Concierge Auto Negotiator Privacy Statement

Revised Date: August 1, 2024

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Introduction

Thank you for your interest in Concierge Auto Negotiator (“Concierge Auto Negotiator”). We respect the privacy of our users when they use our websites, mobile applications, and other online services (collectively, the “Concierge Auto Negotiator Sites”). By using the Concierge Auto Negotiator Sites, you consent to the use of your information in accordance with this Privacy Statement.

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When we refer to Concierge Auto Negotiator within this Privacy Statement, we are referring to Concierge Auto Negotiator, Inc., and its affiliates. This Privacy Statement applies to information collected through the Concierge Auto Negotiator Sites and does not describe the collection, use, and disclosure practices of any of our corporate affiliates or third parties. For information on the collection, use, and disclosure practices of any company with whom you are doing business, whether or not affiliated with Concierge Auto Negotiator, please review their privacy policies.

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Services offered by Concierge Auto Negotiator are not directed to individuals under the age of eighteen (18). If you are under eighteen (18), you should not provide any personal information to us.

This Privacy Statement covers:

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• Information We Collect

• Information You Provide

• Automated Information

• Data Technologies

• Videos

• Location Information

• Publicly Posted Information

• Combined Information and Information from Other Sources

• How We May Use the Information We Collect

• Applications, Widgets, and Social Media

• Advertising Networks

• Information We Share

• Affiliates

• Our Service Providers

• Co-Sponsored Promotions

• Promotions on Behalf of Third Parties

• Sellers, Dealers, and Manufacturers

• Credit Applications

• Corporate and Asset Transactions

• Other

• Your Choices

• Access and Correction

• Links

• Data Security

• Your California Privacy Rights

• Other State Privacy Rights

• Updates to this Privacy Statement

• How to Contact Us

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Information We Collect:

Information is gathered from the Concierge Auto Negotiator Sites by us, our service providers, advertisers, sponsors, and partners.

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Information You Provide. We may collect information that you choose to provide on the Concierge Auto Negotiator Sites in a variety of ways, such as when you:

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• Register for one of our products or services. This information may include your name, address, telephone number, email address, Social Security Number, and credit information;

• Make information available to us via social networking logins, such as Facebook or Twitter;

• Express an interest in buying, selling, or trading in a car (such as by using our “email the seller” function);

• Participate in chats, web forums, or other interactive sessions;

• Apply for credit with a dealer or one of our finance partners;

• Provide payment card information for one of our products or services;

• Subscribe to newsletters or provide feedback; and

• Participate in surveys, sweepstakes, or other promotions.

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Automated Information. Information regarding your use of the Concierge Auto Negotiator Sites may be collected and/or aggregated through the use of automated means. This automatically collected information may include:

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• Your IP address, the type of browser and operating system used;

• Date and time you access the Concierge Auto Negotiator Site and pages you visit, and if you linked from or to another website, the address of that website;

• Emails you open and links you click on within those emails; and

• Your ISP or mobile carrier, and the type of handheld or mobile device that you used.

• Your behavior while using our site, including the time you spend on portions of the site and how you interact with various aspects of the site.

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Data Technologies. Various technologies are used to automatically collect information, such as cookies, local shared objects, and web beacons (generally referred to as “Data Technologies”). “Cookies” are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. “Local shared objects,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and their cookies. Anonymous advertising identifiers are increasingly being used on mobile devices and otherwise in a manner similar to cookies. When we refer to Data Technologies, we are including all current and similar future technologies.

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One or more Data Technologies may be used on the Concierge Auto Negotiator Sites and other websites and mobile applications (that may not be the Concierge Auto Negotiator Sites) by us, by another party on our behalf, or by third parties in accordance with their privacy policies. Data Technologies may be used by us and others, on our behalf and on their own behalf, to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications. We may use a uniquely generated trackable toll-free telephone number on dealer sites or in advertisements. If you call one of these uniquely generated toll-free numbers, we (or a service provider acting on our behalf) may collect non-personally identifiable information about the call (e.g., date, time, duration), as well as personally identifiable information (e.g., your name, the number from which your call originated).

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Videos. We may target and track the videos you view on the Sites. You consent to our tracking of your video viewing through the Site or third-party social media for up to two years or as permitted by applicable law. You also consent to the sharing of your information in relation to viewing certain video content with third parties, including social media companies.

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Location Information. When you download or use the Concierge Auto Negotiator Sites, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“Location Information”). We also may collect Location Information when you visit or are in the vicinity of one of our dealers. We only collect Location Information with your permission (e.g., such as when you agree to provide it to us after you initially access or download the Concierge Auto Negotiator Sites). We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as advertising, search results, dealers in the area, and direction, to evaluate and improve the Concierge Auto Negotiator Sites, or to provide you with content and services relevant to one or more nearby dealers.

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Publicly Posted Information. Information that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms, or similar functionality is public information that we or others may share or use in accordance with the law.

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Combined Information and Information from Other Sources. We may combine information that you provide to us with information we receive from our affiliates and other sources, as well as with other information that is automatically collected. The combined information may include information about your use of the Sites, your use of other websites, devices, and mobile applications, and information from our affiliates and other sources.

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How We May Use the Information We Collect

We may use the information we collect for the following purposes:

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• For everyday business purposes, such as establishing and managing your user account, providing products and services you request, processing and collecting payments, and providing customer support;

• To create listings and advertisements for any cars and other vehicles that you list for sale with us. These lists and advertisements may appear on the Concierge Auto Negotiator Sites and other websites, mobile applications, or services of third parties;

• To provide values and/or offers for cars that you would like to sell or trade in;

• To offer our other products or services and/or the products or services of others to you;

• To communicate about, and administer your participation in, special events, programs, surveys, contests, sweepstakes, and other offers or promotions;

• To enable you to interact with Concierge Auto Negotiator and our users, dealers, manufacturers, and others through various means, such as through our message boards, blogs, and social media;

• To evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications, and websites;

• To provide or sell to third parties to allow them to market or advertise their products or services to you;

• To diagnose and address technical and service problems;

• To perform data analyses, including market and consumer research, trend analysis, demographic analysis, and financial analysis;

• To deliver content (including advertising) correlating to your interests and browsing and usage history, both within the Concierge Auto Negotiator Sites and on other websites and applications;

• To comply with applicable legal requirements and our policies; and

• To contact you via telephone, text, or chat. We will obtain your consent to contact you when and in the manner required by law.

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Applications, Widgets, and Social Media

We may include applications or widgets from social media providers that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Concierge Auto Negotiator Sites and social media networks such as Facebook, Twitter, and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use, and disclosure of all personal information transmitted to that network.

Advertising Networks

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Advertising Networks

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We partner with advertising networks to deliver targeted advertisements based on predictions generated from your visits across various websites, devices, and mobile applications. This type of advertising, sometimes called "online behavioral" or "interest-based" advertising, utilizes information collected through Data Technologies for customization, auditing, research, and reporting. These networks may track your activity both on our sites and on third-party platforms, enhancing marketing efforts and measuring effectiveness. While we don’t share personal identifiers (like names or addresses) with these networks, they may infer your interests based on your interactions with ads.

You can manage your cookie and tracking preferences using the “Manage Cookies” link below. Declining cookies might affect the functionality of certain features. Opting out of interest-based advertising will not stop you from receiving ads, but they won't be tailored to your interests.

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Information We Share

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We do not sell or otherwise share your information except as outlined below:

• Affiliates: We may share your information with our corporate affiliates in accordance with their privacy policies.

• Service Providers: We use third parties to provide services on our behalf. They are required to keep your information confidential and use it solely for the specified services.

• Co-Sponsored Promotions: If you participate in promotions co-sponsored by us and another party, we may share your information with that party. Their use of your information will be governed by their privacy policies.

• Promotions for Third Parties: Third parties may conduct their own surveys, contests, and promotions on our sites. Information provided in response will be governed by their privacy policies.

• Buyers, Sellers, Dealers, and Manufacturers: We may share information with these parties based on your interactions, such as inquiries about vehicles or participation in trade-in programs.

• Credit Applications: Information provided in credit applications will be shared with dealerships and financial partners to process your application, but not for interest-based advertising.

• Corporate Transactions: In the event of a business sale, merger, or asset transfer, your information may be transferred as part of the transaction.

• Other: We may disclose information to protect our interests, the safety and security of users, prevent fraud, or comply with legal requirements.

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Your Choices

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• Providing Personal Information: You can choose not to provide personal information, though this may affect your ability to use certain features or services.

• Marketing Emails: Unsubscribe from marketing emails using the provided link.

• Interest-Based Ads: Opt out of interest-based advertising as described in the “Advertising Networks” section.

• Cookies and Tracking Technologies: Modify your browser’s cookie settings or disable tracking technologies using the “Manage Cookies” link. Some features may not function properly without cookies. Mobile device settings can also adjust advertising identifiers.

• Location Information: Opt out of sharing location data by declining initial invitations or changing settings on your device.

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Access and Correction

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You can access and update your information if you have a password-protected account. If you believe your information is inaccurate, contact us to request corrections.

Links

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Our sites may contain links to third-party websites or applications. Review their privacy policies as we are not responsible for their content or practices.

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Data Security

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We use reasonable security measures to protect your information, but cannot guarantee perfect security against unauthorized use, loss, or modification.

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Your California Privacy Rights

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This notice applies to California residents and complies with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). We collect various categories of personal information as outlined below:

• Identifiers: Real name, address, email, etc.

• Personal Information: Name, address, Social Security number, etc.

• Protected Characteristics: Age, race, gender, etc.

• Commercial Information: Purchase history, consuming tendencies.

• Internet Activity: Browsing and search history.

• Geolocation Data: Physical location or movements.

• Inferences: Preferences, behavior, etc.

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We obtain this information directly from website activity, customer submissions, and third parties like Facebook and Kelley Blue Book. We retain personal information only as long as needed to provide our services.

For further details or to make requests regarding your personal information, please contact us as indicated in the “How to Contact Us” section below.

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Links

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Our sites may contain links to third-party websites and applications. Once you leave our sites, we recommend reviewing the privacy policies of those third-party sites or applications, as we are not responsible for their content or privacy practices.

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Data Security

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We implement commercially reasonable administrative, technical, and physical security measures to protect your information from loss, theft, unauthorized use, disclosure, or modification. However, we cannot guarantee absolute security of networks, servers, and databases, whether operated by us or on our behalf.

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Your California Privacy Rights

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This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the Autotrader Privacy Statement and applies to consumers residing in California. It complies with the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other California privacy laws. Terms defined in the CCPA and CPRA have the same meaning in this notice.

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Information We Collect

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We collect information that identifies, relates to, describes, references, or can be linked to an individual consumer, household, or device ("personal information"). Over the past twelve (12) months, we have collected the following categories of personal information from consumers.

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Data Retention

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We retain personal information only as long as needed to provide our services to consumers and dealers. Given that vehicle purchases are infrequent, we retain certain categories of information, such as identifiers and vehicle information, longer to ensure effective service delivery.

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In determining retention periods, we consider factors including the ongoing necessity of the personal information for our services, its sensitivity, potential risks of unauthorized use, and the reasons for collecting the information. We regularly review and refine our retention practices to ensure they effectively protect consumers while supporting our services.

Sharing Personal Information

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We may share your personal information with third parties for business purposes. We require these third parties to maintain confidentiality and use the information solely for the intended purpose.

In the past twelve (12) months, we have disclosed the following categories of personal information for business purposes:

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• Category A: Identifiers

• Category B: California Customer Records personal information categories

• Category C: Protected classification characteristics under California or federal law

• Category K: Inferences drawn from other personal information

• Category L: Sensitive personal information

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We share personal information with:

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• Affiliates

• Service Providers: For example, marketing campaign services.

• Authorized Third Parties: For example, tools allowing contact with automotive dealerships.

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We have sold the following categories of personal information in the past twelve (12) months:

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• Category A: Identifiers

• Category B: California Customer Records personal information categories

• Category C: Protected classification characteristics under California or federal law

• Category K: Inferences drawn from other personal information

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Your Rights and Choices

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The California Privacy Laws grant specific rights regarding personal information. This section outlines your rights and how to exercise them.

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Access to Specific Information and Data Portability Rights

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You have the right to request information about our collection and use of your personal information over the past 12 months. Upon receiving and confirming your request, we will disclose:

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• Categories of personal information collected

• Sources of personal information

• Business or commercial purpose for collection or sale

• Categories of third parties with whom information was shared

• Specific pieces of personal information collected

• Information on sales and disclosures for business purposes

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California Civil Code Section 1798.83 allows you to request details on whether your information has been shared with third parties for direct marketing purposes. For more information or to address any concerns, contact us as detailed in the “How to Contact Us” section.

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Right to Limit Use and Disclosure of Sensitive Personal Information

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You may direct us to limit the use of your sensitive personal information to what is necessary for expected services. We may decline such requests in certain cases, including:

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• To provide goods or services reasonably expected by consumers

• To prevent, detect, or investigate security incidents

• To combat illegal actions and ensure safety

• For short-term use, including non-personalized advertising

• To perform services on behalf of the business

• To verify or improve the quality of products or services

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Correction Request Rights

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You may request corrections to inaccurate personal information. Upon confirmation of your request, we will make commercially reasonable efforts to correct the inaccuracies.

Deletion Request Rights

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You have the right to request deletion of your personal information, subject to exceptions under California Privacy Laws. Upon confirmation of your request, we will delete your information from our records and direct service providers to do the same.

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Right to Opt-Out of Sales or Sharing of Personal Information

You can opt-out of the sale or sharing of your personal information. To exercise this right, submit a request by clicking “Do Not Sell My Personal Information (CA Residents Only).”

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Exercising Your Rights

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To exercise your access, data portability, limiting use of sensitive personal information, correction, or deletion rights, please submit a “verifiable consumer request” by:

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Contact Us : 

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