DealerRater Privacy Notice

Last updated March 27, 2023

DealerRater.com, LLC ("DealerRater" "we" "us" or "our") respects your privacy and the information that you have entrusted to us. This Privacy Notice (the "Privacy Notice") describes our information handling practices in connection with the website located at www.dealerrater.ca ("Site"), and any other services offered by DealerRater through the Site or through other devices, such as smartphones and tablets, which directly relate to the Site. ("Services").

This Privacy Notice does not describe DealerRater's collection, use, and disclosure of information through means other than the Site (e.g., off-line), the use of the Services, or the collection, use and disclosure practices of any affiliate or other third parties. For more information on a third party's information collection, use, and disclosure practices, please review the privacy notice on the applicable third party's websites. Also, please note that the Site and/or Services may contain links to other websites. DealerRater is not responsible for the websites, content, or privacy practices of any third party. Please see the privacy policies of these third-party websites to understand their practices for handling your information.

By using the Site and the Service, you acknowledge that you have read and agree to this Privacy Notice and expressly consent to DealerRater's data processing as described below. You additionally agree that you are subject to the Privacy Notice for California Residents as well as the DealerRater Terms of Use.

We take your privacy seriously, and work to ensure the security and confidentiality of the personal information you provide to us. Please read this Policy to learn more about how we protect your privacy before using this Site or submitting your personal information. By using this Site or submitting personal information, you consent to the collection, use, and disclosure of your personal information (as defined below) in accordance with the practices described herein. If you do not agree with these terms, do not use this Site or provide any personal information to us.

This Privacy Notice is divided into sections as described:

1. Information We Collect About You and How We Collect It
2. How We Use Your Information
3. Disclosure of Your Information
4. How We Protect Your Information
5. Dealership Accounts
6. Use of Cookies, Web Beacons, and Similar Technologies Elsewhere on the Site
7. Personal Information Retention
8. Children
9. External Links
10. Your State Privacy Rights
11. Notice to California Residents
12. Notice to Canadian Residents
13. Notice to European Residents
14. Changes to this Privacy Notice
15. Contact Information

1. Information We Collect About You and How We Collect It

Information we collect about you:

We may collect both "non-personal" and "personal" information from you when you interact with our Sites and Services.

"Non-Personal Information" refers to information that may not by itself be reasonably associated with, linked to, or used to individually identify you or someone else. For example general, non-specific information regarding your use of the Sites and Services or derived from the information that you provide to us through the Sites and Services.

"Personal Information" refers to information that may be reasonably associated with, linked to, or used to individually identify you or allow you to be personally identified or contacted. For example, Personal Information may include information such as your name, email address, telephone number, address, either alone or in combination with other information.

DealerRater collects personal information relevant to your use and the operation of the Site, including but not limited to:

• your name, mailing address, phone number (including mobile phone number), e-mail address, geographic location as may be associated with a Submission or Dealer Review
• Usage details, including Google Analytics and Mouseflow, other technical information, type of browser and operating system you are using, your IP address, your device identifiers, your Internet or wireless service provider, pages viewed or otherwise visited on the Site, and location-based information, when you use our Site

How we collect this information:

• Directly from our users when they submit a review form, lead form or other web form on the Site.
• Directly and indirectly from interaction with our Site (or an affiliated site). For example, from submissions through our website portal or website usage details (including without limitation IP address, device ID, geolocation data collected automatically).
• Directly from users or their agents. For example, from documents that users provide to us related to the Services for which users engage us for or from audience segments used for targeted experiences.
• Indirectly from clients or their agents. For example, through information we collect from clients in the course of providing Services to them.
• From data aggregators and similar vendors.
• From third-parties that interact with us in connection with the Services we perform. For example, we may ingest audience data from third-party data providers to power targeted messaging or customized services. We may also receive aggregated vehicle sales records for analytics and other purposes.
• From anti-fraud and other crime prevention partners.
• From the following:
  • Cookies: Cookies are small text files that are placed on your computer's hard drive by computers (or servers) to identify your computer. Cookies allow DealerRater to recognize you when you visit the Site, to personalize your experience and generally to serve you better. Cookies and web beacons can tell us what you have seen on the Site. Cookies, web beacons, and IP addresses are also used to compile data regarding usage. Web beacons may also be included in emails sent by DealerRater to determine when and if such emails are opened or forwarded. You can disable cookies or otherwise manage them through tools provided with your browser software and with third-party software packages. If you turn off cookies, some of the Site's Services and/or features will not work as well or at all.
  • Web Beacons: Web beacons (also known as pixel tags, internet tags, clear GIFs, or single-pixel GIFs) are electronic images embedded into a webpage.
  • IP Address Logs: DealerRater also logs Internet Protocol (IP) addresses – the location of your computer on the internet – and may log device ID and information about your browser or operating system.

Please note we do not have access to information that would confirm all uses of cookies, web beacons, or other tracking technology used by our third-party service providers with respect to the Site.

2. How We Use Your Personal Information

We may use the Non-Personal Information we collect and obtain for any lawful business purpose without any duty or obligation of accounting or otherwise to you, provided that the information remains Non-Personal Information. This will include, by way of example, developing products, services, and other offerings based on the Non-Personal Information and providing those offerings to other users and third parties.

We may use the Personal Information we collect about you for a variety of purposes:

• To respond to an e-mail or message or particular request from you.
• To solicit feedback.
• To verify or enforce compliance with the policies governing our Site and applicable laws.
• To protect against misuse or unauthorized use of the Site.
• Contacting you for direct marketing purposes.
• For product improvement and development purposes, including research and analysis.
• To personalize your experience browsing our websites and using the Services. We use cookies for this purpose.
• Cookies may also be used to display relevant ads for our products as you visit other websites.
• To send emails relating to news about our company and various promotions.
• To provide maintenance, support, and customer service.
• To provide advertising, offers for products, services, or other offerings that we feel may be of interest to you.
• As otherwise described in this Privacy Notice and/or our California Privacy Notice.

We may combine and enhance the Personal Information we collect and obtain about you with information we receive from third parties, provided that we use the combined information in accordance with this Privacy Notice.

We may also use the Personal Information we collect and obtain about you to generate Non-Personal Information. When we do so, we will take reasonable measures to ensure that the Non-Personal Information is no longer personally identifiable and may not later be reasonably associated with, linked to, or used to identify you. This will include, by way of example, storing the Non-Personal Information separately from any Personal Information. Once we generate Non-Personal Information from any Personal Information, we will not later attempt to again make that information personally identifiable. However, we may combine and enhance that Non-Personal Information with other Non-Personal Information we receive or obtain from third parties.

You should not provide any information to us, whether via the Services or through the Sites, unless you agree to the use of that information in accordance with this Privacy Notice.

3. Disclosure of Your Personal Information

We may disclose the Non-Personal Information we collect and obtain for any lawful business purpose without any duty or obligation of accounting or otherwise to you, provided that the information remains Non-Personal Information. This will include, by way of example, sharing that Non-Personal Information with third parties.

We may share, disclose, or provide your Personal Information to third parties: (i) when required to combat fraud or to protect our interests; (ii) to enforce the Privacy Notice, California Privacy Notice, or the applicable Terms of Use, Terms of Service, or API license grant; (iii) when required to do so by law or in response to legal process or lawful requests, including from law enforcement or government agencies; (iv) within and among our affiliates and subsidiaries; or (v) as part of a merger, sale of a business, sale of assets, or dissolution.

We have relationships with other companies that we allow to place ads on our Site. As a result of your use of the Site, such ad server companies may collect information such as your domain type, IP address and clickstream information. DealerRater may engage third parties to help us provide the Site and manage our business, although these organizations are subject to confidentiality obligations and may only use your Personal Information for the purposes DealerRater defines. We may analyze your Personal Information and Non-Personal Information in aggregate form which does not identify you personally. We may share this aggregate data with our affiliates, agents, advertisers, manufacturers, and business partners. We may also disclose aggregated user statistics to current and prospective business partners and to other third parties for other lawful purposes. We may use how you browse and shop in order to show you ads for DealerRater or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by DealerRater.

We will share personal information with companies, dealers, organizations or individuals outside of DealerRater when we have your consent to do so. We may use personal information (and permit third parties to whom we may disclose personally identifiable information specifically for direct marketing purposes) to send you promotional or informational messages, but if contact is via phone or SMS only if you have first affirmatively agreed to receive such messages. You agree that DealerRater or other third party may use an autodialer to text or call, and that a portion of any call may be pre-recorded. Standard message and data rates may apply and you consent to such charges.

We belong to ad networks that may use your browsing history across participating websites to show you interest-based advertisements on those websites. Currently, our Site does not recognize if your browser sends a "do not track" signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. You can opt-out of receiving interest-based ads from us by emailing privacy@dealerrater.com and provide your full name and applicable account information, along with your data access request. Please note that if you choose to opt out, you will continue to see ads on our Site, but they will not be based on how you browse and shop.

4. How We Protect Your Personal Information

We are committed to protecting and securing your Personal Information. We will take all reasonably appropriate steps to ensure the safety and security of your Personal Information. This includes using industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Information under our control. For example, our policy is that only those individuals who need your Personal Information to perform a specific job for us are granted access to that Personal Information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. We keep your Personal Information physically secure in our data centers, and we use a variety of security measures to ensure that your information is protected. Please keep in mind that despite these measures, we cannot guarantee or warrant 100 percent security of its servers and databases. Moreover, we cannot guarantee that Personal Information that you submit through the Sites and/or Services will not be intercepted or otherwise disclosed.

We may release Personal Information when doing so is necessary to comply with the law, enforce our policies, or to protect the rights, property, or safety of others. Information that is not personally identifiable may be provided to other parties for marketing, advertising, or other purposes without restriction.

5. Dealership Accounts

Accounts belonging to dealerships may privately contact reviewers through our site on items related to a consumer review. When dealers make such contact, email addresses are not provided to either party without prior consent. DealerRater facilitates the interaction through the DealerRater platform.

6. Use of Cookies, Web Beacons, and Similar Technologies Elsewhere on the Sites

Affiliates and other third-party service providers may collect and use information about your visits to and use of our Site through the use of cookies, web beacons, and other similar technologies. For example, we may work with companies that collect statistical information regarding Site usage and provide related analytical services. We may work with third-party companies that use cookies and web beacons to serve advertisements when you come to the Sites and to generate statistics and metrics related to Site experience. We also may work with third-party advertising platforms and networks that use cookies, web beacons, and similar technologies to collect Non-Personal Information about your visits to and interactions with the Sites and other websites in order to provide customized experiences and targeted messaging. These third parties may also use this information for determining or predicting the characteristics and preferences of their respective audiences, for measuring the effectiveness of their advertising and for other purposes.

Third-party service providers may also collect information from your devices and may combine Personal and Non-Personal Information about you with information from other sources including your visits to this and other websites, mobile websites and/or mobile applications across your various devices. These activities may enable them to identify you in order to provide customized experiences and targeted messaging across those various devices.

If you would like to obtain more information about the practices of some of these parties, or if you would like to make choices about their use of your information, please click here:

https://www.aboutads.info/choices/

More information and additional consumer choice options may be found at this link:

https://www.networkadvertising.org/managing/opt_out.asp

Information and additional consumer choice options regarding mobile device tracking may be found at these links:

IDFA limit ad tracking:

https://support.apple.com/en-us/HT202074

AAID reset and opt-out:

https://www.androiddocs.com/google/play-services/id.html

7. Personal Information Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your non-anonymized Personal Information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, as necessary to resolve disputes, or as otherwise requested by you.

To determine the appropriate retention period for Personal Information, we consider our legal obligations, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means. This duration varies based on data type and use, but we have recorded the durations in our internal records and information management policy and schedule.

8. Children

DealerRater is very concerned about protecting the privacy of children. DealerRater does not intend to collect any personally identifiable information from children under 13 years old or knowingly distribute such information. Children under 13 are not permitted to use the Site, and we request that children under 13 not submit any Personal Information to DealerRater. If a child under 13 has provided DealerRater with Personal Information, the parent or guardian of that child should contact DealerRater immediately Contact Us to delete this information from our files.

9. External Links

Where any links found on the Site link to pages not belonging to DealerRater, those external pages are not governed by this Privacy Notice. Please see the privacy policies of these third-party websites to understand their practices for handling your information.

10. Your State Privacy Rights

You can generally access, review and update your Personal Information by logging in your account making the necessary changes. If you have any difficulty doing so or have other questions about the Personal Information we hold about you, please contact us at privacy@dealerrater.com. To protect your privacy, we and our authorized employees and agents will take reasonable steps to verify your identity before granting you access to or making corrections to your Personal Information.

For residents who reside in the specific states listed below, you can control how your information is used in the following ways below in accordance with applicable law including the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act. For California residents, please see the separate Privacy Notice for California Residents.

• Data Access Request. You may request that we disclose certain information to you about our collection and use of Personal Information. We will provide a copy of this information in a standardized and commonly used format.
• Correcting or Deleting your Personal Information. You can review, update and request to change or delete your Personal Information subject to limitations, exceptions or requirements contained within applicable law. We may ask you to verify your identity before we accommodate your request in accordance with applicable law. Upon verifying the validity of a deletion request, we will delete your Personal Information from our records, and instruct any service providers or third parties to delete your information, when applicable.
• Opting Out of Communications. Our promotional materials include instructions for opting out of receiving further communications. If you no longer wish to receive promotional emails, you may opt out by contacting us with your request at the contact information listed below. Please note that even if you opt out of receiving marketing communications, we may still communicate with you regarding an established business relationship, if one has been established. Please allow a reasonable time after reaching out for us to process your request.
• Opting Out of Analytics Tools. You may opt out of having your data used by Google Analytics via Google's Ads Settings, Ad Settings for mobile apps, or any other available means. Please visit policies.google.com/technologies/partner-sites for more information on how to do this.
• Adjusting Cookie Settings. Most browsers accept Cookies until you change your browser settings. If you do not wish for the Site to collect your information using Cookies, you can typically disable the use of Cookies (or disallow the use of Cookies on specific websites) by changing your browser settings. However, if you remove or reject our Cookies, it could affect how the Site works for you.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out. For this opt-out to function, you must have your browser set to accept all browser cookies.

Colorado, Connecticut, Utah, and Virginia consumers (as defined by the applicable law) have the right to opt-out of our collection of your personal data for purposes of sale (as defined by the applicable law) that can be exercised by submitting your consumer right request to privacy@dealerrater.com or calling us at 800.266.9455.

Colorado, Connecticut, and Virginia consumers (as defined by the applicable law) have the following additional rights:

• The right to opt-out of our collection of your personal data for purposes of profiling.
• The right to appeal the denial of a rights request under applicable law.

Please note that the above rights are not unqualified, we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

You may make any of the above requests by emailing privacy@dealerrater.com or calling us at 800.266.9455.

Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as "sales" are defined in Nevada Revised Statutes Chapter 603A. Nevada residents who nonetheless wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@dealerrater.com.

11. Notice to California Residents

If you are a California resident, state law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, please visit DealerRater's California Privacy Notice.

12. Notice to Canadian Residents

If you are a Canadian resident, federal and provincial law may provide you with additional rights and information regarding our use of your Personal Information.

Transferring Personal Information

We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this notice and applicable Canadian privacy legislation. You are welcome to contact us to obtain further information about our policies regarding service providers outside of Canada.

By submitting your personal information or engaging with the Sites and/or Services, you consent to this transfer, storage, and/or processing.

Accessing and Correcting Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the personal information that we hold about you. You also have the right to request that we provide you with a copy of your Personal Information in a structured and commonly used format.

If you want to review, verify, or correct your Personal Information you may also send us an email at privacy@dealerrater.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Withdrawing Consent

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@dealerrater.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

We have designated a person in charge of the protection of Personal Information. Their contact information can be found in the section Contact Information below.

Communication Preference

CHOICE OF LANGUAGE. The parties have expressly requested that this Agreement and any ancillary documents be drafted in the English language. Les parties aux présentes ont expressément requis que la présente convention et tous les documents y afférant soient rédigés en langue anglaise

EMAIL CONSENT. You agree to receive electronic newsletters, marketing and promotional materials from Cars.com, 300 S. Riverside, Chicago, IL 60606 (userresearch@dealerrater.com, noreply@dealerrater.com, help@dealerrater.com, support@dealerrater.com, marketing@dealerrater.com, sales@dealerrater.com) (800.266.9455) via facsimile, email, and otherwise, and containing information on its products or services. You understand that it may withdraw this consent at any time.

13. Notice to European Residents

These Sites and Services are intended for use solely in the United States (including its territories and commonwealths), and Canada by U.S. and Canadian residents. We make no claims that the Sites and Services are appropriate for use outside of the United States or Canada. DealerRater does not knowingly collect or solicit Personal Information from residents of the European Union. If you believe that we may have any information from or about an EU resident, please email us at privacy@dealerrater.com. No information should be submitted to or posted at DealerRater by any EU resident.

14. Changes to this Privacy Notice

We reserve the right to update and periodically amend this Privacy Notice at our discretion and at any time. If we make changes to this Statement, amendments will be posted online and the date of update will be included. Your continued use of DealerRater.com and its affiliated sites after any such update indicates your agreement to the same.

15. Contact Information

If you have any questions, comments, or concerns about this Privacy Notice, the California Privacy Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us per the information below.

We have designated a person in charge of the protection of Personal Information. You may contact them at: General Counsel and Compliance Officer – Angelique Strong Marks. Contact: 312.601.5000

Phone: 800.266.9455
Email: privacy@dealerrater.com

Finally, you may also mail us with general questions at:

DealerRater.com, LLC
300 S. Riverside Plaza
Suite 1000
Chicago, IL 60606

Effective Date: March 8, 2023