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Privacy and Police

1.Scope and Consent

This Privacy Policy (“Privacy Policy”) applies to the tools, features, and services (collectively, the “Services”) created and/or offered by EZLeads Management, Corp. (“EZ Lead”) including each and every of its owners, agents, officers, directors, shareholders, employees, contractors, sub-contractors, independent contractors, partners, members, managers, parents, subsidiaries and affiliates (together, “the EZ Lead Representatives”, “we” or “our”), through any EZ Lead application, including, without limitation all web-based and mobile applications (“Apps”) that reference or link to these Terms. This Privacy Policy is incorporated into EZ Lead’s Terms of Use (“Terms”). Capitalized terms not defined in the Privacy Policy are defined in the Terms.

This Privacy Policy covers:

A.Information collected from those who use our Services (“you” or “your”); and

B.Information that our Business Partners (defined below) share with EZ Lead or that we share with our Business Partners.

You accept and agree to be bound by this Privacy Policy when you access or use one or all of the Services that link to this Privacy Policy. This Privacy Policy does not cover the information practices of: (i) third-party individuals or entities who perform tasks on our behalf (“Service Providers”); (ii) our third-party business partners who provide websites, applications or other products or services that you may encounter or access through the Services (“Business Partners”); or (iii) any other third parties (collectively with Service Providers and Business Partners, “Third Parties”), even if you access, encounter or interact with such Third Parties through the Services. While we attempt to facilitate access only to those Third Parties that share our respect for your privacy, we are not responsible for the privacy policies or practices of Third Parties, and you are responsible for reading and understanding those Third Parties’ privacy policies.

2.Information Collected or Received

When you use the Services, EZ Lead may collect “Non-Personal Information” and “Personally Identifiable Information” (defined below) (collectively, “Information”) about you, your use of the Services, or the device you use to access the Services.

A.Non-Personal Information

“Non-Personal Information” is any information that does not enable identification of an individual, such as, without limitation, technical information, behavioral information, and aggregated information, including service usage information, web traffic information, content viewed on the Services, your preferences, and information about your operating system, browser, device, keyboard language and hardware.

B. Personally Identifiable Information

“Personally Identifiable Information” (or “PII”) is information that identifies you. Examples of PII that may be collected through the Services include, without limitation:

  • (i)Name
  • (ii)Email address
  • (iii)Mailing address
  • (iv)Telephone number(s)
  • (v)Login information
  • (vi)Social networking handle or username
  • (vii)Photos (e.g., for profiles)
  • (viii)Date of birth
  • (ix)Social security number
  • (x)Driver’s license state and number
  • (xi)Financial information
  • (xii)Employment information
  • (xiii)Residency or credit proof information (e.g., utility bill, copy of paystub, references)
  • (xiv)Insurance information

The specific Information actually collected by EZ Lead will depend on the portion of the Services you access. If Non-Personal Information is connected or linked to PII, we treat the Non-Personal Information as PII.

3.How Information is Collected

A.PII Provided Directly by You

You may voluntarily provide us with PII when using the Services, including, without limitation, when you perform the following activities:

  • Use Interactive Areas
  • Make submissions, post comments, or provide reviews or testimonials
  • Submit online forms or make requests for communication or support
  • Initiate or complete transactions through the Services
  • Send or receive Texts
  • Conduct and/or save searches
  • Electronically sign agreements

Please note that content posted to the Interactive Areas, including your submissions posted in such areas, may be publicly viewable or viewable by anyone who uses the Services. Therefore, if you upload or share any Information to the Interactive Areas, unless otherwise expressly stated by EZ Lead, such Information may be non-confidential and may become publicly available. This means that the Information may be collected, used, or redistributed by others, so please proceed with caution before posting anything sensitive or confidential to the Interactive Areas.

B.Information Collected Automatically

We and certain Third Parties may also automatically collect Non-Personal Information about you and your devices when you interact with the Services. This Information may include, without limitation:

  • Computer or device operating system information
  • IP address
  • Network information
  • Browser type and language
  • Connection speed
  • Mobile device ID
  • Device hardware type
  • Referring website or application accessed before or after accessing the Services
  • Parts of the Services accessed
  • Access times for and length of time spent on a page or using a feature
  • Content viewed
  • Geographic location

C.Information Collected Through Tracking Tools

When you access our Services, we or Third Parties may use technologies such as “cookies”, local storage capabilities, or other similar technologies to monitor usage of the Services (“Tracking Tools”). These Tracking Tools allow the collection of Non-Personal Information (such as pages viewed by you within a certain Service and the duration of the browsing) and PII (such as your login information), including over time and across different properties and devices. Among other things, Tracking Tools can enable EZ Lead to automatically activate certain features for you, make your experience on the Services simpler, more relevant and more convenient, and provide you with personalized, interest-based advertisements, as further described below. Tracking Tools are used widely across the industry.

D.Tracking Tools – In General

By accessing the Services, you consent to us setting and accessing Tracking Tools, including cookies, on your device and in the emails we send you, and to tracking your activities and your use of the Services through these Tracking Tools. For clarity, Third Parties do not have access to Tracking Tools set by EZ Lead on our Services except to the extent necessary to help us provide the Services. EZ Lead and Third Parties may use the following Tracking Tools:

Cookies: Cookies are small data files stored on your hard drive by a website, and may include session cookies (which expire once you close the browser) and/or persistent cookies (which stay on your browser and may be used by the browser on subsequent visits to the Services, unless deleted by you). Among other things, cookies help us make our Services and your experience better. For example, we use cookies to see which parts and features of our Services are popular, count visits to our Services, and improve or tailor the Services and our advertisements to make them more relevant to you. You can turn off your web browser’s ability to accept cookies, but certain parts of the Services may not work for you.

Unique Identifiers: We may use unique identifiers to collect information about your use of the Services on an individual basis, such as length of time spent on a particular page and pages viewed during a particular log-in period. We use this information to evaluate and improve the Services.

Web Beacons: Web beacons, or clear GIFs or pixel tags, are small graphic image files that can be embedded in web pages or emails to collect information about your use of our Services or the correspondences that we send. The information collected by web beacons allows us to analyze how and how many people are using the Services or when you open our emails.

Analytics and Other Technologies: We use other technologies and analytics services, such as Google Analytics, to help analyze how you use the Services and to collect and store information, such as how often you visit the Services, what features you use, what pages you visit, what emails you open, and what other sites or applications you used prior to and after visiting the Services. We use this information to improve our Services. These services may use cookies, including first party and third-party cookies, as well as other Tracking Tools. For example, Google Analytics uses cookies to inform, optimize, remarket, and serve ads based on your visits to the Services. Google’s ability to use and share information collected by Google Analytics about your visits to the Service is subject to the Google Analytics’ Terms of Use and Google’s Privacy Policy. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page or the Google Analytics Opt-out Browser Add-on.

Mobile Device Identifiers: Mobile device identifiers are stored on your mobile device and track how you use the Services through your mobile device. Mobile device identifiers enable collection of Non-Personal Information (such as usage and traffic data). As with other Tracking Tools, mobile device identifiers help EZ Lead learn more about your preferences and internet behaviors in order to operate and improve the Services.

4.Use and Sharing of Information

A.To Provide the Services

We use the Information collected, and may share such Information with Third Parties to provide, operate, and maintain our Services, including for the following purposes:

  • Personalizing, improving, and operating our business and the Services
  • Better understanding the needs and interests of you and others who may use the Services
  • Fulfilling requests you make related to the Services, including to respond to your support requests or to process and facilitate transactions conducted on the Services
  • Processing and facilitating payments
  • Providing Service announcements or providing you with further information, recommendations, and offers from us or Third Parties
  • Complying with applicable law, regulation, legal process, subpoena, or governmental requests, or other legal obligations
  • Resolving disputes or security or technical issues
  • Enforcing our agreements, including this Privacy Policy or the Terms, or investigating potential violations thereof
  • Protecting, investigating, and deterring against fraudulent, harmful, unauthorized or illegal activity, or otherwise as we believe to be necessary to protect the rights, property, or safety of EZ Lead, the EZ Lead Representatives, you, or the general public
  • Performing statistical analysis and research activities
  • Processing or storing Information through EZ Lead’s affiliated companies and authorized Third Parties, as reasonable for business purposes (including, as applicable, their affiliates as necessary to provide us with the requested services)
  • Other commercial purposes (including, without limitation, offering you insurance, financing, service contracts, or other products in connection with the purchase or sale of a vehicle)

If we share your PII for a purpose not mentioned in this Privacy Policy, we will receive your express approval prior to the disclosure.

B.Marketing and Advertisements

We may use your Information to send you information about our Services or the services of our Business Partners, including new products and promotions. Additionally, we may provide your Information to our Business Partners to contact you directly about their products and services, if we think you would be interested. Some advertisements may come from Third Parties called “ad networks.” Ad networks may include ad servers, ad agencies, ad technology vendors, and research firms. We do not provide PII to any ad networks for use not related to the Services. In some cases, advertisements served through the Services may be targeted to those who fit a certain general profile category or may be based on information inferred from the Information provided by you, your Services usage patterns, or your activity on Third Party services, including over time and across properties and devices. By using the Services, you consent to us providing you with marketing materials, which may include the following:

  • Direct Marketing: Communications or advertisements sent directly to you by EZ Lead or our Business Partners via telephone, mail, email, text, or other methods for the purpose of offering you products or services that may interest you.
  • Advertisements: Advertisements and commercials from us or Third Parties. Note that if you click on any Third-Party advertisements, you may be transferred to a website of the Third Party or receive other messages, information or offers from the advertiser and/or other Third Parties, and these advertisers and/or Third Parties may use their own Tracking Tools to collect information in order to send you advertisements and for their legitimate business interests.
  • Interest-Based Advertisements: Content and advertisements personalized to your interests, which are inferred from your activity on our Services and other sites and services, and based on information gathered by us or Third Parties using Tracking Tools. These advertisements may be served to you on our Services or other services, sites, or apps.

You may withdraw your consent through the “Contact Us” portal of the Website. Please note that even if you choose to remove your Information (opt out), you will still see advertisements while you’re browsing online, however they may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. Please note that if you opt-out of targeted advertising, we may still track your use of the Services for analytics, operations and security purposes.

C.Uses and Disclosure of Non-Personal Information

Non-Personal Information informs us how you interact with the Services. Some of this Information may be derived from PII, but, if so, we anonymize or aggregate the PII so that it does not identify the individual from whom it was derived. Non-Personal Information enables us and Third Parties we authorize to figure out how and how often you engage with different parts of the Services so that we can analyze and improve them. We may use Non-Personal Information for:

  • Industry analysis
  • Marketing and advertising
  • Facilitating collection of data concerning your interaction with the Services
  • Fighting spam/malware
  • Other business purposes (e.g., by reporting on trends in the usage of our Services)

EZ Lead may transfer and disclose Non-Personal Information to Third Parties at its own discretion.

5.Third Parties

We may share Information with Third Parties, and they may share Information with us. Unless we tell you differently, our Service Providers do not have any right to PII that we share with them beyond what is necessary to assist us or provide products or services requested or accessed by you.

You consent to our sharing of Information, which may include PII, with Third Parties, such as, without limitation:

  • Social media networks
  • Payment processors
  • Credit check and financing Service Providers
  • Vehicle inspectors
  • Vehicle history providers
  • Shipping providers
  • Web hosting services
  • Analytics and advertising Service Providers
  • Sales management tools
  • Marketing and promotion partners
  • Law enforcement or other legal authorities or bodies pursuant to a subpoena or court order; however, if permitted, we may allow you an opportunity to object to the subpoena or court order before we provide the requested Information

Some specific Third Parties include, without limitation:

  • Microsoft Azure
  • Google Analytics
  • PayPal
  • Facebook

We use commercially reasonable efforts to engage with Third Parties who share our commitment to protecting your Information, and who post a privacy policy governing their collection, processing and use of information. However, we do not control these Third Parties and are not liable for their practices, products, or services. Please read their terms of use and privacy policies to better understand their privacy practices. Please note that some Third Parties who receive your Information may be located in a country that does not have the same data protection laws as your jurisdiction.

Financial Information

If you make a purchase or sale through the Services, or otherwise use the Services in a way that involves sending or receiving payment, we may request Information to process and complete the transaction such as:

  • Credit card information
  • Name and contact information of financial institution
  • Account type
  • Routing number
  • Account number

This Information is collected and stored by our third-party payment processing companies, which may include companies like PayPal (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.

We may, from time to time, request and receive some of your financial information from our Payment Processor for the following purposes:

  • Completing transactions you initiate through the Services
  • Enrolling you in discount, rebate, and other programs in which you elect to participate
  • Protecting against or identifying possible fraudulent transactions
  • Otherwise as needed to manage and operate our business

If you fill out a credit application through our Services, we may collect and store your credit application details that are eventually shared with EZ Lead’s Business Partners or Service Providers, such as, without limitation, Capital One, and which may contain some or all of the following Information:

  • Name
  • Email address
  • Mailing address
  • Phone number
  • Date of birth
  • Driver’s license number
  • Employment information
  • Income information

By submitting your Information, you expressly authorize (i) EZ Lead to transfer such Information to its Business Partners or Service Providers, and (ii) EZ Lead, and any of its Business Partners or Service Providers, to use that Information in accordance with their respective privacy policies.

Ways to Limit our Information Collection and/or Use

If you want to limit our collection and/or use of your Information, you have several choices, including:

Limiting Information provided to EZ Lead: You can always opt not to disclose certain Information to us; however, if you choose not to provide us with certain Information, you may not be able to access certain features or services. Terminating your Account(s): You may be able to limit our collection and use of some of your Information by terminating your Account(s) on the Services.

Your choices for Tracking Tools: You can opt-out of collection by certain Tracking Tools as described above. Most browsers will allow you to erase cookies from your computer’s hard drive or from your device, block acceptance of cookies or receive a warning before a cookie is stored. You may also be able to erase or disable other Tracking Tools using the settings of your browser or mobile device. However, please note that if you block or erase Tracking Tools then our Services (and your experience) may be limited.

Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. We do not support Do Not Track requests at this time. Furthermore, we can’t and don’t make any promises about how Third Parties react when you set this signal on your browser.

Deleting or Modifying Your PII

If for any reason you wish to close your Account or delete or modify your PII, you can contact us through the “Contact Us” section of the Website and we will make reasonable efforts to submit to your request, subject to applicable laws, rules, regulation, or court order. Please note that unless you instruct us otherwise, or as set forth in this Privacy Policy, we may retain and use Information collected from you after termination of your Account, for as long as reasonably required, for the purposes of which such Information was collected, including, without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms or Privacy Policy, and/or to enable you to reinstate your Account, all as permitted under any applicable privacy laws. Furthermore, public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public. Aggregate and/or anonymous information derived from your Account and/or use of the Services may remain on our servers indefinitely.

Changes to the Privacy Policy

EZ Lead reserves the right to make changes to its Privacy Policy at any time and for any reason without prior or subsequent notification. All changes are effective as of the date modified and your continued use of the Services after the indicated date will constitute acceptance to be bound by those changes. EZ Lead reserves the right to stop, temporarily or permanently, the operation of any and all Services without notice, at any time. All information (ours or yours) made available on the applicable portion of the Services may be removed or deleted, so please make your own copy of any Information you submit to EZ Lead. EZ Lead will not be liable to you or to any third party for any changes, suspension, or discontinuance of the Services or any malfunctions that may occur in connection thereto.

Children’s Privacy

We do not intend to and do not knowingly collect PII from children under the age of seventeen (17). We reserve the right to request proof of age at any stage so that we can verify that children under the age of seventeen (17) are not using the Services.

Business Transfers

In the event of a business transfer, your Information is typically one of the transferred business assets. Additionally, if we, or substantially all of our assets, are acquired, or if we go out of business or enter bankruptcy, your Information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Information, including your PII, as set forth in this policy. ,

Interpretation

The section and paragraph headings in this Privacy Policy, as well as all summaries included in this Privacy Policy, are for convenience only and shall not affect the Privacy Policy’s interpretation. Any use of “including”, “for example” or “such as” in this Privacy Policy shall be read as being followed by “without limitation” where appropriate.