell or share this category of Personal Information.

Sale of Personal Information of Minors Under the Age of 16

We do not have any actual knowledge that we "sell" the Personal Information of minors under the age of 16 for monetary or other valuable consideration and we do not have any actual knowledge that we "share" such Personal Information for cross-context behavioral advertising without affirmative consent as required by the CCPA. More information on how minors under the age of 16 may change their choice regarding the "sale" or "sharing" of their Personal Information can be found in Your Choices Regarding our "Sale" or "Sharing" of Your Personal Information.

8. Privacy Requests

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CCPA Privacy Rights.

• Right to Know. You have the right to request that Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a "Right to Know" Privacy Request). This includes: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which that Personal Information came from; (c) our purposes for collecting this Personal Information; (d) the categories of third parties with whom we have shared your Personal Information; and (e) if we have "sold" or "shared" or disclosed your Personal Information, a list of categories of third parties to whom we "sold" or "shared" your Personal Information, and a separate list of the categories of third parties to whom we disclosed your Personal Information to. You must specifically describe if you are making a Right to Know request or a Data Portability Privacy Request (as defined below). If you would like to make both a Right to Know Privacy Request and a Data Portability Privacy Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Privacy Request a total of two (2) times within a 12-month period at no charge.
• Access to Specific Pieces of Information (Data Portability). You also have the right to request that Company provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third-party about you (a "Data Portability" Privacy Request). If you make a Data Portability Privacy Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third-party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Privacy Request and a Data Portability Privacy Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. In response to a Data Portability Privacy Request, we will not disclose your social security number, driver's license number or other government-issued identification number, financial account number, or your account password or security question or answers. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your Personal Information, your account with Company, or the security of our systems or networks. We will also not disclose any Personal Information that may be subject to another exception under the CCPA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of personal information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Privacy Request a total of two (2) times within a 12-month period at no charge.
• 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 CCPA 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 CCPA.
• Deletion. You have the right to request that Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Privacy Request (see Exercising Your CCPA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the CCPA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction or provide you the goods and services for which we collected the Personal Information or otherwise perform under our contract with you, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it. 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.
• Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following as a result of you exercising your CCPA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Privacy Rights

To exercise the rights described above, please submit a request (a "Privacy Request") to us by either:

·       Filling the online form available [here]; or

• Emailing us at Privacy-NA@cnhind.com.
• Calling us at our Toll-Free Customer Care Number at +1 (800) 501-5711.

If you fail to make your Privacy Request 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, or your Authorized Agent that you authorize to act on your behalf, may make a Privacy Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Privacy Requests must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person as described below. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
   

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. For all requests, we will need your (i) name; (ii) email address, and (iii) telephone number.

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 all or a portion of 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. You may also be asked to complete and provide a signed declaration under penalty of perjury that you are the Data Subject who is the subject of the request or their Authorized Agent in certain circumstances. We will only use Personal Information provided in a Consumer Request to verify the requestor's identity or authority to make the request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent. Making a Privacy Request does not require you to create an account with us. However, we do consider requests made through your password protected online account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a Privacy Request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Your Choices Regarding our "Sale" or "Sharing" of Your Personal Information.

Authorized Agents

You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State or by providing them with power of attorney to exercise your rights in accordance with applicable laws (an "Authorized Agent"). We may request that your Authorized Agent submit proof of identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

Response Timing and Format

We will confirm our receipt of your Privacy Request within ten (10) business days of its receipt. We will generally process these requests within forty-five (45) calendar days of its receipt. If we require more time (up to an additional 45 calendar days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

In response to a Right to Know or Data Portability Privacy Request, we will provide you with all relevant information we have collected or maintained about you on or after January 1, 2022, unless an exception applies. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability Privacy Request, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your Privacy Request unless it is excessive, repetitive, or manifestly unfounded. We reserve the right to consider more than two (2) total Right to Know or Data Portability Privacy Requests (or combination of the two) in a twelve (12) month period to be repetitive and/or excessive and require a fee. If we determine that your Privacy Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9. Your Choices Regarding our "Sale" or "Sharing" of Your Personal Information

"Sale" of Your Personal Information

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information for monetary or other valuable consideration at any time (the "right to opt-out"). We do not sell the Personal Information of Data Subjects we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Data Subject who is between 13 and 16 years of age, or the parent or guardian of a Data Subject less than 13 years of age. Data Subjects who opt-in to Personal Information sales may opt-out of future sales at any time.

"Sharing" of Your Personal Information

If you are 16 years of age or older, you have the right to direct us to not share your Personal Information for the purposes of cross-context behavioral advertising, which is showing advertising on other websites or other media based on your browsing history with our Website (the "right to opt-out"). We do not share the Personal Information of Data Subjects we actually know are less than 16 years of age for this purpose, unless we receive affirmative authorization from either the Data Subject who is between 13 and 16 years of age, or the parent or guardian of a Data Subject less than 13 years of age. Data Subjects who opt-in to our sharing of Personal Information for these purposes may opt-out of future such sharing at any time.

How You May Opt-Out of Our Sale or Sharing of Your Personal Information

To exercise the right to opt-out of the "sale" of your Personal Information for monetary or other valuable consideration and of "sharing" your Personal Information for the purposes of cross-context behavioral advertising, you (or your Authorized Agent) may adjust your cookie preferences by visiting the "Do Not Sell or Share My Personal Information" or "Cookies Settings" links on the footer of the Websites, or by configuring your browser to send us a privacy signal as described in more detail below.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into the sale of Personal Information at any time by adjusting the settings through the same links.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

If you (or your Authorized Agent) submit a request to opt-in to our "sale" or "sharing" of your Personal Information, we will use a two-step process in order to confirm that you want to opt-in for such "sale" or "sharing" of your Personal Information. This process may require confirmation of your choices.

Browser Privacy Control Signals

You may also exercise your right to opt-out of the "sale" of your Personal Information for monetary or other valuable consideration and "sharing" your Personal Information for the purposes of cross-context behavioral advertising by setting the privacy control signal on your browser, if your browser supports it. We currently recognize and support the following privacy signals sent by browsers:

·       Global privacy control (for more information on how to configure your browser to send this signal, please see https://globalprivacycontrol.org/).

When we receive one of these privacy control signals, we will opt you out of any further "sale" or "sharing" of your Personal Information when you interact with our Websites through that browser and on that device. We will only be able to propagate your choice to opt-out to your account if you are currently logged in when we receive the privacy control signal from your browser. When we are able to propagate your choice to your account, you will be opted out of "sale" or "sharing" of your Personal Information on all browsers and devices on which you are logged in, and for both online and offline "sales" and "sharing."

10. Your Choices Regarding our Use and Disclosure of Your Sensitive Personal Information

As further described below, we do not use or disclose your Sensitive Personal Information for any purpose other than the following:

• to perform the services or provide the goods reasonably expected by an average Data Subject who requests such goods or services;
• to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal Information, provided that our use of your Personal Information is reasonably necessary and proportionate for such purposes;
• to resist malicious, deceptive, fraudulent, or illegal actions directed at Company and to prosecute those responsible for those actions, provided that our use of your Personal Information is reasonably necessary and proportionate for this purpose;
• to ensure the safety of natural persons, provided that our use of your Personal Information is reasonably necessary and proportionate for this purpose;
• for short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that the Personal Information is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
• to perform services on behalf of us, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us; and
• 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 by, manufactured for, or controlled by us. 

11. Personal Information Retention Periods

We retain all categories of your Personal Information for as long as necessary to pursue the purposes described in this Privacy Notice. However, we may also retain any or all categories of Personal Information when your information is subject to one of the following exceptions:

·       When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated.
·       When necessary for us to exercise or defend legal claims.
·       When necessary to comply with a legal obligation.
·       When necessary to help ensure the security and integrity of our Website and IT systems.

Your Personal Information will be deleted when we no longer require your Personal Information for any of the above purposes.

12. Changes to This CALIFORNIA Privacy Addendum

Company reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Websites and update the addendum's effective date. Your continued use of our Websites or any Financial Product or Service following the posting of changes constitutes your acceptance of such changes.

13.Contact Information

If you have any questions or comments about this California Privacy Addendum, the ways in which Company collects and uses your information described above and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 North America Data Privacy Manager

Email: Privacy-NA@cnhind.com

Postal Address: CNH Industrial America LLC

Attn: Legal

6900 Veterans Blvd

Burr Ridge, IL 60187

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