PRIVACY STATEMENT

January 2012

Mercedes-Benz USA, LLC (˜MBUSA˜) and smart center Fairfield appreciates your interest in its products and your visit to its Internet site, MBUSA.com (the ˜Site˜). Your privacy is important to us and we want you to feel comfortable visiting our Site. Protecting your privacy in the processing of your personal data is an important concern to which we pay special attention. Therefore, this online privacy statement tells you about the information MBUSA and smart center Fairfield collects through the services available on our Site, how we use that information, and how you can opt out of certain uses of information we may collect. By using our services and accessing our Site, you are consenting to the information collection and use practices described in this online privacy statement, as modified from time to time by us. If we decide to change this online privacy statement, we will post a new online privacy statement on our Site and change the date at the top of the online privacy statement. Therefore, we encourage you to check the date of our online privacy statement whenever you visit this Site for any updates or changes. Our online privacy statement complies with the Daimler AG (˜DCAG˜) Data Protection Code of Conduct applicable company-wide for Daimler AG, including the MBUSA Code of Conduct. Our Site may include, however, links to other websites which are not covered by this online privacy statement. These sites have their own privacy and information security policies and terms and conditions. Please review the privacy policy and terms and conditions sections of such websites for additional details.

ACCESSING AND UPDATING YOUR INFORMATION

You may update, review, or correct your Personal Information at any time online by accessing your password-protected registration page via the ˜Online Portfolio˜ at www.mbusa.com. You may also email smart center Fairfield or call us at 1-800-FOR-MERCEDES (1-800-367-6372).

Freedom of Choice
If you do not want your Personal Information to be made available to any third party, please contact us at mailmaster@mbusa.com so we can block your data accordingly. Note, however, that certain services and/or functions of our Site may not be available if you elect to block your Personal Information. Further, if, in connection with your use of a particular service, we ask to use your Personal Information in a way not described in this online privacy statement and you do not wish to permit that use, you can choose not to use that particular service. Otherwise, your use of such service will be your consent to the use of your Personal Information in the way described.

Email Communication
You will only receive email from MBUSA if you have requested to be on our mailing list. If you are currently on our list and would prefer not to receive further information from us, click here. To sign up for news, updates, and information from MBUSA via e-mail, visit www.mbusa.com

Your California Privacy Rights
Under California´s ˜Shine the Light˜ law, California residents who provide Personal Information while obtaining products or services for personal, family, or household use are entitled, once per calendar year, to request and obtain from us information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the previous calendar year (e.g. requests made in 2005 will receive information regarding 2004 sharing activities).
To obtain this information on behalf of MBUSA, please e-mail us with ˜Request for California Privacy Information˜ in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

Children´s Online Privacy Protection Act (COPPA)
Our Site is a general audience site that is not designed nor intended to collect Personal Information from children under the age of 18. MBUSA does not knowingly collect or maintain any Personal Information from children under the age of 18. In addition, no part of this Site is designed with the purpose of attracting any person under age 18. To respect the privacy of children and to comply with the Children´s Online Privacy Protection Act, children under the age of 18 should not provide any Personal Information on this Site. We ask that parents supervise their children while online.

Pixel Tags
We may use Pixel Tags on our Site and may permit third parties to place them on our Site to monitor the effectiveness of advertising or for other legitimate purposes. A Pixel Tag, also known as a "Web bug," is a small, graphic image on a Web page, Web-based document, or in an e-mail message that is designed to allow the site owner or a third party to monitor who is visiting a site. Web beacons are often invisible to the visitor because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document, or email message. Web beacons are represented as HTML IMG tags in the Web page; visitors can click on "view profiles" of the web page to see whether the page is using a web beacon.

Web beacons collect the IP address of the computer that the Web beacon is sent to, the URL of the page the Web beacon comes from, and the time it was viewed. Web beacons can also be linked to Personal Information. For example, advertising networks use Web beacons to add information to a personal profile of what sites a person is visiting and to determine what banner ads to display based on the profile. Another use of Web beacons is to provide an independent accounting of how many people have visited a particular website. Web beacons are also used to gather statistics about Web browser usage at different places on the Internet.

IP Address and Click-Stream Data Collection
MBUSA and smart center Fairfield may collect IP addresses and/or click-stream data for market research, for purposes of system administration and to report aggregate information. An IP address is a number that is automatically assigned to your computer whenever you access the Internet. Our servers identify your computer by its IP address. When you request web pages from our Site, our servers log your IP address.

Click-stream data is information collected by our servers when you request pages from our Site. Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view, and other such Non-Personal Information. When analyzed, this data helps us analyze how visitors arrive at our Site, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of content, and the like.

Security
MBUSA and smart center Fairfield uses commercially reasonable efforts to store and maintain Personal Information to protect it from loss, misuse, alteration, or destruction by any unauthorized party. We encrypt order information, including credit card numbers, using Secure Sockets Layer (SSL) technology to ensure that our customers´ information is safe as it is sent over the Internet to our server.

We exercise reasonable care to protect your Personal Information. This includes storing the Personal Information on our servers behind a secure firewall and ensuring all transmissions to other vendors use secure encryption technology. Unfortunately, no data transmission over the Internet can be guaranteed to be 100 percent secure. So while we strive to protect your Personal Information, we cannot guarantee the security of any information you transmit to us or receive from us. This is especially true for information you transmit to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we maintain physical, electronic, and procedural safeguards to protect your Personal Information.

When registering for access to a secure area of our Site, we will ask you to select a Username and Password. We recommend that you do not divulge your Password to anyone. We will never ask you for your Password in an unsolicited phone call or in an unsolicited email. Also, remember to sign out of the registered area of our Site and close your browser window when you have finished.

Internally, we will limit access to Personal Information to those persons who need the information to provide products and services to you or maintain or service those products or services. These persons are limited in number and are committed to our privacy and security policies. We will review our security arrangements from time to time, as we deem appropriate.

Links to Other Sites
Please be aware that we provide links to third-party sites as a service to our visitors, and that we are not responsible for the content or information collection practices of those sites. Please note that these sites´ privacy policies may differ from those of MBUSA and smart center Fairfield. We encourage you to review and understand their privacy practices before providing them with information.

Privacy Statement Revisions
A revised online privacy statement will only apply to data collected subsequent to its effective date on this version of our Site. Any revisions will be posted at least seven days prior to its effective date.

INFORMATION

We collect several types of information on our Site. Personal information is information that identifies an individual or is directly associated with a specific person, such as a customer´s name, mailing address, telephone number, email address, credit card number, or information about activities which can be directly linked to that person, such as his or her purchases (˜Personal Information˜). Our definition of Personal Information does not include ˜aggregate˜ information. Aggregate information is data about use of our Site, such as pages visited on our Site. Aggregate information helps us understand trends and customer needs so that we can better consider new products and services, and tailor existing products and services to customer desires.

We may also collect ˜Non-personal Information˜, which is information about you that does not itself identify you individually. Examples of Non-personal Information include age range and gender.

Collection of Personal Information
When you use certain parts of our Site, we collect certain kinds of Personal Information:

Owners Online Account Setup: To set up an Owners Online Account, we ask visitors to provide a valid VIN for vehicles purchased in the United States. In order to set up an Owners Online Account, we require visitors to provide a valid email address, as well as create a unique Username and Password. In addition, this area allows you to receive personalized MBUSA news and information via email. When you register for Owners Online, we may collect various kinds of Personal Information including your name, email address, home address, and home phone number. We also collect and store access information related to your account, including Username and Password.

Customer Service Correspondence: We may collect information that identifies you personally when you submit comments, questions, or suggestions to our Customer Service department.

Transactions: We collect Personal Information to fulfill an order you place on our Site for MBUSA-branded items. Such information would include name and address, credit card number and expiration date, and billing address.

Use of Personal Information
Except as disclosed in this statement, we do not sell or disclose information that identifies our visitors personally or makes it possible for other parties to contact them directly without our visitors´ consent. We may use, sell, disclose, or otherwise dispose of Personal Information we collect in the following circumstances:

Purchase Inquiry. We use the information you provide about yourself during Purchase Inquiry to contact you regarding your inquiry. We do not share this information with parties other than the MBUSA Dealer you have specified during your inquiry.

Transaction Processing. We may use your Personal Information to create a convenient and easy-to-use shopping process that includes an online ˜shopping cart˜ that allows you to track selected products and proceed through purchase. We use the information you provide about yourself when placing an order to complete that order. Also, we may share transactional information with entities as is necessary to process credit card payments or other purchasing or delivery systems. We may use your email address to communicate with you or notify you of special offers or programs you might find of interest.

Response to Inquiries. We use return email addresses to answer the email inquiries we receive. We may also use these email addresses to provide order status and order tracking information, and to respond to queries.

Gift Certificates. We may offer gift certificates by which you can personalize a product you order for another person. Information you provide to us to create a gift certificate is only used for that purpose, and it is only disclosed to the person receiving the gift.

Online Portfolio. If you choose to create an Online Portfolio or receive products or information, or to otherwise give us Personal Information, we may store some or all of that information and use it for marketing research and marketing purposes, which may include sharing it with MBUSA authorized dealerships or with various suppliers that provide marketing, research, or other services for us. To enhance your experience on our Site, we might use information you provide to us through your Online Portfolio to pre-populate forms with your name, address, phone number, and email address. In such cases, we may employ an outside research company to call you on our behalf.

Vehicle Design. If you choose to save information such as a vehicle configuration on our Site, we may contact you to follow up on your interest in our cars. In such cases, we may employ an outside research company to call you on our behalf.

Companies that work for or with MBUSA: We may, without notice to you, share Personal Information with companies that work for us for the sole purpose of providing you with valuable services you´ve requested or already have through our Site. These companies may assist us in fulfilling your requests or processing your transactions. In addition, we may share Personal Information with companies that work for us to provide marketing and other services. We may also share your Personal Information with non-affiliated persons and entities with whom we have entered into a joint marketing agreement, where we together market either our products or those of our marketing partner. We enter into contractual agreements with these companies prohibiting them from disclosing or using our customer information other than to carry out the purposes for which the information was disclosed. These companies are in no way authorized to sell, rent, or trade your Personal Information. While there are such contractual obligations in place, we cannot and do not guarantee that a third party will not breach its contractual obligation and use your Personal Information in a way contrary to this online privacy statement.

Legal Requirements. We may disclose Personal Information: (a) to conform with the law, respond to claims, or comply with legal process served on MBUSA or DCAG (e.g., a lawful subpoena, warrant, or court order); (b) to enforce or apply our policies or agreements (including to initiate, render, bill, and collect for amounts owed to us); (c) to protect and defend our or our visitor´s rights or property, the Site, our employees, visitors, or the public; or (d) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

Use of Non-Personal and Aggregate Information
We may use non-personal and aggregate information to better design our Site and share with our marketing and advertising agencies.

COOKIES

A cookie is a small text file that the browser sends to the web server with each page request. A cookie can be saved on a visitor´s hard drive as a small text file or it can be restricted to the computer´s memory where it is removed once the browser is closed. Only the cookies that are associated with a specific URL are sent to the web server; cookies that are sent from one web server are never sent to another web server. MBUSA and smart center Fairfield uses cookies to identify specific machines in order to gather aggregate data on how visitors are utilizing our Site. In some cases cookies might be used to identify a specific visitor.

Use of Cookies

We use cookies to enable MBUSA and smart center Fairfield to automate access and data entry functions of our Site and track use of the Site to determine those areas which are useful or popular and those that are not, thereby enabling us to improve and update the Site effectively. Once a visitor has registered on our Site, MBUSA may elect to use cookies to track a specific visitor. We use this information to enhance the visitor experience during future visits to our Site. We might also collect information on the browser type including plug-in versions, for example Flash or QuickTime. Another example of information we might capture is the URL where a visitor is entering or exiting our Site.

Disabling Cookies

You may adjust your Web browser to either alert you of the use of cookies or refuse to accept cookies. For Internet Explorer or AOL users, you can click on the Start button and then select Control Panel, Internet Options, and the Security tab. If you click on the Custom button, you will be able to see the cookie options. For Netscape users, in the browser, select File, Preferences, and then Advanced to view the cookie options. Be aware that if you elect not to accept cookies, the Site may not function properly or may not permit access.

Penske Privacy Policy

Updated  and Effective as of: 06/01/2012

Penske Automotive Group, Inc. is committed to respecting the privacy rights of our customers and all visitors to our corporate and dealership website properties. We are publishing this policy to advise you what information we collect, how we use that information and how your information is protected. If you have any questions or concerns regarding this policy or our websites, please contact us at corporatemarketing@penskeautomotive.com or write to us at Penske Automotive Group, Inc. 2555 Telegraph Road, Bloomfield Hills, Michigan 48302, Attn: Chief Privacy Officer.

What information does Penske Automotive Group collect?

We collect information that you provide on applications, forms, surveys and other correspondence such as your name, email address, social security number and income. We collect information about your transactions with us or others. We receive information from consumer reporting agencies, credit references, employers and insurance agencies such as your credit history, credit worthiness and information that we obtain to verify employment history or that insurance coverage is in force. We collect information from cookies (see below) and other technology to track your website usage with us and to provide you with customized content, among other things.

Disclosure of information to others

Penske Automotive Group will not rent or sell your name, address, email address, credit card information or other personal information to any third party. We may use and disclose some or all of your information to third parties as set forth herein. We require these third parties to keep your personally identifiable information secure in accordance with federal requirements such as the Gramm Leach Bliley Act, where applicable. We may use and disclose some or all of the information in accordance with applicable law as follows:

Service Providers/Marketing Partners – We provide information to third parties to assist us in servicing accounts, administering and enforcing our accounts, providing services to our dealerships or our customers and responding to customer inquiries. We also may use marketing and other firms to assist us in our own marketing efforts. These third party service providers may use customer information to perform contracted services at our request. We require these third parties to keep your personally identifiable information secure in accordance with federal and other applicable requirements, and our contracts with these third parties require that your information be used only to perform the contracted services.

Others – We are required to report sale related information to our manufacturer partners and government agencies. In addition, we may buy and sell assets or businesses such as automobile dealerships. When this occurs, customer information generally is transferred to the acquirer. We also disclose information about you to third parties in certain other circumstances, as permitted by law, or to process a transaction requested by you. This privacy policy does not apply to the use of your information by third parties.

Audits/Judicial Proceedings – We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on our website.
Does this policy apply to Penske Automotive Group’s affiliates or other sites that are linked from this site?
No, this policy applies only to Penske Automotive Group, this site and our dealerships’ sites. As described above, we may share information obtained from this site with our partners and other third parties. While we expect that these others will respect your privacy in a manner consistent with our policies, we cannot guarantee that they will do so.

Use of Cookies

We may use cookies or other tracking methods to recognize you and your access privileges on this site, to facilitate the interaction between you and this site, and to track site usage. In addition, we may embed the services of third parties to enhance the functionality of our site, and those third parties may use cookies or other tracking methods in order to provide these services, track site usage, or for other reasons. You, of course, have the option of refusing to accept cookies from this or any other site by, for example, changing your browser preferences or using commercially-available software. However, if you refuse the cookies from these sites, you may find that some services do not function properly or may be considerably slower.
“Cookies” are small strings of text that are transmitted to a user’s computer when the user accesses a website, and then stored on the user’s computer for future access by the cookie provider. Cookies are part of the flow of information between a user’s computer and web servers, and are widely used on the web for, among other things, customizing user interaction with websites.

Security

The security of customer information is very important to us and we take a number of steps to safeguard it. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard non-public personal information about you.
When our credit pre-approval form asks users to enter sensitive information (such as social security number), that information is encrypted and is protected with 128-bit or greater SSL encryption software, an industry standard for reputable organizations. While on a secure page, such as our credit pre-approval application form, the website address will begin with https://......
Furthermore, once the information has been received by us, we use security procedures and policies commensurate with industry standards to safeguard against loss, theft, unauthorized access, destruction, use, modification and/or disclosure.

Links

This website contains links to other sites. Please be aware that Penske Automotive Group is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personal information. This privacy statement applies solely to information collected by this website.

Notification of Changes

We retain the right to change this privacy policy at any time. We will post those changes to this page so that users are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We will use, share, and disclose all information in accordance with the privacy policy in effect at the time the information was collected.

Children

Penske Automotive Group does not knowingly allow anyone under the age of 16 to participate in any services offered on our website which requires the submission of user information. If we learn that a user is under 16 and has submitted user information to us, we will delete that information as promptly as possible.

Your Consent

As a condition to using the Penske Automotive Group site, we require your approval to collect this data. By visiting penskeautomotive.com or any of our affiliated dealership sites, you agree that we may collect and use this information as stated in our privacy policy. If we change our privacy policy, we will post the changes on this page so you are always informed about what information we collect, how we use, and under what circumstances we disclose it.
Thank you for taking the time to review Penske Automotive Group’s privacy policy. Should you have questions or require additional information, please contact us at the email or postal address in the first paragraph above.

TERMS OF USE

Penske Automotive Group operates this site and is making it available to you upon these Terms of Use and subject to our Privacy Policy. By using this site, you signify that you accept these Terms of Use and our Privacy Policy. Do not use the site if you do not accept these Terms of Use or our Privacy Policy. Please note that we reserve the right, at our discretion, to modify these Terms of Use and our Privacy Policy at any time without notice, so you should check these Terms of Use and our Privacy Policy periodically for modifications. Your continued use of this site following the posting of such modifications will mean that you accept these Terms of Use and our Privacy Policy, as modified.

Use of Information

This site, including the information contained on this site, is protected by copyright and trademark laws under U.S. and International law. Penske Automotive Group and/or third-party information providers own all information on this site, and you do not acquire any ownership rights by accessing, downloading or printing the information.
If you are a personal user, you may access, download and print information on this site for your personal, non-commercial home use only. If you are a company user, you may access, download and print information on this site for your company's internal use only. In either case: (1) you must retain all copyright and other proprietary notices on all copies of the downloaded or printed information, and (2) you may not modify the information, or reproduce, publicly display, distribute or otherwise use the information for any public or commercial purpose. The use of any information from this site on any other website or networked computer environment (including for purposes of establishing a link to this site) is prohibited.
Penske Automotive Group does not grant you any express or implied right under any patents, trademarks, copyrights or trade secret information, other than the limited right to access, download and print information as described in the preceding paragraph. In particular, without prior written authorization from Penske Automotive Group, you are prohibited from using or copying the name, mark, logo, picture or image of Penske Automotive Group or any derivation thereof.

Submissions by You

We request that you not send us any unsolicited confidential or proprietary information, including trade secrets, ideas, concepts or know-how. If despite our request you or someone acting on your behalf furnishes us unsolicited information, you acknowledge that Penske Automotive Group will be under no obligation to treat such information confidentially and Penske Automotive Group and their affiliates will have an unrestricted, irrevocable, worldwide, royalty-free license to use, reproduce, display, transmit and distribute such information.

Third-Party Sites

As a convenience to you, we provide links on this site to websites operated by other entities, including Penske Automotive Group affiliates. These sites are beyond our control, and the sites may have practices or policies that are different from those described in these Terms of Use or our Privacy Policy. Penske Automotive Group makes no representations or warranties regarding these other websites or any information appearing on such sites. In addition, links from this site do not imply that Penske Automotive Group sponsors or endorses these other sites or any of the products or services described there.

Disclaimer and Limitation of Liability

This site is licensed and operated by Penske Automotive Group located in Bloomfield Hills, Michigan, and is an automotive dealership operation consisting of the dealerships, vehicle models, vehicle inventory and/or marketing content represented in this site and its subsidiary sites. The information within this site is provided "as is". No warranty is expressed or implied to the fullest extent permissible by applicable law. Penske Automotive Group and any of its providers of information do not warrant error-free or uninterrupted service of this site. Please note that this site is operated in Bloomfield Hills, Michigan and therefore all disclaimers are predicated on applicable Michigan or U.S. laws and standards. Visitors from outside Michigan or U.S. should be aware that Penske Automotive Group makes no representation that this site and the information contained herein is appropriate or available for use in other areas. Those who enter this site from outside Michigan or U.S. do so at their own initiative and are directly responsible for compliance with their local laws to the extent those laws apply.

All vehicles are sold on an "as-is" basis unless stated otherwise. Prices, sales tax and shop supplies are posted where applicable. Vehicle pictures may not represent actual vehicle. Prices and special offers are subject to change. Mileage listings are estimates and are not necessarily accurate odometer readings. Some vehicle information and vehicle pricing may be unintentionally missing or inaccurate, and Penske Automotive will endeavor to correct such discrepancies in a commercially reasonable manner upon Customer notification of such errors or omissions, but pricing errors and listing errors are considered invalid and may or may not be honored at the sole discretion of Penske Automotive Group and its participating dealerships. Payment calculator should not be used for exact finance amounts. Daily changes in inventory may result in the unavailability of certain vehicles listed on-line.

THIS SITE, AND THE INFORMATION PROVIDED HEREIN, MAY CONTAIN INACCURACIES AND TYPOGRAPHICAL ERRORS. PENSKE AUTOMOTIVE GROUP DOES NOT WARRANT THE ACCURACY OR COMPLETENESS OF THIS SITE, OR THE INFORMATION PROVIDED HERE, OR THE RELIABILITY OF ANY ADVICE, OPINION, STATEMENT OR OTHER INFORMATION DISPLAYED OR DISTRIBUTED THROUGH THIS SITE. YOU ACKNOWLEDGE THAT ANY RELIANCE ON ANY SUCH ADVICE, OPINION, STATEMENT OR OTHER INFORMATION WILL BE AT YOUR SOLE RISK. PENSKE AUTOMOTIVE GROUP ALSO DOES NOT WARRANT THAT THE FUNCTIONS CONTAINED IN THIS SITE WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THIS SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.

THIS SITE, AND THE INFORMATION PROVIDED HEREIN, ARE PROVIDED "AS IS" WITHOUT ANY REPRESENTATION OR WARRANTY, EXPRESS OR IMPLIED, OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, NONINFRINGEMENT, OR FITNESS FOR ANY PARTICULAR PURPOSE. SOME JURISDICTIONS DO NOT ALLOW FOR THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU.

IN NO EVENT WILL PENSKE AUTOMOTIVE GROUP, OR ANY OF THEIR AFFILIATES OR ADVERTISERS OR SPONSORS BE LIABLE TO ANY ENTITY FOR ANY DIRECT, INDIRECT, SPECIAL, CONSEQUENTIAL OR OTHER DAMAGES (INCLUDING, WITHOUT LIMITATION, ANY LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF INFORMATION OR PROGRAMS OR OTHER DATA ON YOUR INFORMATION HANDLING SYSTEM) THAT ARE RELATED TO THE USE OF, OR THE INABILITY TO USE, THE CONTENT, MATERIALS, AND FUNCTIONS OF THIS SITE OR ANY LINKED WEBSITE, EVEN IF ANY OF THEM IS EXPRESSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.