Effective Date: April 03rd , 2023

Privacy Notice

This is the United States Privacy Notice (“Privacy Notice”) of Dealerware, LLC (“Dealerware”, “we”, “us”, or “our”). Dealerware is a subsidiary of Audi of America.

We at Dealerware recognize the importance of protecting the personally identifiable information of our partners and their customers (“Retailers”). To demonstrate our commitment to maintaining the privacy of personally identifiable information, we have created this Privacy Notice to disclose our privacy practices for the personally identifiable information that we collect and receive through use of our products and services either offline, (e.g., through our in-person interactions with you) or online through our websites and apps (collectively, the “Services”).

Please note, most personal information Dealerware collects is collected on behalf of Retailers who license and use our Services. Any information collected about you through your

Retailer’s use of our Services is collected on behalf of the dealership which has independent use and access to it. Retailers may download, retain and use this information outside of Dealerware’s systems. For more information on how your dealership uses personal information, including information collected through the use of Dealerware’s Services, please refer to your Retailer’s privacy policy or contact your dealership directly.

You can also download a copy of our Privacy Policy here.

What Personally Identifiable Information Dealerware Collects

In the course of working with our Retailer partners we collect the following personal information about individuals who work with Retailers:

• Contact information such as name, email address, and phone number
• Employment information such as job title and location

On behalf of Retailers, we collect the following information regarding vehicles driven (“Vehicle Information”):

• Travel details such as information about use of the vehicle such as where a vehicle is rented, where and when a vehicle is returned, gas consumption, mileage and other information related to the vehicle
• Geolocation and telematic data collected as a part of the Dealerware services that allows Dealerware to use a global positioning satellite or other technology to track, locate and/or disable the vehicle and to provide such information and the capability to track vehicle assets

On behalf of Retailers we collect the following information from drivers of Retailer vehicles (“Driver Information”):

• Contact information such as name, email address, mailing address, phone number, and emergency contact information
• Biographical and demographic information such as data of birth, age, photograph, driver’s license number, passport number, and nationality. We also collect text fields on your driver’s license and payment card to collect information necessary to rent a vehicle (e.g., name, expiration date, driver’s license number)
• Travel details and preferences such as dates of rental, location of pickup and drop-off of a rental vehicle, vehicle preferences (e.g., vehicle size or type and use of ski or surf rack), and insurance information
• Geolocation and Telematic Data collected from the vehicle and other devices installed on the vehicle
• Inferences drawn from any of the personal information described above to create a profile about your preferences, behavior, characteristics, and attitudes
• Sensitive Personal Information such as financial information or location data collected in connection with a vehicle rental. Audi on Demand uses sensitive personal information for specific purposes such as to process transactions.

Generally, we only retain Driver Information in order to enable the Retailer to deliver the Dealerware services. We retain Driver Information in an aggregated or deidentified form (i.e. not personally identifiable) to produce analytics and to improve our Services.

From website and/or app visitors we collect:

• IP address
• Information on your interaction with our Services and advertisements such as pages you visit on our Sites

From time to time, we may receive personal information about potential customers (e.g., Retailer employees) who purchase and license our Services. We may receive this information from our service providers, data brokers, or business partners. We may combine this information with other information we process.

We may aggregate any personal information that we collect from our websites and apps in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for our own legitimate business purposes without restriction.

How Personally Identifiable Information is Collected at Dealerware

• Personal information collected when you rent a vehicle from a Retailer. We collect information when you rent a vehicle, including but not limited to, geolocation data, photographs including from your driver’s license, information about relevant health conditions, travel details including location where vehicle is rented and the date of rental, and vehicle preferences (e.g., vehicle type, use of ski or surf rack)
• Personal information collected when you interact with our Sites. We collect data through our website and apps and automatically from devices you use to connect to our Services. For more information about this, please our “Online Tracking and the Use of Cookies and Other Technologies” below
• Personal information from public or third party sources. We may collect information from publicly-available or third party sources including, but not limited to, social media and other websites that enable social sharing, government agencies, public or third party information sources, third party service providers, travel agents, or business partners, and our affiliates. We also may combine information we have collected from multiple sources
• From our retail partners. We collect some information from our retail partners about their employees and customers

How Personally Identifiable Information is Used Dealerware

Depending on the Services provided to you, we use personal information to:

• Provide and administer the Services
• Communicate with current Retailer customers regarding our services and offerings
• Provide Retailers with customer service and support
• Research, develop, manage, protect and improve our Services
• Maintain and develop our service-oriented software and other business systems
• Analyze data or have a third party do so on our behalf
• Track the location and use of a Retailer vehicle
• Send our Retailer customers information about products and services or materials that may be of interest to you
• Process payments
• When you use our online services, we may also use your information to evaluate what portions of our online services are visited more often than others, determine where visitors came from, where they go, and how long they stay on a particular page, or on our websites in general
• Protect our legal rights and manage the security of our Services, vehicles and property
• Prevent fraud and protect our business interests and rights, privacy, safety and property, or that of the public
• To protect and enforce our contractual rights
• To disclose information to government and regulatory authorities when required by law or in response to legal processes, obligations, or requests

Our vehicles are equipped with Global Positioning Systems (“GPS”) that we use for vehicle tracking and anti-theft purposes. GPS allows us to determine the location of your vehicle during your reservation. We also equip our cars with technology that monitors driver behavior and accident detection factors. Dealerware uses this data to manage where its vehicles are stored and parked, help you locate a car you have reserved, provide roadside assistance, improve our services, locate lost or stolen vehicles, and enforce our legal rights.

From time to time, we also may combine your personal information with information obtained from other sources, including third parties, in order to provide you with more customized Services and product offerings.

We may use personal information collected from any of the sources listed in “How personal information is Collected at Dealerware” section of this policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Services, identifying usage trends and determining the effectiveness of our promotional campaigns. We may also use inferences drawn from personal information to create a profile reflecting your preferences.

How We Disclose Your Personal Information

We disclose your information:

• Within our family of companies. We share data with other companies in the Dealerware family, including our parent company, Audi of America
• Service providers and third parties. With service providers that provide services on our behalf, which include advertisers, ad servers, content providers, credit card processors, data processors, website development and support, fulfillment services providers, e-mail list hosting companies and distribution companies), and professional services providers including accountants, auditors, and legal advisors
• With our business partners. We share information with our partners including the Retailer who provided you with the vehicle
• With government, regulatory, or law enforcement organizations. Dealerware reserves the right to disclose your information to government agencies to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law. We also may disclose your information to agencies responsible for the processing or handling of traffic or parking related violations

We may also transfer or assign your personal information to third parties as a result of or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.

We do not sell your personal information or transfer personal information to third parties to use for their own benefit; however, we allow certain companies to place tracking technologies like cookies on our Sites. Those companies receive information about your interaction with our Sites that is associated with your browser or device and may use that data to serve you relevant ads on our Sites or others. Except for this kind of sharing, we do not sell any of your information. For more information about your choices, please see “Your Privacy Choices.” below

Online Tracking and the Use of Cookies and Other Technologies

If you use our websites and apps, certain information may be collected from your computer or device in the course of your use of our websites and apps. As with many websites and apps, we may use both session based and persistent “cookies” and/or other technology (e.g., web bugs, e- mail bugs, clear GIFs, web beacons, tracker GIFs and “clickstream” data logs) in our Websites or in our electronic communications with you to enhance the functionality of our websites and apps and services. These technologies also make your transactions and other activities more convenient and efficient.

Cookies “Cookies” are small amounts of data that a website can send to your web browser and store on your computer. It is our policy not to save sensitive data, such as passwords or credit card information, in cookies.

Most web browsers are initially set up to accept cookies. You have the option of disabling or refusing cookies at any time in your browser preferences. However, note that some parts of our online Services will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized preferences, and/or may have difficulty completing transactions.

The use of cookies is an industry standard, and as such, you will find that most major websites use them. Dealerware and Dealerware’s affiliates have two (2) primary uses for cookies. First, we use them to specify a user’s preferences. For example, we use cookies to store information about travel preferences and rental history. Second, we use cookies to track usage trends and patterns. This helps us understand our users’ needs better and improve areas of our online Services.

IP Addresses

An IP address is a unique number that is automatically assigned to your computer whenever you are using the Internet so that your computer can be identified on the Internet. This allows us to gather useful information and data about our customers’ use of the site.

Dealerware collects IP addresses for the purposes of: helping us diagnose problems with our main computers, for system administration, to report aggregated information to our business partners, and to audit the use of our website. When users request Web pages from our website, our Web servers log the user’s IP address. We do not normally link IP addresses to other personal information, which means that a user’s session will be logged, but the user will remain anonymous to us. For example, we collect and/or track the home server domain name, the type of computer, and the type of Web browser used by you to access this website. Such collection and tracking information is gathered by us as you navigate through our websites, and will be used by us for our business purposes only.

In select instances, we may use IP addresses to help us identify you when we feel it is necessary to enforce compliance with our website Terms of Use or to protect our service, site, users or others.

Third Party Use of Technology

Third parties (including, but not limited to, software vendors, advertisers, ad servers, content providers, and services providers) may also use similar technologies by or through our online Services or through their own websites. In connection therewith, such entities may collect information about you and your usage activity on this and other websites. Dealerware does not control these third parties and is not responsible for the actions of our third party business partners. We encourage you to check their terms of use and privacy policies for such information.

Internet Based Advertising

We may use third-party servicing technology and service providers to serve ads on our behalf across the Internet and sometimes on our apps or websites. They may collect non-personally identifiable information about your visits to our online Services, and your interaction with our products and services. They may also use information about your visits to send you targeted advertisements for goods and services. This information is collected through the use of a pixel tag, or similar technology which is industry standard technology used by most major websites. If you would like more information about this practice and to know your choices about not having this non-personally identifiable information used, please visit http://www.networkadvertising.org/managing/opt_out.asp.

We may also share usage information about visitors to our online Services with selected third parties for the purpose of targeting our online advertisements on our websites and other websites. To do this, we use web beacons and cookies provided by our third-party ad server on our websites. In connection with those activities, third parties may have access to and use information about your online usage activity.

Web Beacons

Web pages may contain an electronic file called a web beacon that allows a website to count users who have visited that page or to access certain cookies.

Face ID and/or Touch ID

If you access our application through an Apple device or an Android/Google device, we may offer Face ID/Touch ID for Apple devices or Face Unlock/Fingerprint Unlock for Google/Android devices as an alternative authentication method for logging into your profile or account. We do not have access to the data associated with your enrolled face picture or fingerprint. We are only notified as to whether your log-in authentication was successful. For more information, please review Apple’s Platform Security Guide at

https://support.apple.com/guide/security/welcome/web and Android/Google’s Security Guide at https://source.android.com/security.

Visiting Third-Party Websites

Our Sites may contain links or references to third party websites. These websites are outside of our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over these third-party websites and our Privacy Notice does not apply to such websites. We encourage you to check the terms of use and privacy policies of such sites before disclosing any personal information via such sites.

Occasionally when linking to a third-party website from our Sites, you may still see Dealerware affiliate logo or a Dealerware affiliate website frame. This is to provide you with a seamless experience when visiting our websites. In these cases, you are no longer on our websites but the third-party website, and therefore the information collection practices of the third party’s website may differ from Dealerware’s. The privacy notice of the third party site will govern how information collected from you is used by the owner of the website. You can always know what website you are on by checking the Uniform Resource Locator (URL) in the location bar within your browser.

How We Protect the Security of Personally Identifiable Information

The security of personal information is important to us. We exercise reasonable care in implementing generally accepted standards of security to protect personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction, such as firewalls and Secure Socket Layer (SSL) encryption for some of your more sensitive personal information.

Unfortunately, “perfect security” does not exist on the Internet, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information , we cannot guarantee that personal information stored on our servers, or transmitted to or from a user, will be free from unauthorized access.

You are responsible for maintaining the strict confidentiality of your account passcode, membership numbers and pin numbers, and you will be responsible for any access to or use of our Services by you or any person or entity using a passcode provided to you, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. In the event of the unauthorized use of your passcode, account, or membership number, or any other breach of security involving your information as it pertains to Dealerware, you agree to immediately notify us. It is your sole responsibility to ensure that you exit from your account at the end of each session, control the dissemination and use of your passcode, control access to and use of your account and membership number, and notify us when you desire to cancel your account with our Services. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

It is our policy that we will never request certain sensitive personal information, such as your credit card number, passcode, membership number or pin number, in an e-mail, text or on a website that is not located at the domain name used by Dealerware or an affiliate or is not requested and entered directly through our Retailers. If you receive an e-mail or other correspondence requesting that you provide any such information via e-mail or to a website that is not on such domain name, please do not provide your information, and report such request to our privacy officer at [email protected].

Your Privacy Choices

You may have certain rights and choices regarding our processing of your personal information. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right to:

• Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
• Access a copy of the personal information we retain about you
• Request deletion of your personal informationCorrect or update inaccurate personal information
• Opt-out of sales or sharing of your personal information for cross context behavioral advertising purposes

We reserve the right to verify your identity in connection with any requests regarding personal data to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are a an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

Typically, we will use multi-factor authentication or some equivalent method to verify your identity. Under some circumstances, we may request additional information. For example, if we suspect an access request is fraudulent, we will request additional information in order to verify your identity.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial, provide an explanation of our actions, and the reasons for the denial.

You have the right not to be discriminated against for your privacy choices. We will not restrict or deny you access to our Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Services. For example, if you ask us to delete your license information, you will not be able to rent or drive a Retailer vehicle unless you provide us with your current license information.

If you wish to contact us to access or correct your personal information we have, or to inquire or provide feedback about our privacy practices, you can email us directly

at [email protected] or submit a request via our app.

If you would like to opt-out of cross context behavioral advertising, please click here. Our sites are also equipped to respond to “Do not sell” signals.

Children’s Privacy

Our Services are not directed to children under the age of 18. If you are under the age of 18, then please stop using our Services and do not provide us with personal information of any kind whatsoever. If we learn that we have collected personal information from a child under the age of 18, please contact us at [email protected] and we will endeavor to delete that information.

Data Retention

Dealerware retains data in accordance with its record retention program. The criteria used to determine retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Sites or Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the Site Terms of Use, applicable statutes of limitations, litigation or regulatory investigations). The time periods we use to determine retention are based on the longest period Audi on Demand needs to keep a category of company records that may contain personal information.

International Data Transfers

Our Services our offered by us from the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal data as the one in which you reside. We may need to send your personal information overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected.

Short Code Messaging

Dealerware collects your telephone number only to provide Services such as text messaging mobile contracts to your mobile phone. Dealerware shall safeguard this information with the same standards used to protect personal information. Dealerware will not sell or share your telephone number with any third party not involved in providing the Services.

Changes to this Privacy Notice

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice. If we materially change the way your personal information will be used, we notify you by way of either prominent posting on our Website(s), e-mail and/or mail. We encourage you to periodically review this Privacy Notice in order to keep apprised of any changes.

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