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The policy authorizes collection of AI assistant interaction data including full transcripts, navigation destinations, contacts, call history, and discussion topics from both in-vehicle AI assistants and GM mobile apps, with disclosure limited to service providers acting on GM's behalf and law enforcement under warrant or court order.
This analysis describes what General Motors's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a data collection category encompassing conversation transcripts and personal contact data generated through AI assistant use, creating a detailed behavioral and relational data record tied to vehicle and app operation that is subject to government access requests under the policy's stated warrant-or-court-order standard.
The updated statement narrowed its definition of personal information from 'identifies, relates to, or could reasonably be linked to you' to 'describes, relates to, or could reasonably be linked to you.' This language change affects which information GM must treat as personal information under the policy. The revised de-identification section reorganizes prior language, now stating GM 'may use technical measures to remove information that could reasonably identify you or your vehicle' and requires 'the same safeguards from any third parties we share it with.' The policy clarifies that its protections apply to personal information dealers disclose to GM, but do not cover dealers' independent data practices. Cruise is no longer listed as a GM affiliate exempt from this privacy statement, though the scope of privacy protections for Cruise users depends on whether Cruise now operates under this statement or maintains separate privacy terms.
View change record →The agreement authorizes collection of AI assistant interaction data including conversation transcripts, navigation destinations, contacts, and call history when users interact with AI assistants in GM vehicles or mobile apps; this data may be disclosed to service providers for product development and retained subject to the policy's general retention framework.
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"If you use artificial intelligence (AI) assistants in your vehicle or our Vehicle Mobile Apps, we may collect information about those interactions. This includes information you choose to share with the assistant and information about what you are trying to do when you use it. Depending on how you use the assistants, this may include, for example, the transcript of your interactions, places you ask it to navigate to, your contacts, call history, and details or comments related to the topics you discuss with it.Excerpt from General Motors's GM Privacy Statement
(1) REGULATORY LANDSCAPE: AI assistant interaction data collection, particularly transcripts and contact data, engages state biometric and voice data frameworks; Illinois BIPA may apply where voice data is processed in ways that create voiceprints or biometric identifiers. The FTC Act applies to unfair or deceptive collection practices. California's CPRA may classify certain AI interaction data as sensitive personal information depending on content. The EU AI Act is not directly applicable to this U.S. policy but may be relevant for cross-border deployments. (2) GOVERNANCE EXPOSURE: High. The breadth of AI assistant interaction data collected, including transcripts, contacts, and call history, represents a sensitive behavioral data category. The policy limits disclosure to service providers without independent use rights and to law enforcement under warrant, but the scope of data accumulated over time creates significant governance obligations around data minimization, retention, and access controls. (3) JURISDICTION FLAGS: Illinois BIPA creates heightened exposure if voice data is processed to derive biometric identifiers. California CPRA may require opt-out rights for AI-derived inferences. Washington's My Health MY Data Act could apply if AI interaction data is used to infer health conditions. Any jurisdiction requiring explicit consent for voice recording or transcript retention creates additional compliance obligations. (4) CONTRACT AND VENDOR IMPLICATIONS: Service providers receiving AI assistant interaction data are stated to have no independent right to use this data, which must be confirmed in underlying data processing agreements. If third-party AI platforms (such as Google Assistant integrations) process this data, the scope of GM's contractual controls over those platforms should be assessed. (5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the current consent mechanism for AI assistant interaction data collection is sufficient under applicable state voice recording, biometric, and sensitive data laws. Data mapping should confirm what AI interaction data is retained, for how long, and under what access controls. If third-party AI providers are involved, vendor agreements should be reviewed to confirm alignment with the policy's stated disclosure limitations.
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This provision establishes a data collection category encompassing conversation transcripts and personal contact data generated through AI assistant use, creating a detailed behavioral and relational data record tied to vehicle and app operation that is subject to government access requests under the policy's stated warrant-or-court-order standard.
The agreement authorizes collection of AI assistant interaction data including conversation transcripts, navigation destinations, contacts, and call history when users interact with AI assistants in GM vehicles or mobile apps; this data may be disclosed to service providers for product development and retained subject to the policy's general retention framework.
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