Privacy Policy

TIER10

PRIVACY POLICY

Updated: August 1, 2018

ABOUT US

We are an ad agency serving the automotive industry by providing marketing services for our business clients, primarily regional automotive dealer associations (Associations) (collectively, our Services) to help Associations and their member dealers (Dealers) sell and service more cars.

OUR APPROACH TO PRIVACY PROTECTION

Tier 10 Marketing, LLC and our affiliates (Company, us or we) have adopted this Privacy Policy, which applies to all users of our website tier10.com, and of its subdomains, and any websites specifically identified as belonging to us (collectively, Sites). We are committed to protecting the privacy and personal information of users of our Sites and Services.

This Privacy Policy describes our policies and procedures for the collection, use and disclosure of your information and data on our Sites and through our Services. Information we collect on behalf of our clients or that they collect and store in one of our applications is subject to their own privacy policies and practices. Our Privacy Policy applies only to personally identifiable information we collect on our own behalf. Our Sites also contain a link to Terms of Use which govern your use of these Sites. You understand that by using the Sites or Services you agree to the terms of this Privacy Policy and the Terms of Use.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

The personally identifiable information we collect may include your name, address, zip code, phone number, email address, and other identifying information, and may also include information about vehicles you own or lease (Personally Identifiable Information or PII). We collect PII in a number of different ways and from a number of different sources. We collect PII you provide us through our Sites or when using certain aspects of our Services. We may also collect PII you provide to our clients, automotive dealers, auto manufacturers, or our authorized vendors, as well as information we obtain from third party databases (collectively, our Partners).

As part of our Services, we may serve as an intermediary between you and our clients where we have access to emails, calls, chats or texts. In this capacity, we would have the ability and authority to read or listen and retain the content of those communications, including contact information. In all cases, the information we may retain and how we may use it are subject to this Privacy Policy and applicable law.

We may also collect usage information about how our Sites and Services are accessed and used. This may include information such as your computer’s IP address, browser type, type of device used, pages on our Sites that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

HOW WE USE YOUR INFORMATION

We use your PII to provide information you request from our clients about their vehicles or services, to respond to your inquiries, and to customize information and advertising that we believe may be of interest to you. We may

also use your PII to provide you with marketing materials, as well as other information we believe may be relevant to you. We also use remarketing services to advertise to you on third party websites, such as Google, Bing, Twitter and Facebook and their partners. To control or opt out of any of their ad services, or to review their privacy policies, please visit their sites.

Your PII may be shared with our affiliates and Partners, and may also be disclosed to third parties who work with us, our affiliates, or Partners. Our clients, dealers and auto manufacturers, for example, may use that information to contact you. We may also work with third parties that provide certain functions on our behalf, such as analyzing data or authenticating contact information.

We require our third party service providers to contractually commit to protecting your PII in accordance with both industry standards and applicable law. While we have implemented policies and procedures to protect PII, we cannot control, and are not responsible for, the manner in which our Partners or other third parties use that PII. Accordingly, you should review their privacy policies, as well.

We may also use your PII by combining it with non-personal information and aggregating it with information collected from others. We use this aggregated data in a number of ways, such as to improve the quality and value of our Services and to analyze and understand how our Services are used. In addition, we may provide aggregated data to our Partners so that they may understand how people use our Services or their own.

OPTING OUT

If you wish to stop receiving email communications from us, you may “unsubscribe” using the link at the bottom of the email you receive. If you wish to be placed on our postal mailing Do Not Contact list, email us at Contact Us and provide the name and address as listed on the mailing. Use the STOP function to stop text communications. To control ads appearing on your browser or mobile device you can adjust your settings or use third party ad blocking tools.

COOKIES

We may use cookies to recognize you and optimize your experiences when visiting our Sites and using our Services. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. However, if you do not accept cookies, you may not be able to use all of the features of our Sites or Services. We do not currently support Do Not Track signals other than cookies.

EXTERNAL LINKS

Our Sites or Services may contain links to other third-party websites. After you leave our Sites, we have no control over the information collected from or about you. We are not responsible, and assume no liability, for the privacy policies and/or practices on any third-party websites. This Privacy Policy only governs information collected by us on our Sites.

HOW WE PROTECT YOUR DATA

We use safeguards that satisfy generally accepted industry standards to preserve the integrity and security of your PII. However, we cannot guarantee the security of information you provide us with certainty or warrant it will not be accessed, disclosed, altered, or destroyed by unauthorized persons. We will make all legally required

disclosures of any breach of the security, confidentiality, or integrity of your PII, in the manner and within the time periods required by applicable law.

JURISDICTIONS

Your PII is collected and used by us within the United States. We make no representation that our Privacy Policy complies with the laws of any foreign jurisdictions, including the European Union’s General Data Privacy Regulation. If you choose to provide us with PII from outside the United States, you do so at your own risk and are responsible for compliance with any applicable foreign laws.

COMPLIANCE WITH LAW ENFORCEMENT

We cooperate with government and law enforcement officials, as well as private parties, to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties that we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, including, but not limited to, subpoenas, to protect our property and rights or that of a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or subject to legal action.

OUR POLICY TOWARDS CHILDREN

Our Sites and Services are not targeted to or intended for use by children. We are concerned about the privacy and safety of children when they use the internet. Accordingly, we will not knowingly request PII online from anyone under the age of 13 without prior, verifiable parental consent. Unfortunately, we cannot always determine the age of a visitor to our Sites or user of our Services.

CORPORATE TRANSFER

In connection with a corporate merger, acquisition, divestiture, asset sale, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves some or all of our assets, including your PII.

CHANGES

We may modify our Privacy Policy, at any time and for any reason, by posting the revised Privacy Policy on our Site. Your use of our Sites or Services after any such posting indicates your acceptance of our modified Privacy Policy.

CONTACT US

If you have any questions or concerns regarding your privacy when using our Sites or Services, please contact us at Contact Us. In certain circumstances, you may have the right to access, update or to delete the information we have on you; if you are unable to do within your account settings, please contact us. We will make every effort to respond promptly and address your concerns.