PRIVACY POLICY

Last Updated and Effective: October 2023

automotiveMastermind Inc. (“aM”) is a software as a service digital marketing company that provides, among other things, an online platform for predicting consumer purchasing behavior for marketing and advertising purposes. The full range of aM’s services (the “Services”) shall be as defined in aM’s Terms of Service (Public) or at such other web address as may be notified to you from time to time.

Any terms capitalized but not defined herein shall have the meanings ascribed to them elsewhere in the Terms of Service (Public).

aM provides this Privacy Policy to inform you of aM’s policies and procedures related to the collection, use and disclosure of your information. This Privacy Policy may be updated from time to time. If we make material changes to this Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice or sending you a notification. You are advised to consult this Privacy Policy regularly for any changes. We will note the effective date of the latest version of our Privacy Policy at the beginning of this Privacy Policy.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within aM’s organization or among its affiliates within the United States or internationally.

PERSONAL INFORMATION WE COLLECT

“Personal information” is any information that can be used to identify an individual or device, and may include things such as your name, physical address, email address, phone number, login information, marketing preferences, company affiliation, geographic location, or payment card information. aM may also collect other information that you provide as part of your use of the Services (e.g., without limitation, zip code and individual preferences) (“Non-Identifying Information”).

 

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information.

We collect information about you in a variety of ways depending on how you interact with us and our Services, including:

• Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, or contact us by phone, email, or otherwise.
• Automatically through the use of cookies, server logs, and other similar technologies when you interact with our Services.
• From other sources, including, for example, our affiliates, business partners, service providers, and other third parties, or from publicly available sources.

The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

 

Context	Types of Information	Primary Purpose for Collection and Use of Information
Account Registration	We collect your name and contact information when you create an account to access or use the Services. We also collect information relating to the actions that you perform while logged into your account.	We have a business interest in providing account related functionalities to our users.
Customer Information	We collect the name, and contact information, of our customers and their employees with whom we may interact.	We have a business interest in contacting our customers and communicating with them concerning normal business administration such as projects, services, and billing.
Cookies and Similar Tracking Technologies	We use cookies and similar tracking technologies on our websites to collect certain information. For more information, please refer to the “Cookies” section below.	We use cookies to optimize the experience for our users, ensure that certain parts of the website work properly, and for personalized advertising.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.	We have a business interest in understanding how you interact with our communications to you.
Support	If you contact us for support, we will collect your name, email address, phone as well as any other content that you send to us, in order to reply.	We have a business interest in receiving, and acting upon, your feedback or issues.
Newsletter and Mailings	When you sign up to receive our industry trends and insights newsletter, or other mailing lists, we collect your email address.	We share information about our products and services with individuals that consent to receive such information. We also have a business interest in sharing information about our products or services.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a business interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a business interest in detecting and preventing fraud.
Server logs	When you visit the Services, aM’s servers automatically record information that your browser sends (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you visited before you came to the Services, pages of the Site that you visit, the time spent on those pages, information you searched for on the Site, access times and dates, and other statistics.	We have a business interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our Services is the most popular.

PURPOSE AND USE OF PERSONAL INFORMATION

aM may use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) for operational, legal, administrative, and other legitimate purposes permitted by applicable law. Some of the ways we may use Personal Information include:

• Providing the Services.
• Administering your inquiries.
• Providing you with requested products or services.
• Providing you with information regarding similar products or events.
• Analyzing and monitoring extent of use.
• Providing customized product and service information.
• Allowing you to participate voluntarily in mailings or other events.
• Providing product service updates, information, and alerts.
• Sending communications, including for marketing or other customer satisfaction purposes.
• Order processing and to provide transaction documents.
• To contact you for information verification purposes.
• Analyzing and monitoring extent of use and enhancing aM’s Platform.

aM may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how the Services are used. aM may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

aM also uses your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, you should follow the unsubscribe instructions provided in any of the communications or submit your request by completing the form on our Privacy Request Page.

YOUR RIGHTS

We strive to make sure that our information is reliable, accurate, and up-to-date. While personal information is maintained by aM, individuals in certain jurisdictions will have rights over how their personal information is processed. To find out what rights apply in your jurisdiction, please visit the ‘Additional Information for Certain Jurisdictions’ section below.

To make a request regarding your personal information, please complete the form found on our Privacy Request Page.

Below is a brief description of rights that may apply to you:

Right to information and access

In some circumstances and subject to certain exceptions, you may have the right to access and request information about the processing of your information. Information typically requested includes:

• The categories or specific types of personal information we have collected.
• The business purpose for collecting, disclosing, and/or selling the information.
• The sources from which personal information was collected.
• The categories of third parties with whom we share personal information.
• Specific pieces of information we have about you.

Right to deletion

In some circumstances and subject to certain exceptions, you may have the right to ask us to delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.

Right to data portability

In some circumstances, you may be able to request copies of your information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit this information to another entity without hindrance.

Right to correction

You may have the right to ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.

Right to Opt Out of  the sale of your personal information

You may have the right to direct us not to sell your personal information.

Right to Opt Out of targeted advertising

You may have the right to direct us not to share your personal information for purposes of cross-context behavioral advertising (also referred to as targeted advertising).

Right to nondiscrimination

You may have the right to not be treated differently for exercising your rights.

Upon receipt of a valid request made through our Privacy Request Page, we will take the necessary steps to assess and respond.

Please be aware that in order to accommodate some requests we must verify your identity before we can respond to a privacy request and this may require you to provide photographic identity information to aM. Because your personal information—for example, your email address—is often required to access or use aM platforms and technologies, we retain personal information as long as your account is active. You may have the opportunity to correct, update, or modify this information by logging into your account and updating your information online. Please note that some information may be retained on our systems, where permitted by law, even after you request deletion.

SHARING PERSONAL INFORMATION

To support the purposes described in this Privacy Policy, aM may share or disclose personal information to:

• aM’s parent, subsidiary, affiliates, and other related companies for the purposes listed above (Purpose and Use of Personal Information);
• The organization that arranges your access to our products or services (if that is not you) to fulfill its contractual obligations and to provide our products and services;
• Service providers and business partners for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law or otherwise with your consent.

Personal information handled by these service providers is subject to their terms of use and privacy policies. Please review the service provider’s terms of use and privacy policies to better understand how they manage your personal information.

There may also be instances when aM may disclose your personal information without providing you with a choice in order to:

• honor a request that you have made through the products or services;
• comply with the law or in response to a court order, government request, or other legal process;
• protect the interests, rights, safety, or property of aM or others;
• protect against fraud or for risk management purposes; or
• respond to adverse third parties (i.e., adverse parties and their counsel and other agents) in the context of litigation.

In addition, if aM sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, you acknowledge that IHS Markit may transfer your personal information to a third party as part of that transaction.

We may also ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

In all cases aM requires all unaffiliated third parties to treat personal information as confidential. aM will not provide personal information to third parties for their own marketing purposes without your consent.

If you participate in a discussion forum, chat room, or provide comments related to aM on a social media or other public platform, you should be aware that the information you provide there (i.e., your public profile) will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither aM nor you have control over. Also, please recognize that social media forums and chat rooms not controlled by aM may have additional rules and conditions. aM is not responsible for the personal information or any other information you choose to submit on these forums that are not aM controlled.

The Platform may offer you the ability to share personal information through a social networking site (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.

AGGREGATE INFORMATION AND NON-IDENTIFYING INFORMATION.

aM may share aggregated information that does not include Personal Information and aM may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated and Non-Identifying information shared in these contexts will not contain your Personal Information.

To the extent we maintain and use Personal Information in a de-identified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.

COOKIES

Like many websites, aM uses “cookies” and similar tracking technologies to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. aM uses cookies for two purposes. First, aM utilizes persistent cookies to save your login information for future logins to the Services. Second, aM utilizes session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by you and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser.

We may also place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites.

We do not currently recognize the “Do Not Track” signal.

PHISHING

Identity theft and the practice currently known as “phishing” are of great concern to aM. Safeguarding information to help protect you from identity theft is a top priority. aM does not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

aM cooperates with government and law enforcement officials and private parties to enforce and comply with the law. aM will disclose any information about you to government or law enforcement officials or private parties as aM, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity aM may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

SECURITY

aM has physical, administrative, and technical safeguards in place to help protect the personal information aM collects. While there is no such thing as perfect security on the Internet, we will take reasonable and appropriate steps to ensure the safety of your personal information.

In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

RETENTION OF PERSONAL INFORMATION

aM will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. For example, your email address is often required to access or use aM platforms and technologies, so we retain this personal information as long as your account is active. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS

California

For the purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.

Your rights

In some circumstances and subject to certain exceptions, California residents have the right to information and access; deletion; data portability; correction; object to the sale of your information; opt-out of targeted advertisings; and the right to nondiscrimination.

You or your authorized agent may exercise your access, deletion, data portability, and correction rights through the Privacy Request Page or by dialing toll-free 1-800-801-0018. If you are an authorized agent, you must include signed authorization from the individual giving you permission to submit the request on their behalf.

You or your authorized agent may opt-out of the sale of your personal information, by visiting the California Do Not Sell My Personal Information Request Page. You may opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the “Do Not Share” link on our homepage. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference. [You may also opt-out of other forms of targeted advertising by submitting a request as described above.] We also recognize Global Privacy Control (GPC) signals and other user-enabled opt-out preference signals as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. To learn more about the GPC, you can visit its website here.

In order to accommodate a request from an authorized agent, we may require (i) your signed authorization for the authorized agent to submit the request on your behalf; (ii) you to verify your identity; and/or (iii) you to confirm that you have provided permission for the authorized agent to submit the request on your behalf.

Categories of Personal Information Collected and Third Parties with Whom Personal Information Is Shared Within the Last 12 Months:

The table below describes the categories of personal information we collect, disclose for a business purpose, “sell” and/or “share” (as those terms are defined by California law). Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not knowingly sell personal information about children under 16.

Category	Category Description	Collected	Disclosures for a Business Purpose	Sharing for Cross-Context Behavioral Advertising	Sales
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, national identification number (including SSN), driver’s license number, passport number, or other similar identifiers.	✔	Affiliates or subsidiaries Business partners Data analytics providers Data brokers Internet service providers Joint marketing partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms Social networks	·    Advertising networks	·    Business partners ·    Data analytics providers ·    Data brokers ·    Advertising networks
Protected classification characteristics.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	✔
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories, or tendencies.	✔
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	X	N/A	N/A	N/A
Internet or similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	✔
Geolocation data.	Specific physical location or movements.	X	N/A	N/A	N/A
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	X	N/A	N/A	N/A
Professional or employment-related information.	Current or past job history or performance evaluations.	✔
Non-public education information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	X	N/A	N/A	N/A
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	✔
Other	Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e), such as name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	✔

Categories of Sensitive Personal Information Collected

We collect the following categories of sensitive personal information (as defined under California law):  Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.  This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services.  Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121.  We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

LINKS TO OTHER SITES

aM’s Services contain links to other websites. If you choose to visit a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of aM’s affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. aM does not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. aM encourages you to read the privacy policies or statements of the other websites you visit.

OUR POLICY TOWARD CHILDREN

The Services are not directed to persons under 18. aM does not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact aM at info@am-home-wordpress.automotivemastermind.com. If aM becomes aware that a child under 13 has provided it with Personal Information, aM will delete such information from its files.

CONTACTING US

If you have any questions about this Privacy Policy, or if you need to access this Privacy Policy in an alternative format due to having a disability, you should contact aM at:

55 Water Street, 44th Floor

New York, NY 10041

OR

Email: info@automotivemastermind.com