Accessing the Websites and Personal Information Collection

General

This Privacy Policy (“Policy”) covers how DEALERWING LLC (“DEALERWING”) handles information collected and received from or through our websites at Upload.dealerwing.com as well as through associated web applications (collectively, for purposes of this Privacy Policy, the Websites) or otherwise in connection with our provision of services.

Personal information is information about you that identifies you, or others, individually—such as your name, address, e-mail address, or phone number—that might not be publicly available. This Policy does not apply to the practice of entities or people that DEALERWING does not own, control, employ, or manage.

Accessing the Websites and Personal Information Collection

You are required to be signed up with DEALERWING to access the Websites. When you access the Websites without actively providing any personal information we collect limited technical information, such as your IP address. We also use cookies and analytics as described below.

Certain parts of the Websites do require that you provide us with personal information, including that of third parties for which you represent you are authorized to use on the Websites, for access to or use of those parts. For example, if you register to use a portion of the Websites that is password-protected (such as to sign up as an Administrator), you may be required to provide information as described in the “Registration and Forms” section below.

We, like most major websites, use cookies (text files placed on your hard drive by a web server) to help personalize and maximize your experience and time online. Cookies are not used to run programs or deliver viruses to your computer. They are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you. We use cookies to improve the Websites and to facilitate your use of the Websites.

Registration and Forms

Through the Websites you may register to sign up for services as appropriate for your role in the customer services (for example, as an Administrator). These registrations may require you to provide the following on behalf of your customers and/or or your dealership:

Contact information such as name, e-mail address, postal address and phone number
Demographic information such as ZIP Code and date of birth
Information about your dealership, including purchase history
Employment information needed for performance of services using the Website
Payment information to invoice for services purchased

We may use this information to effect transactions or provide services for which the information was provided, to contact you with additional information, and to analyze use of the Websites and services.

Information Related to the Services

Certain types of information will necessarily be generated or shared in the course of DEALERWING’s performance of services for Administrators.

For example, we may collect information from Administrators or other sources concerning dealership customers to provide the Services, and create analyses of related results. Likewise, dealership specific information will not be shared in any direct form with any Administrator of another dealership. Administrators are provided with access to and reports that aggregate numerical and qualitative data solely for their dealership.

Links

The Websites may contain links to other websites. DEALERWING is not responsible for the privacy practices of sites other than our own. We encourage you to be aware of the privacy statements on other websites and to read these statements.

Protection of Information

The Websites are password secured and can only be accessed using unique login credentials. You must have a specific user identifier (user ID) and password to access resources through any password-protected portions of the Websites. Your login credentials and password are for your use only and strictly confidential. You are responsible for maintaining the confidentiality and security of those credentials, and are responsible for all activity occurring on the Websites using your login credentials and password. You are strictly prohibited from any sharing of your login credentials and/or password with any other person(s) and from any use of your login credentials other than for your use of the Websites in compliance with the Terms.

Third-Party Data Collection/Online Tracking

We use service providers such as website analytics providers to help us understand and improve the usage of the Websites and the effectiveness of our marketing efforts. Analytics service; these disclosures are generally built with Google Analytics and like services in mind; additional customized information for these services is available if that service is used may use cookies, your IP address or an anonymous identifier as well as certain information from your browser, together with other non-personal information about your visits to the Websites and other websites, so that we, the analytics service to provide analytical information about our Website. If you would like more information about advertising networks, including choices about the use of information by Analytics company and other companies for multi-site advertising purposes, go to and

Currently, various Internet browsers offer a “do not track” or “DNT” option that uses a DNT header to indicate the DNT preference setting on the browser. DEALERWING does not track your activity over time and across different websites or online services, and thus we do not currently respond to browsers’ DNT signals with respect to the Websites. We do not permit our third-party service providers to collect information from the Websites for other websites or for their own purposes other than as described in this Policy.

Children’s Privacy

We are committed to complying with all applicable laws and regulations regarding the collection, storage, and use of personal information of minors under the age of 18, including the Children’s Online Privacy Protection Act of 1998.

We do not collect personal information from minors under the age of 18. Individuals under the age of 18 are not permitted to use the Websites without the supervision of a parent or legal guardian. We do not knowingly collect or solicit personal information from children under the age of 18 or knowingly allow such persons to register for an online account or to place orders or provide personal information through the Websites. If we learn that someone under the age of 18 has provided any personal information through the Websites, we will remove and permanently delete that information as soon as reasonably possible.

If you are a parent or guardian who believes that your minor, under the age of 18, has submitted personal information or other information to us without your consent, please contact us using the contact information provided below. Once we verify that you are the parent or legal guardian, we will cooperate with you to discuss what, if any, personal information we have collected about your child and how that information may have been shared or used.

Changes to This Statement

DEALERWING reserves the right to change this privacy statement at any time. Notification of changes will be posted on the Websites. Because these changes may affect your personal information, we suggest that you look for information regarding changes on a regular basis and review the changes as soon as they are published on the website.

Disclosures for Compliance with Law

Notwithstanding the provisions of this Privacy Policy or the Terms of Service, information may be and will be disclosed as needed in order to comply with law, respond to facially valid process or subpoena, to stop or mitigate illegal activity or potential harm, to protect the security of information, and to protect against fraud.

Correcting Your Information

We strive to assure the correctness of the information we maintain. If the information we have about you and/or your customer is inaccurate, we will correct the information in a manner as timely as possible. To provide us with corrections, please contact us in any of the following ways:

Send an e-mail message with corrections to .
Send mail with corrections to DEALERWING LLC,1552 Eagle Nest, Winter Springs, FL 32708
Call us at (213)632-8211.

Security

We employ reasonable security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of your information. However, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.

Effective Date: August_, 2016

AM 58289261.1