Town Motors Privacy Statement

At Town Motors, we care about consumer privacy, and we believe in providing transparency to consumers about our information practices. This Privacy Statement explains how Town Motors collects, uses, discloses, and protects your information.

This Privacy Statement applies to the information Town Motors collects about you through websites, applications, social media assets, software, and other services provided by or on behalf of Town Motors. When you access, visit or use the Services, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Statement.

If a Service is co-branded or developed by a third party or linked to a third party, the third party’s privacy statement may apply.

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Information You Provide. We and our vendors collect the information you voluntarily provide to us in connection with using our Services, including through product inquiries, requests for vehicle information, technical services or questions, product registration and support, events and promotions, job applications, other inquiries and transactions. Our vendors also may collect information from you, including, for example, when you participate in our contests, sweepstakes, surveys, and other promotions. Some portions of the Services may allow you to submit comments, reviews, ratings and other content.

Information We Obtain from Affiliates, Business Customers and Others. We may obtain information about you from outside sources. For example, our affiliates, Dealers and Dealer associations that deploy Town Motors products and services, may share with us certain information you have previously provided to them. We also may obtain commercially-available demographic information from third parties. If you engage with us, our affiliates or our business customers via social media, the social media platforms also may share certain information with Town Motors. You may be able to adjust your social media privacy settings to limit the sharing of your social media data.

Information We Obtain by Automated Means. We may collect information about your use of our Services or devices you use to connect to the Services by automated means, including tracking technologies. These tracking technologies may include “cookies,” which are small lines of text/data that are written onto your computer by a website. Town Motors and vendors acting on our behalf may use cookies, pixel tags, web beacons or other similar technologies to operate the Services. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

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Our Services may include third-party advertising, promotions, co-branded features, links to other websites, and other programs offered by or in collaboration with third-party businesses. In addition to collecting information directly from you, these third-party businesses may use web beacons and cookies to measure the effectiveness of their ads, personalize or optimize advertising content, and track users who click on the links made available through the Services. When you use our Services, these third-party businesses may collect information about your online activities over time and across third-party websites or online services. We are not responsible for the privacy practices of these third parties, and we encourage you to read their privacy policies, which may apply to these third-party programs. Some third-party advertising companies may provide a mechanism to opt-out of their tracking or advertising. For example, they may be members of the Network Advertising Initiative (which manages the privacy choices of its members) or other organizations that offer consumers privacy choices.

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Information About You. The information that you provide directly to us and that we obtain from others is what we need to serve you, our affiliates and business customers. This information may include your contact details (such as name, postal or email address, phone number, Twitter handle or other online aliases); details about your vehicle and Dealer transactions; contact information of individuals with whom you would like to share Town Motors content; social media identifiers; demographic information; and other information you may choose to share with us by interacting with our Services or with our affiliates, business customers or other businesses that share information with us.

Information About Your Device. The information we collect by automated means also helps us, our affiliates and our business customers to provide and tailor various products and services. We may collect the following details by automated means:

Usage Information. We and our vendors may automatically collect your usage activity, preferences, and browser details (such as your IP address and browser type), as well the ID and type of the device you use to connect to our Services, and other details about your use of our Services. This may also include the collection of information about your online activities over time and across third-party websites or online services.

Online Tracking. Because there is not yet a consensus on how companies should respond to web browser-based or other do-not-track (“DNT”) mechanisms, Town Motors does not itself respond to web browser-based DNT signals.

Location Data. Some of our Services may collect geo-location data to provide location-related functionality, such as the location of your nearest Dealer. We may link location data to other information we have collected about you.

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We use your information to serve you, our affiliates and business customers. The following are general purposes for which we may use your information.

Provide Products and Services. We may, for example, use your information to complete a transaction you have asked us to do, including e-commerce transactions or “get a quote” or “find a dealer” requests, or to send you communications regarding products, service reminders or vehicle information.

Operate our Business and Develop and Improve Our Products and Services. Examples include using information collected through cookies and similar technology to better understand how our Services are used, develop new offerings, or personalize your experience in using the Services.

Customer Service. If you request support or other information, we may use your information to respond to your request. We may follow up with you to notify you periodically about important topics, like Services updates or changes to our Privacy Statement.

Marketing. We may use your email address to let you know about current offers, invite you to participate in those offers and manage your participation in them. We also may use information about your use of our Services to tailor our offers to your preferences or to offer you products and services that we believe may be of interest to you. Among other privacy choices described in this Privacy Statement, you may direct us to not send you email marketing communications by clicking on the unsubscribe link included in the emails you receive from us.

Recruitment and Job Applications. We may use the information submitted on resumes and similar documents through Town Motors for the purpose of employment consideration. We may keep your information on file for future consideration.

Compliance with Legal Requirements, Rules and Internal Policies. We may be required by law or internal data retention policies to maintain information about you for a certain period of time, or to notify you of a security breach. We also may be required by social media platform rules (such as Facebook) to handle the social media information you or the platform share with us in a certain manner.

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This section describes the types of organizations with whom we may share your information.

Within Town Motors. Town Motors may authorize access to your information within our enterprise, by our employees and other personnel, to fulfill our obligations to you and to operate our business.

Affiliates and Vendors. Our affiliates and vendors may access and use your information for the purposes we describe in this Privacy Statement, including as necessary to provide functionality, products, and services to us and you in connection with the Services. For example, when you register for a sweepstakes, a vendor may process the sweepstakes entry. Town Motors requires vendors to process your information under the direction of Town Motors and in accordance with this Privacy Statement, contractual restrictions, and applicable law. We also may share data collected through cookies and similar technology with our vendors to advertise or market to you on other sites as you browse the web. We may allow our affiliates and vendors to have access to aggregate statistics – that are not linked by us to any specific consumer – about consumer behavior, sales, traffic patterns, and related Services information.

Marketing Partners. We may share your information with our marketing partners when, for example, we participate in a co-branded promotion with another company. We will not share your personal information with third parties for their own marketing purposes.

Your Public Comments. Some portions of our Services may allow you to submit comments, reviews, ratings and other content. This content may be displayed on the Services and may be viewable by other users of the Services or the public generally.

Mergers, Acquisitions or Insolvency. If Town Motors should ever file for bankruptcy or merge with another company, or if Town Motors should decide to buy, sell, or reorganize some part or all of its business, Town Motors reserves the right to disclose your information, including to prospective or actual purchasers in connection with one of these transactions.

As Required by Law and Other Extraordinary Disclosures. Town Motors may be required to disclose your information if it:

• believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority;
• would potentially lessen our liability in an actual or potential lawsuit or investigation; or
• is necessary to protect our or others’ rights or property.

Mobile Information. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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We make reasonable efforts to secure our systems. However, data transmissions over the Internet cannot be guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us and you do so at your own risk.

By providing your email address to us or using the Services, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically. You may have a legal right to receive this notice in writing. To receive a free written notice in the event of a security breach (or to withdraw your consent from receiving electronic notice), or if you want to update the contact information you have previously provided to us, you should contact us.

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You may request to access, correct, update or delete the personal information we maintain about you, or otherwise adjust your privacy preferences by contacting us. We may limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances, or as we otherwise deem appropriate. In addition, please note that we may not be able to edit or delete your personal information stored with our third-party service providers, or we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).

Our Services are not directed at children or intended to be used by children. Do not send any information about yourself to us if you are under the age of sixteen (16). In addition, if we learn a person under the age of thirteen (13) has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately.

If you are a California resident, you may request that we provide to you:

• a list of the categories of personal information about you that Town Motors has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request;
• the names and addresses of such third parties; and
• if the nature of the third parties’ business cannot reasonably be determined from their names, examples of the products or services marketed, if known to Town Motors, sufficient to give you a reasonable indication of the nature of the third parties’ business.

This is a U.S. website, and this site and our Services are subject to U.S. laws, including those governing the privacy and security of your information. If you use the Services, you are transferring your information to Town Motors in the United States. By using the Services or providing your information to us through the Services you consent to the transfer of your personal information to the United States, and our handling of your information in accordance with applicable U.S. requirements.

In the future, we may change our Privacy Statement, and we will post the new Privacy Statement on the Services in advance of the date it becomes effective. You agree to the new Privacy Statement by continuing to use the Services.

We retain your information for as long as it is necessary and relevant for the purposes described in this Privacy Statement. The information we retain about you will be handled in accordance with this Privacy Statement.