Privacy Policy

Last updated and effective as of November 10, 2019.

This privacy policy (“Policy”) describes how Tradevantage LLC and its affiliates (“TradeVantage”, “we”, “us” or “our”) collect, protect and use personally identifiable and other information that you, whether acting as an individual or on behalf of an entity, including you and all persons, entities, or digital engines of any kind that harvest, crawl, index, scrape, spider or mine digital content by an automated or manual process or otherwise (collectively, “user”, “you” or “your”), may provide in connection with your use of our website and any of our services (collectively, “Website” or “Services”). This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Please read this Policy carefully. By visiting the Website or utilizing our Services, you are consenting to our collection, use, disclosure, retention and protection of information about you and devices you use as described in this Policy, and you agree to be bound by this Policy. You acknowledge that you have read this Policy and agree to all its terms and conditions. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website or our Services. We also direct you to our Terms and Conditions which govern your use of the Website and our Services.

Collection of Personal Information

We generally collect personally identifiable information with your specific knowledge and consent. For example, when you register for a TradeVantage account through our Website you may be provided with or required to choose a username and password and you are required to provide specific information about you and your vehicle. Such information may include without limitation your first and last name, date of birth, email address, telephone number, home or other physical address, credit card information, driver’s license number, your motor vehicle’s make, model, trim, model year, mileage, color, options, vehicle identification number (“VIN”), and license plate number. We may receive and store any information you, (or the devices you use to access the Website or Services) provide to us when using our Website or our Services including without limitation all information in connection with your creation of a TradeVantage account, purchase of our Services, subscription for any of our content or programs, completion of any forms on the Website, including without limitation any registration form or vehicle questionnaire in connection with our Resale Guarantee Service, or in connection with any other communication or transaction with us. You may choose not to provide us with certain information, but as a result you may not have access to some of the Website’s features or certain of our Services. Users who are uncertain about what information is mandatory after reviewing this Policy and consulting the Terms and Conditions may contact us at support@TradeVantage.com.

We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if you follow a link in an email we send to you. We may obtain information about you from affiliates, partners and other third parties. This information may include information about your use of this Website or our Services, your use of other websites, your interactions with or purchases from [partner automobile dealers,] your interests and preferences and other information about you or your household. We may combine the information we obtain from third parties with information that we or our affiliates have collected about you.

Automatic Collection of Information

Our servers may automatically collect information about you, your online behavior, and your computer or other devices used to access the Website or Services. This may include information, without limitation,

such as your device’s IP address, browser type and version, operating system type and version; identifiers associated with the devices you use to access our Website or Services; geographic location of you and/or your devices used to access the Website or the Services; language preferences; or the webpage you were visiting before you came to our Website; pages of our Website that you visit and the features you use and the time spent on those pages; information you search for on our Website; access times and dates and other statistics; and information regarding you internet service provider.

We use Google Analytics to analyze traffic to this Website in order to help us understand our users’ and visitors’ needs and to continually improve our site for them. The data they collect on our behalf may include search engine referral, affiliate referrals, traffic driven by banner ads or other online promotions, how visitors navigate around the site, and the most popular pages. We also collect certain technical information, such as the browser version and operating system. Google Analytics collects only anonymous, aggregate statistics. We reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any lawful business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.

Social Media

You may use third party social networking services or other online services that are integrated with or linked to our Services to access our Website and Services. When you do so, information you have made available to those services, including information about your contacts on those services, may be made available to us. By associating a social network account with our Website or Services, you agree that we may access and retain that information in accordance with the policies of the social network or other online service and this Policy. For example, we may be able to access account or profile information that you have provided to the social network service or information about your interactions with the social network service to make information available to us (such as when commenting on a blog post or using a sign-on service, such as Facebook Connect). Some social networking services may also facilitate your registration for our Services or enhance or personalize your experience on our Website. Your decision to use such services is voluntary, and we shall have no liability with respect to your use of such services. You should ensure you are aware of the information your third party social networking services may make available to us by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We reserve the right to use, transfer, assign, sell, share, and provide access to all personally identifiable information and other information about you and your devices that we receive through third party social networking services in the same ways described in this Policy as all of your other information.

Managing Personal Information

You have the ability to access, update, change and delete certain of your personal information if you are a registered user with a TradeVantage account. You may do so by accessing the “My Account” page after signing into your TradeVantage account. The information you can access, update, change and delete may change as the Website or Services change. When you update, change or delete information, however, we may maintain a copy of the unrevised, previously provided information in our records. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your personal information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, personal information shall be deleted. Therefore, the right to access, update, change and delete your information cannot be enforced after the expiration of the retention period.

Use of Collected Information

We and others acting on our behalf may use the information that we collect or receive to operate our business, including our Website and provision of Services, as described below:

Operate and Support our Website and Our Services. We use the information we gather in order to operate our Website and provide our Services. For example, we may use the information that we collect or receive to respond to queries and emails of our users; process transactions; provide support and assistance that you request or to diagnose or address technical problems in the operation of our Website or any of our Services. If you establish a TradeVantage account, we may use information about you to manage or support your account. We may identify your use of our Website or Services across devices, and we may use information we collect from you and receive from others to optimize your use of the Website and our Services as you use different devices.

Improving and Evolving our Services. We constantly evaluate and improve our Website and our Services, including developing new products or services and use the information we gather to do so. We also use the information to personalize your experience.

To Allow You to Connect with Partners. When you use our Services, we may use the information you provide us to allow you to connect with a limited number of partners, including [partner automobile dealers]. When you choose to share your contact information with such dealers, your direct interactions with those dealers will not be controlled by this Policy. You should review the applicable policies of those dealers to understand how they may use your information.

This Policy only addresses our own information practices. This Policy does not apply to information you share with third parties, including but not limited to dealers, even if we link to those third parties from the Website. These third parties may have their own privacy policies governing their use of information that you can access from their websites.

Advertisement

We may display online advertisements and we may share aggregated and non-identifying information about our users that we collect through the registration process or through online surveys and promotions with certain advertisers. In some instances, we may use this aggregated and nonidentifying information to deliver tailored advertisements to the intended audience. [[Unless otherwise set forth in this Policy, we do not share personally identifiable information about individual users with advertisers.] [OR] [We may share certain information with third parties to help us promote our products and services, or to help us customize advertisements, offers, or other communications to you.]

Sharing Information

We may share information about you in the following ways:

We may share information with our affiliates for their everyday business purposes, to provide services or to perform marketing. We may also participate in joint ventures with others and we may share information as part of that joint venture.

We may share information with third party service providers who help us operate our business or provide services on our behalf, including third parties who help us operate our Website or facilitate our Services. In such cases, the information may be used by us and by such third parties, each pursuant to its own

policies. While we may seek to require such third parties to follow appropriate privacy policies and will not authorize them to use this information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.

We may share information with partners, including automobile dealers. For example, we may share information with our partner automobile dealers to allow you to communicate with them, and them to communicate with you. Such information may be shared with third parties who support our Website, partners and others.

We may share information we have collected from you in connection with the sale or merger of our business or the transfer of assets.

We may use and share the information we gather to enforce our rights and protect our property and those of our affiliates, users and members of the public, to comply with applicable law, legal process, legal advice and for preventing fraud, theft, and injury to you, us or others.

California Privacy Rights

In addition to the other rights set forth in this Policy, California residents who provide Personally Identifiable Information (as defined in the California Online Privacy Protection Act 2003 (CalOPPA)) and Personal Information (as defined in the California Consumer Privacy Act of 2018 (CCPA)) (collectively, the “Information”) to obtain our Services for personal, family, or household use are entitled to: (i) request and obtain from us deletion of Information, unless such Information is necessary to compute a transaction for which the Information was collected, to provide our Services, to detect or protect against security incidents, or as otherwise required or allowed by law; and (ii) request and obtain from us, up to twice in any twelve (12)-month period, information about the Information we shared in the immediately prior twelve (12)-month period, if any, including, if applicable, specific categories and pieces of such information collected, sources from which such information was collected, the identity of those businesses with which we shared such information and the business purpose for collecting or selling such information.

To make these requests please contact us at support@TradeVantage.com or (305) 728-3275, and we will respond within forty-five (45) days of such verifiable request. We will need to collect information from you to verify your identity in connection with such request.

Do Not Track Signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, this Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser.

Billing and Payments

We use third party payment processors to assist us in processing your payment information securely. Such third party processors’ use of your personal information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

Privacy of Children

We do not knowingly collect any personal information from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any personal information through our Website or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through our Website or Services without their permission. If you have reason to believe that a child under the age of thirteen (13) has provided personal information to us through our Website or Services, please contact us. You must also be old enough to consent to the processing of your personal information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

Consent to Transfer

The Website is maintained in the United States of America. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Website, participating in any of our Services, and/or providing us with your information, you consent to this transfer.

Cookies

The Website uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services.

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

Links to Other Websites

Our Website may contain links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices or the content of such other websites or third parties, we expressly disclaim any statements or assertions made on such websites, including without limitation, any failure on the part of any linked websites to comply with any privacy policy posted on the website, and we deny all liability associated with your use of, and the content on, other such sites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect personal information.

Information Security

We secure personal information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your personal information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Data Breach

In the event we become aware that the security of the Website has been compromised or users’ personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals by email if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law.

Changes and Amendments

We may update this Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat personal information. When changes are made, we will revise the updated date at the bottom of this page and post a notification on our homepage. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website or Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes.

As part of our annual Policy update, the list and description of information collected by us set forth in this Policy will be updated to include any information collected in the twelve (12) months prior to such update.

Contacting Us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to your individual rights and your personal information, you may do so by reaching out to support@TradeVantage.com.