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Introduction

This Privacy Policy describes how, along with our subsidiaries and affiliates (collectively referred to as “ShareVia,” “we,“ “us,” or “our“), ShareVia processes Personal Information when we provide services or when you use our websites, mobile, and other online applications and products and services (collectively, the “ShareVia Sites”). We are committed to ensuring the privacy and integrity of the Personal Information you share with us or we otherwise collect as we provide these Services.  Throughout this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.

Information we collect

Information is gathered from the ShareVia Sites by us, our service providers, advertisers, sponsors and partners.

Information You Provide

We may collect information that you choose to provide on the ShareVia Sites in a variety of ways, such as when you:

1. register for one of our products or services. This information may include your name, address, telephone number, email address, Social Security Number, and credit information;
2. make information available to us via social networking logins, such as Facebook, Instagram, or Twitter;
3. express an interest in buying, selling or trading in a car or products offered by ShareVia;
4. participate in chats, web forums, or other interactive sessions;
5. apply for credit with a dealer or one of our finance partners;
6. provide payment card information for one of our products or services;
7. subscribe to newsletters, access podcasts, or provide feedback; and
8. participate in surveys, sweepstakes or other promotions.

Automated Information

Information regarding your use of the ShareVia Sites may be collected and/or aggregated through the use of automated means. This automatically collected information may include information such as:

1. your IP address, the type of browser and operating system used;
2. date and time you access the ShareVia Sites and pages you visit, and if you linked from or to another website, the address of that website;
3. email you open and links you click on within those email;
4. your ISP or mobile carrier, and the type of handheld or mobile device that you used; and
5. your behavior while using our site, including the time you spend on portions of the site and how you interact with various aspects of the site.

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Data Technologies

1. Various technologies are used to automatically collect information, such as cookies, local shared objects, and web beacons (generally referred to as “Data Technologies”). “Cookies” are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. “Local shared objects,” sometimes known as Flash Cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies. Anonymous advertising identifiers are increasingly being used on mobile devices and otherwise in a manner similar to Cookies. When we refer to Data Technologies, we are including all current and similar future technologies.
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2. One or more Data Technologies may be used on the ShareVia Sites and other websites and mobile applications (that may not be the ShareVia Sites) by us, by another party on our behalf, or by third parties in accordance with their privacy policies. Data Technologies may be used by us and others, on our behalf and on their own behalf, to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications.

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Data Protection Mechanism.

ShareVia is committed to the protection of sensitive data and Personal Information. We employ a variety of security technologies and procedures designed to help protect your Personal Information from unauthorized access, use, or disclosure. This includes measures such as encryption, access controls, secure data storage, and regular security assessments.

Photos and Videos

We may target and track the photos and videos you view on the Sites. You consent to our tracking of your photo and video viewing through the Site or third party social media for up to two years or as permitted by applicable law.

Location Information

When you download or use the ShareVia Sites, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“Location Information”). We only collect Location Information with your permission (e.g., such as when you agree to provide it to us after you initially access or download the ShareVia Sites). We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as advertising, search results, dealers in the area, and direction, to evaluate and improve the ShareVia Sites, or to provide you with content and services relevant to one or more nearby dealers.

Publicly Posted Information

Information that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms or similar functionality is public information that we or others may share or use in accordance with the law.

Combined Information and Information from Other Sources

We may combine information that you provide to us with information we receive from our affiliates and other sources, as well as with other information that is automatically collected. The combined information may include information about your use of the ShareVia Sites, your use of other websites, devices and mobile applications and information from our affiliates and other sources.

How We May Use the Information We Collect

We may use information we collect for the following purposes:

• for everyday business purposes, such as establishing and managing your user account, providing products and services you request, processing and collecting payments and providing customer support;
• to offer our other products or services and/or the products or services of others to you;
• to communicate about, and administer your participation in, special events, programs, surveys, contests, sweepstakes and other offers or promotions;
• to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications and websites;
• to diagnose and address technical and service problems;
• to perform data analyses, including market and Consumer research, trend analysis, demographic analysis and financial analysis;
• to deliver content (including advertising) correlating to your interests and browsing and usage history, both within the ShareVia Sites and on other websites and applications;

• to comply with applicable legal requirements and our policies; and
• to contact you via telephone, text or chat. We will obtain your consent to contact you when and in the manner required by law.

Advertising Networks

1. Advertising that is customized based on predictions generated over time from your visits across different websites, devices and mobile applications is sometimes called “online behavioral” or “interest-based” advertising. We may partner with advertising networks, which are companies that deliver targeted advertisements to Consumers and generate statistics and metrics related to the delivery of interest-based advertisements. They may utilize information collected through a variety of Data Technologies to provide customization, auditing, research and reporting for us, our affiliates and other advertisers. This data collection takes place both on the ShareVia Sites and on third-party’s websites and mobile applications. This process allows ShareVia and third parties to deliver targeted advertising, enhance marketing programs and help track the effectiveness of such efforts. Our advertising networks also may use this information for determining or predicting the characteristics and preferences of their respective advertising audiences and measuring the effectiveness of their advertising in accordance with their privacy policies.

2. We do not provide information that is directly associated with a specific person (such as name and address) to an advertising network when you interact with or view a customized advertisement. However, when you view or interact with an advertisement, the advertiser may make an assumption that you are interested in the subject matter of the advertisement.

3. Some companies disclose when they are using interest-based advertising programs on the ShareVia Sites to deliver third-party ads or collecting information about your visit for these purposes and give you the ability to opt-out of this use of your information. You may see an icon in or around third-party advertisements on the ShareVia Sites that use interest-based advertising programs and on pages where data is collected and used for online interest-based advertising. Clicking on this icon will provide additional information about the companies and data practices that were used to deliver the ad. You can opt out of delivery of targeted advertising to you by multiple companies by visiting www.aboutads.info/choices, www.networkadvertising.org/managing/opt_out.asp  and www.evidon.com. Please note that even if you opt out, you will continue to receive advertisements, but they will not be tailored to your specific interests.

Information We Share

We do not sell or otherwise share Google user data to third parties for advertising or marketing purposes. Any sharing of data is done only with explicit user consent, for the purpose of providing requested services, and under the protection of similar privacy safeguards.

1. Affiliates. We may share information about you, including Personal Information, with our corporate affiliates, who will use it in accordance with their privacy policies.
2. Our Service Providers. We may engage third parties to provide the services offered through or in connection with the ShareVia Sites on our behalf. We require such providers to maintain information about you as confidential and to use the information only to perform the services specified by us in a manner consistent with this Privacy Policy.
3. Co-Sponsored Promotions. In the event that you participate in a survey, sweepstakes, contest or other promotion that is co-sponsored by ShareVia and a third party, we may share information collected in conjunction with the survey, sweepstakes, contest or promotion, including Personal Information, with that third party. After the information is provided to those third parties, the subsequent use or disclosure of such information is subject to their privacy policies and practices. Surveys, sweepstakes and other promotions conducted on behalf of ShareVia and a third party will include branding from both ShareVia and the third party.
4. Promotions on behalf of Third Parties. Periodically, third parties may conduct surveys, contests, sweepstakes and other promotions for their own purpose on the ShareVia Sites. Information you provide in response to those activities is governed by their privacy policies. Surveys, sweepstakes and other promotions conducted solely for the purpose of a third party will include only the third party’s branding.
5. Corporate and Asset Transactions. If we sell all or substantially all of our business or sell or transfer all or a material part of our assets, or are otherwise involved in a merger or transfer of all or a substantial part of our business, we may transfer all information we have collected and stored, including Personal Information, to the party or parties involved in the transaction as part of that transaction.
6. Other. We may access or disclose information, including Personal Information, to:

• protect or defend our interests and the legal rights or property of ShareVia and our affiliates;
• protect the rights, interests, safety and security of users of the ShareVia Sites or members of the public;
• protect against fraud or for risk management purposes; or
• comply with prudent legal practice as we may determine, and applicable law or legal process.

Your Choices

You are entitled to make certain choices about how we communicate with you.

1. You may choose not to provide Personal Information, even though that might impact your ability to register or receive a particular product or service.
2. If you do not want to receive marketing email from us, you can follow the unsubscribe link provided in those emails.
3. If you do not want to receive interest-based advertisements, you can opt out as discussed in the “Advertising Networks” section above.
4. You have a number of choices regarding certain Data Technologies. Most web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. You may also render some web beacons unusable by rejecting their associated cookies and disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or opting out at www.Evidon.com or the website of the technology provider. If you choose to decline Cookies or similar technologies, however, please note that certain features may not function properly or at all as a result. You may be able to adjust the use of advertising identifiers on mobile devices through the settings on your device. Finally, if you do not want to use a uniquely generated telephone number, you may choose to not call us.
5. If you do not want us to use Location Information, you can decline our initial invitation to provide that information, or opt out by changing the location services settings on your mobile device. However, please note that certain features may not function properly or at all as a result if you opt out.
6. Data Retention and Deletion: ShareVia retains user data only as long as necessary to provide the requested services to our users or to comply with our legal obligations. We have implemented measures to ensure the deletion of user data from our records when it is no longer needed for the provision of services or when a user requests deletion of their data. Users can request the deletion of their data by contacting us directly through the provided contact details.

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California Privacy Rights

14. If you are a Consumer receiving products or services for which we are a Business, as those terms and any other capitalized terms in this section are defined under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”), and is effective upon the date that the CCPA enters into operation, California law may permit you to request information regarding the:

1. Categories of Personal Information (as defined by applicable California law) Collected, Sold or Disclosed by us;
2. Purposes for which categories of Personal Information Collected by us are used;
3. Sources of information from which we Collect Personal Information; and
4. Specific pieces of Personal Information we have Collected about you.

In addition, if you are a Consumer you may:

1. Opt-out of the Sale or Disclosure of your Personal Information, in some circumstances;
2. Opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding the Services; and
3. Request deletion of your Personal Information by us and our Service Providers, in some circumstances.

The CCPA also provides Consumers with the right not to receive discriminatory treatment by a Business for the exercise of these rights regarding Personal Information. You can make requests related to your California privacy rights emailing legal@sharevia.com or in writing to ShareVia, 44 Milton Ave, Alpharetta GA 30004.

Disputes

If you choose to visit the ShareVia Sites, your visit and any dispute regarding privacy is subject to this Privacy Policy and our Terms of Service Agreement, including limitations on damages, resolution of disputes, and application of the law of the state of Delaware.

Updates to this Privacy Policy

We may update this Privacy Policy to provide clarification or notice of changes to our practices. If we make changes, we will revise the date at the top of this Privacy Policy. We will provide you with additional notice of material changes by posting notice of the changes for thirty (30) days before we implement those changes.

How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at help@sharevia.com.

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