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PRIVACY POLICY | Business to Business |

General

DEALERWING LLC (“DEALERWING”) recognizes the importance of protecting privacy and nonpublic personal information. This Privacy Policy (“Policy”) will explain how DEALERWING treats customer data, including, information collected and received from authorized Dealerships (“Dealer”), namely, through DMS services, sales, OEM Provided data, Recall provided data, purchased conquest data, website collected data, or otherwise in connection with the services rendered by DEALERWING to a customer (“You”) on behalf of a Dealer .

DEALERWING takes Your privacy seriously and is committed to safeguarding Your privacy online, we have developed a privacy statement to help you understand the terms and conditions surrounding the collection and use of the information provided by Your Dealer. This statement discloses the types of information we obtained, how it is used, and how you can gain access to and edit any data that we’ve collected about you at any time through services provided to You on behalf of the Dealer.

These policies may be changed at any time, in which case the revised Policy will apply to information collected after the date the Policy is changed and posted. By using any of DEALERWING’S services or submitting any information to DEALERWING through Your authorized Dealer, You and Dealer consent to the terms and conditions of this Policy and our Terms of Use, which govern your use of the services rendered and are incorporated by reference herein.

Guiding Principles:

DEALERWING respects the privacy of individuals who receive solicitation on behalf of Dealer and or our services offered to You on behalf of a Dealer or otherwise Web sites, send us e-mail, or participate in features/services we offer online. Accordingly, our policy regarding online privacy has been developed using the following guiding principles: DEALERWING maintains a strict “no-spam” policy. Subscribers to our e-mail services (or any other feature/service found on our Web site) will not receive unsolicited e-mail messages from us. If you are receiving this Policy it is because we have identified, to the best of our knowledge, that you have opted into receiving text messages/email messages in accordance to the CAN-SPAM Act (Email) & TCPA – Telephone Consumer Protection Act (Text Messages & Calls) from an authorized Dealer. Your Dealer collects information primarily and provides DEALERWING with such information to provide You with a more relevant experience. When using Your Data as provided by Your authorized Dealer, we will make every reasonable effort to avoid excessive or irrelevant collection of data. Dealer agrees to take reasonable physical, electronic and managerial measures to safeguard and secure any information you provide to us (e.g. data will be stored in protected databases on secured servers with restricted access). DEALERWING will not share any information provided to us with anyone without Your consent, as granted to the Dealer, other than to provide the service You’ve requested. At the time You register with your Dealer, You will be notified of, and asked to consent to, the sharing of your information with any particular third party necessary to the provision of the requested service. If you no longer want to receive further communications You may opt out of receiving future communications at any time (see opt-out Procedures below).

Non-Personally Identifiable Data:

Anytime you visit our Web site, or receive any services or solicitation from DEALERWING on behalf of Dealer, we may gather or receive certain non- personally identifiable information regarding the means You use to access our site or receive our services. This information may include the type and version of Your browser, Your service provider, Your IP address and any search engine you may have used to locate the site. We use this information to help diagnose problems with our server, administer the Web site, and compile broad statistical data. In addition, we gather certain navigational information about where you go on our Web sites. This information enables us to determine which areas of the Web sites are most frequently visited and helps us to tailor the sites to the needs and interests of our online visitors. Such information is gathered by us in the aggregate and will not be associated with a specific individual without that individual’s consent.

Information Voluntarily Provided:

You represent and warrant that You have authorized Dealer to provide us with any such information about You or was otherwise authorized and collected through business conducted with your Dealer, namely, through services, sales, OEM Provided data, Recall provided data, purchased conquest data, website data, E-Mail Reminder Services, request information, etc. Any information provide to us (i.e. name, e-mail address, etc.) when You enroll with your authorized Dealer, or collected through the use any of Your Dealer’s services, websites, or interactive portions of our Web sites, is securely maintained on our Web server and internal systems. This information may be used to provide You with information You’ve requested about the Dealer, their products/services, and DEALERWING services, or to provide you with special notices. We may also collect “Demographic Information” (i.e. information that you submit, or that we collect, that is not Personal Information; this may include, but is not limited to, zip code, hometown, gender, username, age/birth date, browsing history information, searching history information, and registration history information).

Dealer represents and warrants that it has full authority from You or otherwise was authorized to collect through business conducted with You, namely, through services, sales, OEM Provided data, Recall provided data, purchased conquest data, website data, E-Mail Reminder Services, request information, to contact you and provide certain information and communications to DEALERWING to provide certain services and communications on behalf of Dealer.

This Policy does not apply to the practice of entities or people that DEALERWING does not own, control, employ, or manage. You may opt out of receiving future communications at any time (see opt-out Procedures below). This data may also be used to tailor your experience on our sites by providing content that is relevant to your interests and geographic region.

Accessing the Websites and Personal Information Collection

In order to access our Web sites and services You are required to be signed up with DEALERWING or Your Dealer. Our Websites collect limited technical information, such as your IP address, when accessing and using our services. We also use cookies and analytics to collect certain information as described below.

Cookies

Cookies are small blocks of data created by web serving software while a user is browsing a website and placed on a user’s device by the user’s browser ) to collect data that include your Internet protocol (IP) address, the type of browser and operating system you use, the date and time of your visit, the state in which you are located. We use cookies (text files placed on your hard drive by a web server) to help personalize and maximize your experience and time online. Cookies are not used to run programs or deliver viruses to your computer. They are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you. We use cookies to improve the Web sites and to facilitate your use of the Web sites.

Information we collect.

You must register through your Dealer or authorize your Dealer and you may additionally sign up for services directly with DEALERWING as appropriate for your role under the customer services or Dealer. These registrations require you to submit the following information on behalf of the customers and/or or dealership:

  • Contact information such as name, e-mail address, postal address and phone number
  • Demographic information such as ZIP Code and date of birth
  • Dealership information, including purchase history, service history, notice history
  • Payment information to invoice for services purchased
  • SMS messaging and Marketing Emails

  1. Information we provide

    • Contact Information: DEALERWING collects contact information that you provide in your interactions with the Dealer and/or the Dealer’s website, or directly through DEALERWINGS, such as by entering information into a contact form or communicating with the Dealer by phone, email or chat. This includes information such as your name, personal phone number, home address, and email address.
    • Customer Profile: DEALERWING generates a unique ID number and traffic number and creates a user profile. DEALERWING collects information that a user provides through its Dealer and interactions with its Dealer and includes that user-provided information in the user profile. DEALERWING also combines information collected automatically (described below) with user profile information for the same individual.
    • Chat and Phone Communications: DEALERWING collects information that you enter into or through a chat feature or functionality made available on the Dealer website and/or information provided through phone communications with the Dealer. This information may include contact information and the content of any chats that you provide, including any inquiries or requests and your chat history.
    • SMS messaging and Marketing Emails: DEALERWING collects your contact information and the content of your email communications with the Dealer. If you provide the Dealer with consent to receiving text messages, DEALERWING may collect the phone number that you provide and your messaging history including any information included in those messages to provide such communications on the Dealers behalf. Mobile information will not be shared with other third parties for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

  2. Information Collected Automatically

    • Log data: This may include your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, and how you interact with our Services.
    • Device information: This may include your browser type and version, browser settings, time zone, unique device identifiers, available plugins, information about your approximate location (as determined through your IP address), mobile, computer, and/or device hardware information (e.g., operating system version, hardware model, IMEI number, and other unique device identifiers, MAC address, and device settings), device event information, log information, and crash data.
    • Usage information: This may include features that you use, clickstream data, access dates and times, and how you interact with the Dealer. This information may also include the traffic source for the visit, referring / exit pages and URLs, how you interact with links on the Dealer or our website, landing pages, and pages viewed. DEALERWING also may collect the date and time you open an email communication or click on any links in an email sent via the DEALERWING services may associate this information with the email address we already have from you.

  3. Information from Third Party Sources

    DEALERWING may access or receive information from third-party sources that the Dealer connects or uploads to the DEALERWING services. These third-party sources of information may include the Dealer’s internal and/or third-party business operations and marketing systems and other third-party service providers to the Dealer, such advertising or analytics vendors.

  4. Sensitive Personal Information

    DEALERWING does not intentionally collect personal information that is considered sensitive under privacy laws, such as genetic data, health information, race or religious information, about users to provide the Services.

We may use this information to effect transactions or provide services for which the information was provided, to contact you with additional information, and to analyze use of the Websites and services.

Information Related to the Services

Certain types of information will be necessarily generated or shared in the course of DEALERWING’s performance of services.

For example, we may collect information from Dealers, Administrators, or other sources concerning dealership customers to provide the Services, and create analyses of related results. Likewise, dealership specific information will not be shared in any direct form with any Administrator of another dealership. Administrators are provided with access to and reports that aggregate numerical and qualitative data solely for their dealership.

How DEALERWING Uses Personal Information

DEALERWING uses the personal information collected in the following ways:

  • To provide the DEALERWING services to the Dealer and/or customer
  • To assist the Dealer in establishing and managing a business relationship with the customer;
  • To send marketing communications, including emails and SMS messages, on the Dealer’s behalf;
  • To analyze use of the Dealer website and communications;
  • To conduct research and analytics related to the Dealer’s website and marketing activities, such as to understand how they are being used and where improvements may be needed;
  • To personalize and improve user experience and when interacting with the Dealer through personalized communications;
  • To compile aggregate and anonymized data for DEALERWING’s own use; and
  • For DEALERWING’s own legal and compliance obligation

Links

The Web sites may contain links to other websites. DEALERWING is not responsible for the privacy practices of sites other than our own. We encourage you to be aware of the privacy statements on other websites and to read these statements.

Information Collected from Other Sources:

To help us better understand and respond to your needs and interests, we may in the future receive information about You from other sources. We will ask any provider of such information to represent and warrant that the information has been gathered and maintained in accordance with all state and federal laws. Any such information will be maintained by us in accordance with the standards set forth in this privacy policy along with other personal information You’ve provided.

We use certain service providers such as website analytics providers to help us understand and improve the usage of the Web sites and the effectiveness of our marketing efforts. We may use “Google Analytics” to collect information about Your use of our services. Google Analytics collects information such as how often users visit a Web site, what pages they visit when they do so, and what other sites they used prior to coming to the Web site. We would use the information we get from Google Analytics only to enhance user experience. Google Analytics collects only the IP address assigned on the date a site is visited, rather than other Personal Information. We do not combine the information collected through the use of Google Analytics with Personal Information. If you would like more information about advertising networks, including choices about the use of information by Analytics company and other companies for multi-site advertising purposes, go to www.networkadvertising.org and www.networkadvertising.org/choices/.

Browser-Based Do Not Track:

Currently, various Internet browsers offer a “do not track” or “DNT” option that uses a DNT header to indicate the DNT preference setting on the browser. DEALERWING does not track your activity over time and across different websites or online services, and thus we do not currently respond to browsers’ DNT signals with respect to the Web sites. We do not permit our third-party service providers to collect information from the Web sites for other websites or for their own purposes other than as described in this Policy.

Children’s Privacy

We are committed to complying with all applicable laws and regulations regarding the collection, storage, and use of personal information of minors under the age of 18, including the Children’s Online Privacy Protection Act of 1998.

We do not collect personal information from minors under the age of 18. Individuals under the age of 18 are not permitted to use the Web sites without the supervision of a parent or legal guardian. We do not knowingly collect or solicit personal information from children under the age of 18 or knowingly allow such persons to register for an online account or to place orders or provide personal information through the Web sites. If we learn that someone under the age of 18 has provided any personal information through a Dealer, we will remove and permanently delete that information as soon as reasonably possible.

If you are a parent or guardian who believes that your minor, under the age of 18, has submitted personal information or other information to us without your consent, please contact us using the contact information provided below. Once we verify that you are the parent or legal guardian, we will cooperate with you to discuss what, if any, personal information we have collected about your child and how that information may have been shared or used.

Disclosure of Personal Information:

DEALERWING understands the importance of your privacy. We collect and maintain the personal information of our consumers for our use and our subsidiaries. We do not sell, rent, or trade consumer information to third parties, other than as described below, and never without your consent. Third parties may collect personally identifiable information about your online activities over time and across different websites when you use this website.

Business Partners:

DEALERWING may partner with select retailers and other companies at various times to provide expanded services to our Web site visitors. As part of such a relationship, we may share with these companies the use of certain interactive Web site functions (i.e. the E-Mail Reminder Service). Information provided by site visitors through the use of such interactive functions may be available to both our dealership and our partners.

Agents:

DEALERWING may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from agents working on our behalf.

Business Transfers:

In the event that DEALERWING sells or transfers a particular portion of its business assets, consumer information may be one of the business assets transferred as part of the transaction. If substantially all of the assets of our company are acquired, consumer information may be transferred as part of the acquisition.

Compliance with Law/Safety:

DEALERWING may disclose specific personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect the users of our Web sites, the sites themselves, or the public.

With Consent:

Other than as set forth in this Privacy Policy, You will be notified when any personally-identifiable information about You may be shared with third parties, and You will be given the opportunity to decline to share that information.

Protection of Information

DEALERWING is committed to respecting and protecting the privacy of our users and whom which we render our services. In order to protect Your information and privacy the Web sites are password secured and can only be accessed using unique login credentials. In order to receive any communication from DEALERWING on behalf of Your authorized Dealer, You must have consented to providing such information and receiving such communications and will be linked to your unique identifier and will be for your use only and strictly confidential.

Accessing Our Web Sites from Outside of the United States:

If you are visiting our Web site from a location outside of the U.S., your connection will be through and to servers located in the U.S. Any information you provide during your visit will be processed and maintained on our Web server and other internal systems located within the U.S.

SMS Consent and Terms & Conditions:

If you have consented to receive text messages from DEALERWING services you may receive texts with offers or information about our products and services. Message rates may apply and messaging frequency may vary. You may opt-out at any time by texting, STOP.

Opt-out Procedures:

You may always opt-out of receiving future communications from DEALERWING. Our sites, emails, SMS, messages or marketing received allow users to opt-out of receiving such communications at the point where personal information is requested, or through other means as identified.

  1. Your Choices – Opting Out

    1. Opting Out of Data Collection by DEALERWING

      You may choose to opt out of data collection by DEALERWING. To opt out, email [email protected]

    2. Opting Out of Marketing Emails and SMS Messages Sent Via DEALERWING

      • Email Opt-Out: To stop receiving promotional email communications sent via DEALERWING on the Dealer’s behalf, click on the “unsubscribe” link in the communication or send an email to [email protected]
      • Please note that the opt out applies only to email communications sent via DEALERWING services and only for the particular Dealer whose communications you’ve opted out of.You may continue to receive other marketing emails sent by the Dealer or other of the Dealer’s third-party service providers or agents, and you may continue to receive marketing emails from other Dealers that DEALERWING is contracted with if that specific Dealer was not opted out. To opt out of other marketing communications sent by the Dealer, please see the Dealer’s privacy policy for the relevant opt-out information. To opt out of email communications sent by DEALERWING on behalf of other Dealers, you will need to submit a separate opt-out request with DEALERWING for each Dealer.If you opt-out of marketing emails sent via DEALERWING, the Dealer will still send you transactional emails, such as responses to your requests.
      • SMS Opt-Out: To stop receiving SMS marketing communications sent via DEALERWING on the Dealer’s behalf, you can opt out at any time by responding with an opt-out notice in the SMS communication.

Please be aware that the Dealer may engage in targeted advertising through its third-party advertising partners. DEALERWING does not serve targeted ads, and DEALERWING does not directly engage in targeted advertising on the Dealer’s behalf. For information about the Dealer’s targeted advertising activities and your options, please see the Dealer’s privacy policy.

Changes to This Statement

DEALERWING reserves the right to change this privacy statement at any time. Notification of changes will be posted on the Websites. Because these changes may affect your personal information, we suggest that you look for information regarding changes on a regular basis and review the changes as soon as they are published on the website.

Disclosures for Compliance with Law

Notwithstanding the provisions of this Policy or the Terms of Use, information may be and will be disclosed as needed in order to comply with law, respond to facially valid process or subpoena, to stop or mitigate illegal activity or potential harm, to protect the security of information, and to protect against fraud.

Correcting Your Information

We strive to assure the correctness of the information we maintain. If the information we have about you and/or your customer is inaccurate, we will correct the information in a manner as timely as possible. To provide us with corrections, please contact us in any of the following ways:

  • Send an e-mail message with corrections to [email protected].
  • Send mail to DEALERWING LLC,1552 Eagle Nest, Winter Springs, FL 32708
  • Call us at (213)632-8211.

Security

We employ reasonable security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of Your information. However, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.

Indemnification and hold harmless by Dealer/Customer

The Dealer represents and warrants that it has provided DEALERWING with accurate consent information on behalf of its customers and You. Dealer represents and warrants that You have provided consent to receive certain marketing information and communications on its behalf and has assigned such consent to DEALERWING to provide certain marketing information, communication, and services to You on behalf of Dealer. Accordingly, the Dealer aggress to indemnify DEALERWING and its affiliates, subsidiaries, heirs, assigners, and their respective officers, employees, shareholders, representatives and agents (the “Indemnified Parties”), and to defend and hold each Indemnified Party harmless from and against any and all claims, damages, losses, liabilities and expenses (including all fees and charges of internal or external counsel with whom any Indemnified Party may consult and all expenses of litigation and preparation therefor) which any Indemnified Party may incur or which may be asserted against any Indemnified Party by any person, entity or governmental authority (including any person or entity claiming derivatively on behalf of the customer), in connection with or arising out of or relating to the matters referred to in this Privacy Policy or other marketing, communication, or information solicited, whether (a) arising from or incurred in connection with any breach of a representation, warranty or covenant by the Dealer, or (b) arising out of or resulting from any suit, action, claim, proceeding or governmental investigation, pending or threatened, whether based on statute, regulation or order, or tort, or contract or otherwise, before any court or governmental authority in connection with Dealers services; provided, however, that the foregoing indemnity agreement shall not apply to any claims, damages, losses, liabilities and expenses solely attributable to an Indemnified Party’s gross negligence or willful misconduct. The indemnity agreement contained in this Section shall survive the termination of the parties relationship.

Effective Date: January 1, 2026.

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