PRIVACY POLICY

INTRODUCTION

Welcome! Digital Lead Performance LLC DBA LeadHelm (“LeadHelm”, “Company”, “We” or “Us”) respects your privacy and we are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our website https://leadhelm.com, and our other related mobile application, mobile websites, services, tools and other applications (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

DEFINITIONS

• “Account” means an account that a User creates on the Website or App through other means in order to register for use of Services.
• “App” means our mobile application in which you may access the Services and Site.
• “Calls” means dialing a Customer’s phone number to speak to them by phone.
• “Customer” means a customer of a Dealer who requests or provides specific information on motor vehicles or motorcycles in connection with potential Product Sales.
• “Customer Data” means information relating to a Customer, including personally identifiable information of such Customer and Customer Messages.
• “Customer Messages” means audio recordings of Customer phone calls, either live or voice messages, to Dealers with respect to potential Product Sales.
• “Dealer” means a User who uses the Services on behalf of a motor vehicle or motorcycle dealership, company, organization or entity.
• “Dealer Data” means any information Dealer may upload or provide to the Company through the Services, including, but not limited to, Customer Data.
• “Product Sales” means motor vehicle and motorcycle sales and purchases.
• "Services" means all of our related data, our proprietary software, content and related documentation and information, products and services and any other features, technologies and/or functionalities offered by use on the Website, App or through any other means in connection with the collecting, providing and processing of digital leads with respect to Product Sales.

SCOPE AND CONSENT

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through the App or through use of the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy and you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at StayConnected@leadhelm.com.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Website and Services, including personal information, which may include name, address, phone number, email address, and financial information, as well as information about your internet connection, the equipment you use to access our Website and usage details.

We collect this information directly from you when you provide it to us as well as automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us When Visiting the Website. The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website, such as name, email and business name. This includes information provided when subscribing to our newsletter or requesting further services or information. We may also ask you for information when you report a problem with our Website.
• Information that you provide by filling in forms on our Website, such as name, email and business name. This includes information provided when subscribing to our newsletter or requesting further services or information. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

Information You Provided by a Dealer and its Authorized Users and Dealer Data. The information we collect when a Dealer becomes a User of the Services which includes:

• The Dealer’s and its authorized users’ names, contact information, username and email address.
• Any other information the Dealer may upload or provide to Us through the Services.

The Dealer’s Customer Data. The information we collect through the provision of the Services, including:

• Customer Data;
• Customer Messages;
• Dealer Data.

Financial Information. We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third-party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.

User Contributions. You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website. Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Mobile Information. We may collect additional information from you if you access our Website through a mobile device (e.g., your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location).

Information We Collect Through Automatic Data Collection Technologies When you visit the Website, we may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our Website, for when you later return to the Website. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Geo-location information to provide certain location-based services that you request.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Recognize you when you return to our Website.
• For more information, see How We Use Cookies and Tracking Technologies below.

HOW WE USE AND RETAIN YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide the Services to Dealers;
• To provide you with information that you request from us.
• To provide you with notices about your account or registration.
• To personalize your experience by providing content on the Website.
• To improve the Website.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We use aggregate information about our users and non-personal information to analyze Website and user behavior and prepare aggregated reports.

We use information from the Website to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms and Conditions.

When you access the website on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy. For example, we may use this information to provide you with location-based services, such as advertising, search results and other personalized content.

We retain information as long as it is necessary and relevant for our operations.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, such as RingCentral, which receives Customer Messages.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms and Conditions.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at StayConnected@LeadHelm.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. 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.

We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms and Conditions, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent re-registration.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms and Conditions.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

HOW WE USE COOKIES AND TRACKING TECHNOLOGIES

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):

• We offer certain features that are available only through the use of tracking technologies.
• We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Website. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
• With your prior consent as obtained through your use of this Website.
• We encode and protect the tracking technologies that we set, so that only we can interpret the information stored in them.
• We may target and track any videos you view on the Website. You consent to our tracking of your video viewing through the Website for up to one year or as permitted by applicable law or until consent is withdrawn.

The following table sets out details of the individual tracking technologies we use and the purposes for which we use them. We provide the chart below as a courtesy for all users but we are not obligated to maintain or update it. We are not responsible for third-party sites and their privacy practices as it relates to opt-outs from tracking activities. The following third-parties that collect information from you on our Website have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities.

YOUR STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, see the below notice.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please send an email to StayConnected@leadhelm.com. To appeal a decision regarding a consumer rights request please send an email to StayConnected@leadhelm.com with the subject heading "Notice of Appeal of Decision."

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated email address: StayConnected@leadhelm.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Notice to California Residents

   Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to StayConnected@leadhelm.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

   How We Respond to Do Not Track Signals for California Residents

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

DATA SECURITY

We store and process your information on our servers located in the United States.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls.

It is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third parties.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Address: 12730 Commonwealth Drive, Suite 2, Fort Myers, FL 33913

Email: StayConnected@leadhelm.com