California & Nevada Privacy Notice

This CALIFORNIA & NEVADA PRIVACY NOTICE supplements the information contained in the Privacy Statement of GVUST, LLC (collectively, “we,” “us,” or “our”) and applies to visitors, users, and others who reside in the United States. We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 and Nevada Senate Bill 220 (an Act relating to Internet privacy) and other California and other state privacy laws (all such laws are collectively referred to for purposes of this Privacy Notice as the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. By using this Site, you acknowledge that you have read and agree to be bound by this Privacy Notice and agree that you are subject to the GVUST Terms of Service and GVUST Privacy Statement.

Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples (Including, but not limited to) or (non- exhaustive list)	Collected (YES or NO)
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A 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.	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin (including language use and possession of a driver’s license issued to persons unable to provide their presence in the United States as authorized under federal law), citizenship, religion or creed (including religious dress and grooming practices), marital status, medical condition (including cancer or a record or history of cancer), AIDS/HIV, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, childbirth, breastfeeding and related medical conditions), sexual orientation, veteran or military status, Political affiliations or activities, status as a victim of domestic violence, assault, or stalking, genetic information (including familial genetic information), request for family care leave, request for leave for an employee’s own serious health condition, request for Pregnancy Disability Leave, retaliation for reporting patient abuse in tax-supported institutions.	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	NO
F. Internet or similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	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.	NO
K. Inferences drawn from personal information	Profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes	YES

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our users when they submit a lead form or other web form on a www.gvust.com site.
• Directly and indirectly from interaction with our website (or an affiliated site). For example, from submissions through our website portal or website usage details (including without limitation IP address, device ID, geolocation data collected automatically).
• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us or from audience segments used for targeted advertising.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• From data aggregators and similar vendors.
• From third-parties that interact with us in connection with the services we perform. For example, from demand-side platforms, data management platforms, ad targeting vendors, and/or attribution partners. For example, we may ingest audience data from third-party data providers to power targeted ad serving. We may also receive aggregated vehicle sales records for analytics and other purposes.
• From anti-fraud and other crime prevention partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to provide a lead to an OEM, car seller or other party, we will use that information and submit as indicated.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you including the powering of products and features used throughout the site.
• To power and maintain saved user accounts.
• For attribution purposes.
• To send promotional materials.
• To provide custom and/or individually-tailored website experiences.
• For ad serving, targeting and retargeting, creation of audience segments, and related OBA (online behavioral advertising) purposes.
• To create inferred search preferences and inclination/intent to purchase certain vehicles or makes/models for improved ad targeting and custom experience implantation.
• For internal operations and site optimization including product development.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To enable anti-fraud and crime prevention efforts.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Where information is provided in connection with employment or employment applications, information may be used in the normal course of employment and the application process.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct 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 is among the assets transferred.
• For additional purposes more fully described in our Privacy Statement.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes more fully discussed in the GVUST Privacy Statement and as described below:

• A. Identifiers — we collect names and other identifiers when consumers submit leads or open accounts
• B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) — we collect names and other identifiers when consumers submit leads or open accounts
• C. Protected classification characteristics under California or federal law — we may collect certain characteristics when submitting a lead to determine eligibility for certain special offers made by car sellers and OEMS (e.g. veteran discount)
• D. Commercial information — we collect this information for attribution purposes
• F. Internet or similar network activity — we collect behavioral information to create custom experiences and targeted messaging
• G. Geolocation data — we collect Geolocation data to create custom experiences and targeted messaging as well as for attribution purposes
• K. Inferences drawn from personal information — we collect inference information to create custom experiences and targeted messaging

Categories of Parties to which we may Disclose Personal Information

We may disclose your personal information for a business purpose to the following categories of third parties:

• Our subsidiaries, parent(s) and affiliates
• Service providers (including without limitation Ad targeting/retargeting vendors, attribution vendors, and HR and other internal operations platform providers)
• Clients and customers
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months we have not sold personal information.

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• – sales, identifying the personal information categories that each category of recipient purchased; and
• – disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech and/or ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Emailing info@gvust.com.

Only you (or a person registered with the Secretary of State of your state of residence that you authorize to act on your behalf) may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us as follows:

• Email: info@gvust.com

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us as provided above.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we reserve the right to deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option (if no preference is indicated we reserve the right to contact you at our discretion). Any disclosures we provide will only cover the 12-month period preceding the receipt date of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Privacy Notice

We reserve the right to update and periodically amend this Privacy Notice at our discretion and at any time. If we make changes to this Privacy Notice, amendments will be posted online and the date of update will be included. Your continued use of GVUST and its affiliated sites after any such update indicates your agreement to the same.