DEALERSHIP - PRIVACY POLICY

Updated: May 26, 2025

OUR APPROACH TO PRIVACY

We are committed to protecting the privacy of your personal information ("Personal Information" or "PI") and the responsible use of that information to deliver personalized, relevant content to our customers. This Privacy Policy applies to this website or mobile application and the websites and mobile applications that display this Privacy Policy (collectively, "Sites"). It also describes our policies and procedures for the collection, use, and disclosure of your information and data on these Sites and the services available through them ("Services").

INFORMATION WE COLLECT

The Personal Information we collect may include your contact details such as your name, postal and email address, and phone number. It also includes information you provide when communicating with us via email, mail, phone, chat or text. We collect data about your vehicle, including sales and service history, vehicle payments, VIN, and mileage. When you apply for vehicle financing or make purchases, we may collect your driver’s license number, insurance policy numbers, social security number, and other financial or credit-related information. Payment information is collected to process transactions. We also collect details about your online activity and personal preferences when using our Sites and Services, as well as social media details and any other information you choose to share on those platforms. Additionally, we collect technical information such as your IP address, browser type, device type, pages visited, geolocation data, and the date and time of your visit.

HOW WE COLLECT INFORMATION

We collect Personal Information in a number of ways. This includes information you choose to provide through our Sites or Services, as well as information obtained from affiliates, automotive manufacturers, subcontractors, vendors, and third-party providers including marketing agencies, advertising networks, credit reporting agencies, social media platforms, data brokers, and online lead providers. We also collect information automatically from devices you use to access or interact with our Sites and Services. Additionally, we may collect information during communications via email, mail, phone, chat or text, and may retain copies or recordings of those interactions.

HOW WE USE YOUR INFORMATION

We use your Personal Information to provide our Services, communicate with you, respond to inquiries, and customize the information and ads you see. This includes targeted advertising on platforms like Google, Bing, YouTube, Facebook, and Instagram. We use your information to process transactions, verify customer identity, confirm eligibility for manufacturer rebates, and provide or facilitate financing. Additionally, we analyze and operate our Sites and Services by aggregating and combining your information with non-personal data. This helps us improve the quality and value of our offerings. We may also use your information to defend against or respond to legal claims. Importantly, we do not engage in profiling that results in legal or similarly significant effects.

WHO WE SHARE YOUR INFORMATION WITH

We may share your Personal Information with our affiliates, automotive manufacturers, and trusted third-party service providers (our "Suppliers") who perform services on our behalf. We may also share your information in connection with a corporate acquisition, merger, or sale of assets. Sharing may also occur as required by applicable law. While we assess our Suppliers to ensure they meet industry and legal standards, we do not control how they use the data. Therefore, we recommend reviewing their individual privacy policies in addition to ours.

EXTERNAL LINKS: DATA USE BY THIRD PARTIES

Our Sites and Services may link to other websites operated by third parties. Once you leave our Sites, we do not control the information collected by these external websites. Third-party advertisers and partners may collect information from you directly or through tracking technologies embedded on our Sites. We are not responsible for the privacy policies or practices of any third-party websites or services. We encourage you to review their terms and policies directly.

COOKIES, ETC.

We use a number of technologies to automatically collect information, including cookies, tracking pixels, and web beacons. Our Sites include a notice that we use “Cookies,” which are small text files sent from a web server that are stored on your device and enable a site to remember you or your preferences. We may use cookies to recognize you and optimize your experience when visiting our Sites and using our Services. Tracking pixels are small images used to track users, typically for advertising or analytics purposes. Web beacons allow data to be exchanged between systems. Our Sites may also be monitored by third-party software that may capture information about your visit to help us improve the quality of our Sites and Services. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. However, if you do not accept cookies, you may not be able to use all of the features of our Sites or Services. Some browsers incorporate a “Do Not Track” (DNT) feature that, when turned on, signals to websites and online services that you do not want to be tracked. However, as there is no accepted standard for how to respond to DNT signals, we do not currently support DNT signals, other than cookies.

HOW WE PROTECT YOUR DATA

We employ data safeguards that comply with applicable federal and state law, including the updated FTC Safeguards, and in accordance with industry standards, to preserve the integrity and security of your Personal Information. However, we cannot guarantee the security of information you provide us with certainty or warrant it will not be accessed, disclosed, altered, or destroyed by unauthorized persons. We will make all legally required disclosures of any breach of the security, confidentiality, or integrity of your PI, in the manner and within the time periods required by applicable law.

DATA RETENTION

We retain your information only for as long as it is necessary and relevant for the purposes described in this Privacy Policy, and as required by applicable law.

OUR POLICY TOWARDS CHILDREN

Our Sites and Services are not targeted to nor intended for use by children. We are concerned about the privacy and safety of children when they use the internet. Accordingly, we will not knowingly request Personal Information from anyone under the age of 13 without prior, verifiable parental consent.

JURISDICTIONS

Your Personal Information is collected and used by us within the United States. We make no representation that our Privacy Policy complies with the laws of any foreign jurisdictions, including the European Union’s General Data Privacy Regulation. If you choose to provide us with PI from outside the United States, you do so at your own risk and are responsible for compliance with any applicable foreign laws.

COMPLIANCE WITH LAW ENFORCEMENT

We cooperate with government and law enforcement officials, as well as private parties, to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties that we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, including subpoenas, to protect our rights or that of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be, or may pose a risk of being, illegal, unethical or subject to legal action.

CORPORATE TRANSFERS

In connection with a corporate merger, acquisition, divestiture, asset sale, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves some or all of our assets, including your Personal Information.

CHANGES TO OUR PRIVACY POLICY

We may modify our Privacy Policy, at any time and for any reason, by posting the revised Privacy Policy on our Site. Your use of our Sites or Services after any such posting indicates your acceptance of our modified Privacy Policy.

STATE PRIVACY LAWS

Some states have adopted privacy laws and regulations that provide their residents with additional rights (collectively, State-Specific Privacy Laws). These states include California (pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act), Virginia (pursuant to the Virginia Consumer Data Protection Act), Colorado (pursuant to the Colorado Consumer Privacy Act) and Connecticut (pursuant to the Connecticut Data Privacy Act). If you are a resident of one of these states, then you have certain rights concerning your Personal Information, including:
- The right to know how and for what purpose we collect it
- The right to access your information and request corrections to inaccurate information
- The right to opt-out of it being sold to third parties
- The right to opt-out of targeted advertising
- Subject to certain exclusions for legitimate business purposes, the right to have it deleted

In addition, Nevada privacy laws requires website operators to provide a way for Nevada residents to opt-out of the sale of certain information that website operators collect about them.

Furthermore, California privacy laws provides employees and job applicants who are California residents with certain rights with respect to their Personal Information. Accordingly, such employees and job applications should review our Privacy Policy to see the types of PI we collect and how we use it.

Other states are in the process of enacting their own privacy laws. As they do, residents of those states may have rights similar to those above with respect to their information. We will continue to monitor federal and state privacy law developments and update our policies and procedures as needed to comply with any additional State-Specific Privacy Laws.

If you have further inquiries about your information under a State-Specific Privacy Law, or are a resident of one of those states and wish to access, correct, opt-out or have your information deleted, please contact us as specified below under “How to Contact Us”. We will need to verify your identify before taking any action, in order to protect against the unauthorized disclosure or deletion of PI.

FORDDIRECT DATA USE

We work with FordDirect to provide us with advertising and related services, and analytics. This includes, but is not limited to, the deployment of tracking technologies on our properties that collect and provide information about you to FordDirect or our provision of your name, email address, and other contact details to FordDirect, including for advertising and related services and analytics. To the extent we disclose information to FordDirect, FordDirect may use that information in accordance with its own privacy statement. For details on FordDirect’s data practices, see: FordDirect Privacy Statement.

HOW TO CONTACT US

If you have any questions or concerns regarding your privacy when using our Sites or Services, or are a resident of one of the states listed above and wish to exercise your rights under an applicable State-Specific Privacy Law, please email us at privacy@datadrivenholdings.com. California residents may also call us toll-free at 1-888-565-6043. We will make every effort to promptly respond and address your concerns.