INFORIDE® PRIVACY POLICY

LAST UPDATED: January 30, 2023

Worth Advertising Group, Inc. ("Worth Advertising Group" "we" “our” or “us”) is committed to protecting your privacy, and as such has adopted privacy practices to protect the information we collect from you. The practices are described in this privacy policy (the “Privacy Policy”). Our Privacy Policy is designed to provide transparency into our privacy practices and principles, in a format that our users can navigate, read and understand. We are dedicated to treating your personal information with care and respect.

This Privacy Policy covers our online privacy practices with respect to use and disclosure of Information that you may provide when you access, download or use the InfoRide Mobile Application (the "InfoRide App")(when available), visit the InfoRide websites located at inforideauction.com and inforide.app (the “Website(s)”) or access the InfoRide SaaS Platform available to Dealerships and their authorized End Users (the “Platform”) (collectively referred to herein as the “Services”). Please review the following Privacy Policy and contact us at evan@inforideauctions.com, if you have any questions or concerns.

ACCEPTANCE OF TERMS:

By accessing, downloading or using our Services you agree to be bound by the terms and conditions of this Privacy Policy, our Terms of Use available at this link and by the terms of our End User License Agreement (“EULA”) or Dealership SaaS Agreement (“SaaS Agreement”) as may be applicable. By accessing our Services you acknowledge that you fully understand our Privacy Policy and freely consent to the collection, use and disclosure of your Information, as described in this Privacy Policy. If you do not consent to the collection, use and disclosure practices described below, you must immediately cease any access or use of our Services.  

PRIVACY POLICY SCOPE:

This Privacy Policy describes:

• Information We Collect From You and How We Collect It
• Parents and Children
• Third Party Information Collection
• How We Process Your Information and Our Lawful Basis for Doing So
• How We Share Your Information
• Your Choices About Our Collection, Use and Disclosure of Your Information
• Opt-In/Opt-Out Communications
• Information Retention and Accessing and Changing Your Personal Information
• California Privacy Rights – Notice to California Residents
• Data Protection and Security
• Consent
• Sensitive Data
• Third Party Sites and Links
• Analytics/Performance Cookies
• Email/Marketing Communications
• Changes to Our Privacy Policy
• Contact Information

This Privacy Policy applies only to Information we collect in the InfoRide App, Websites and Platform and other electronic communications sent through or in connection with the Services. This Privacy Policy DOES NOT apply to information that we collect offline or on any other Worth Advertising Group owned apps or websites, including third party websites you may access through the Services; or to information that you provide to or is collected by any third party. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy section below). Your continued use of the Services after we revise our Privacy Policy means you accept and consent to those changes, so please check the Privacy Policy periodically for updates.

INFORMATION WE COLLECT FROM YOU AND HOW WE COLLECT IT:

When you use the Services, certain types of data may be collected from you, including: (1) Personally Identifiable Information; and (2) Non-Personal Information (collectively referred to as “Information”). For more detailed  information on the collection of personal information from children, please refer to the “Parents and Children” section below.

Personally Identifiable Information

You may be able to view, access, use or download the Services (or portions thereof) without disclosing any information that, either alone or in combination with other information, can be used to uniquely identify, contact or locate you (collectively, “Personally Identifiable Information” or “PII”). However, certain portions of the Services may only be accessible by disclosing certain PII, including your name, email address and phone number. We collect information in different ways, depending on your use of the Services and whether you are a customer shopping on the inforide.app Website or InfoRide App (“Buyer”), or a an authorized end user (“End User”) of an authorized dealership (“Dealership”) using the Platform pursuant to a separate SaaS Agreement entered into by and between Worth Advertising Group and the Dealership. Buyer, End User, and Dealership, are all collectively referred to herein as “users”. Users actively provide information to Worth Advertising Group in various ways while using our online Services. For example, you share information when you:

• Create a Buyer account on the inforide.app Website or InfoRide App;
• Create a Dealership or End User account on the Platform;
• Request information about our Services where we collect information;  
• Use our chat feature in the inforide.app Website, InfoRide App or Platform;
• Upload Vehicle Data to the Platform as an End User or Dealership;
• Request customer service; or
• Contact us through any of our Services.

By providing PII, you acknowledge that you understand our collection, use and disclosure of it, as described in this Privacy Policy.

Automatically Gathered Information

Worth Advertising Group automatically tracks certain information about you based upon your behavior while using the Services. This information is used to better understand and serve you by responding to your particular interests and needs.

Usage Details

When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, date and time you access the Services, the number of links you click within the Services, any third party website and sections within the Services that you access, logs, resources and other communication data that you access and use on or through the Services.

Device Information

When you access the Services, we may collect information about your device and internet connection, including the device's unique device identifier, IP address, operating system, geolocation data, browser type, and network information.

Location Information

When you use the Services, we may collect Geolocation information, such as city and state you provide, or location information derived from your interactions with the Services, subject to the settings on your device or browser.

Use of Cookies (or mobile cookies)

Our Services may use cookies to enhance the user experience while using our Services. Cookies are pieces of information that some apps and websites transfer to the computer or mobile device that is browsing that app or website and are used for record-keeping purposes by many apps and websites. Use of cookies makes web browsing easier by performing certain functions such as saving your passwords, saving personal preferences regarding your use of the particular app or website, and ensuring that you don't see the same advertisement repeatedly. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of our Services.

Use of Web Beacons

A “web beacon,” “clear GIF,” “web bug,” or “pixel tag” is a tiny graphic file with a unique identifier that is similar in function to a cookie, but allows us to count the number of users that have visited certain pages or screens of our Services, and to help determine the effectiveness of promotional or advertising campaigns, and for other related app statistics.

We also may use these technologies to collect information about your activities over time and across third party websites, apps, or other online services linked to our Services (behavioral tracking).

PARENTS AND CHILDREN:

Our Services may not be used by anyone under the age of eighteen (18). Our Services are not intended for or directed to minors or children under 16 years of age and no part of our Services are designed or intended to attract anyone under the age of 16. We will never ask for or knowingly collect information from children. If you are a child under the age of 16, you are not permitted to use the Services and should immediately exit our Services. Consistent with the Children's Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 16. If you think that we have collected personal information from a child under the age of 16 through the Services, please contact us at Worth@worthadv.com and we will dispose of the information.

THIRD PARTY INFORMATION COLLECTION:

When you use the Services, and certain third party sites linked from the Services, third parties may use automatic information collection technologies to collect information, including location information about you or your device. These third parties may include: InfoRide business partners, advertisers, ad networks, ad servers, your mobile device manufacturer, your mobile service provider, or other service providers.

The information they collect may be associated with your personal information and location or they may collect information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about any third party content, advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE PROCESS YOUR INFORMATION AND OUR LAWFUL BASIS FOR DOING SO:

Generally

We use Information that we collect about you or that you provide to us, including PII to:

• Create and maintain your Buyer account;
• Create and maintain your authorized Dealership and End User account (as applicable);
• Provide the functionality and Services requested or purchased;
• Connect Dealerships and End Users with Buyers;
• Process payments (only through our third-party payment processor);
• Facilitate your orders, bids and requests for Services;
• Provide users with customer service and technical support;
• Provide users with a tailored experience when using our Services;
• Enhance functionality of our Services;
• Protect the security and integrity of our Services and help prevent fraud;
• Conduct analytics;
• Notify you when updates are available, and of changes to any services we offer or provide through it.
• To send important notices, such as communications about changes to our terms, conditions and policies.

The Information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Recognize you when you use the Services.

Information Provided at Time of Registration

To access and use certain of the Services, you may be required to register a unique username and password, by entering your name, e-mail address, phone number, and other information that assists Worth Advertising Group in providing access to the InfoRide App, Websites, Platform and other Services selected by you. This information is necessary for us to provide you with access to and use of the Services. Two-factor authentication may be required.

Supplemental Information Provided While Using the Services

Supplemental information may be requested and provided by you through the Services to facilitate the offering of Services and functionality requested or purchased by you or the Dealership for which you are an authorized End User of, including the following:

• As an authorized End User of a Dealership certain vehicle inventory information may be provided by you (“Vehicle Data”). Vehicle Data may include, but is not limited to, vehicle photographs, VIN numbers, vehicle make, model, trim, color, year, features, and other specifications. Vehicle Data is information that we obtain from you, related to the vehicle inventory of the Dealership of which you are an authorized End User. Vehicle Data includes data in electronic form input or collected through the Platform uploaded by an End User. We may collect and process the Vehicle Data provided by you, in order to provide the Services requested or purchased by you, or the Dealership for which you are an authorized End User of.  
• As a user of the inforide.app Website, InfoRide App and/or Platform certain chat feature functionality may be made available for you, to allow Buyer and Dealerships/End Users to directly connect in order to engage in conversations related to the vehicle purchase and sale. All information provided by you in the chat feature may be stored, saved and/or reviewed by Worth Advertising Group.
• Handling contact and support requests. If you send us an email through our “Contact” link to request user support, or if you contact us by other means including but not limited to via phone, we process your personal information to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.

Payment Information

To facilitate processing payments, you may need to create a digital wallet and provide a payment method and the following information: name, billing address, credit card or banking information, and such other applicable information as requested by our third party payment processing service, which is currently Stripe, whose privacy policy can be reviewed at https://stripe.com/privacy. If your payment method information changes (e.g., card number, account number, routing number, expiration date, CVV), then our third party payment processor may acquire additional information from you. This information is necessary for Stripe to verify and process payments for transactions made through the Services.

Geo-location Information.

When you use certain of our Services, we may collect information about your precise or approximate location as determined through your IP address, GPS, or nearby devices (Wi-Fi access points, cell towers, etc.) in order to provide you with information from Dealerships located nearby.

HOW WE SHARE YOUR INFORMATION:

We may disclose non-personal information about our users, and information that does not identify any individual or device, without restriction. We do not sell, share, or otherwise transfer your personal information to third parties, except for sharing your personal information with our third-party service providers and partners in furtherance of Worth Advertising Group’s Business Purposes as described below. We may also share your personal information when we believe sharing is necessary to comply with applicable law, enforce our policies, or protect our or others' rights, property, or safety. We may share your Information as follows:

• To fulfill the purpose for which you provide it. For example, if you contact us regarding a privacy request, we will transmit the contents of that email and your email address to the proper party at Worth Advertising Group to address your concern.
• By using the Services, users consent to Worth Advertising Group’s collection and use of the Information provided by you in order to advance Worth Advertising Group’s purposes, including, but not limited to: (a) maintain and service your account; (b) process transactions and request for Services, which includes but is not limited to: (i) processing Vehicle Data; (ii) monitoring chats; (iii) connecting Dealerships/End Users with Buyers for vehicle discussions, bids and purchases; and (iv) processing payments for Services; and (c) providing similar services to you (collectively “Worth Advertising Group’s Business Purposes”).
• We may share your personal information with other trusted third-party companies and individuals to provide and improve the Services, facilitate and complete transactions and requested services, analyze use of our Services,  perform analytics and produce statistics on the Services, or deliver other requested services and features to you.
• We may share you geo-location information with Dealerships in order to connect you with Dealerships in your area.
• For any other purpose disclosed by us when you provide the Information.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including under any EULA or SaaS Agreement, as applicable.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Worth Advertising Group our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• To an affiliate, subsidiary organization, buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Worth Advertising Group's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Worth Advertising Group about our Service users is among the assets transferred.

YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION:

We strive to provide you with choices regarding the Information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your Information.

• Do Not Track Signals. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
• Location Information. You can choose whether or not to allow the Services to collect and use real-time information about your device's location through the device's privacy settings and location settings. If you block the use of location information, some parts of the Services may become inaccessible or not function properly.

OPT-IN/OPT-OUT COMMUNICATIONS:

We provide users of the Services the opportunity to sign-up for certain email communications using their email address. Users are not obligated to sign-up for these communications. You may revoke your consent to receiving these communications at any time by clicking the unsubscribe button in the email correspondence or contacting us at evan@inforideauctions.com. 

INFORMATION RETENTION AND ACCESSING AND CHANGING YOUR PERSONAL INFORMATION:

Information collected through the Services will be deleted when such Information no longer serves one of the above-mentioned purposes. You can review and change the personal information that you entered, by logging into the Services and visiting the settings page. 

You may also send us an email at evan@inforideauctions.com to request access to, correct, or delete any Information that you have provided to us. In some cases, we may not be able to delete your Information except by also deleting your user access. 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.

CALIFORNIA PRIVACY RIGHTS - NOTICE TO CALIFORNIA RESIDENTS:

If you are a California resident, California law may provide you with additional rights regarding our use of your Information. To learn more about your California privacy rights, visit  https://oag.ca.gov/privacy/privacy-laws 

DATA PROTECTION AND SECURITY:

We have implemented measures designed to secure your PII from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your Information also depends on you. Be sure not to let others access your device or account. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your PII, we cannot guarantee the security of your PII transmitted through our Services. Any transmission of PII is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures we provide.

CONSENT:

When you provide us with PII through our Services, through the mail, over the phone, or by using the Services we imply that you consent to our collecting it and using it to carry out Worth Advertising Group’s Business Purposes.  

IMPORTANT: Except as stated herein as necessary to carry out Worth Advertising Group’s Business Purposes and to provide the Services, we do not share your personal information to any third parties, including but not limited to advertisers, strategic partners or vendors.

THIRD PARTY SITES AND LINKS:

The Services contain links to third party sites. Please be aware that we are not responsible for any of the content, information, data, activities, offers, deals, promotions, products, services or advertisements (collectively, “Content”) on these third party sites, that may be made available to you through these third party sites, or that may be advertised on the Services. By accessing any linked third party site, you assume all risk of use and reliance upon any of the Content contained on the third party site.  

By providing you a link to these third party sites, we make no representations, warranties, approvals, or endorsements regarding the Content provided or the nature, quality, or accuracy of such Content, or other services made available. We encourage you to read the terms of use and the privacy policies of each such linked third party site you choose to access.

ANALYTICS/PERFORMANCE COOKIES:

Worth Advertising Group may use analytic tools to analyze the performance of our Services as well as how visitors use our Services including:

• Google Analytics - For more information on Google Analytics cookies and privacy policies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

EMAIL AND MARKETING COMMUNICATIONS:

We are committed to being compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM Act”). All e-mails you receive from Worth Advertising Group are intended to fully comply with the CAN-SPAM Act. You can withdraw your consent to receive any direct marketing communication from us by contacting evan@inforideauctions.com or following the opt-out instructions in our email communications.

CHANGES TO OUR PRIVACY POLICY:

We reserve the right to change the terms of this Privacy Policy at any time by posting those changes to this Privacy Policy, so that you are always aware of our processes related to collection, use and disclosure of your Information. For significant changes, we will notify you by posting a prominent notice on our Website indicating at the top of the Privacy Policy when it was most recently updated.  Please consult the Website regularly for important changes to the Privacy Policy as they occur.

You agree to be bound by all the provisions of the Privacy Policy that are displayed on the Website on the date you use the Services. Your continued use of the Services, indicates your acceptance of all of the provisions of this Privacy Policy displayed on the Website on the date of such use.

CONTACT INFORMATION:

To ask questions or comments about this Privacy Policy and our privacy practices, contact us at:

Worth Advertising Group

625 W. University Avenue

Gainesville, Florida 32601

Telephone Number: 352-519-5852

Email address: evan@inforideauctions.com