Privacy Statement

Effective Date: March 13, 2013

This website is brought to you by VinSolutions, Inc. (”VinSolutions,” “we,” “us,” or “our”). We respect the privacy of visitors to our website and that of the visitors to the dealer websites that we host (“Hosted Site(s)”, together with our website, the “Sites”). Please read this Privacy Statement carefully so that you understand what information we collect through the Sites and what we do with that information. This Privacy Statement applies only to information collected online through the Sites and does not describe the ways in which we may collect or use information obtained offline or through any means other than through the Sites. In addition, this Privacy Statement applies only to our use and collection of information on the Sites. Each of the Hosted Sites may include an additional privacy statement that contains additional terms governing the collection and use of your information via the particular Hosted Site. If you have any questions about this Privacy Statement, please contact privacy@vinsolutions.com.

By visiting the Sites, you (“you” or “visitor”) agree that your visit, and any dispute over your privacy or our information collection and disclosure practices, is governed by this Privacy Statement and our Terms of Use (“End User License Agreement” or “EULA”).

THE INFORMATION WE COLLECT

The information we gather generally falls into two categories: (1) information supplied by visitors to the Sites when, for example, inquiring about a product or service offered through the Sites; and (2) tracking information gathered as visitors navigate through the Sites. Once you provide VinSolutions or a Hosted Site with personal information, you are not anonymous to us. Please note that third-party providers (including, but not limited to, vendors of products and services and providers of widgets, tools, and applications) (collectively, “Third-Party Providers”) featured on or linked to by the Sites may also be gathering information through your use of their services. We do not control the information practices of these Third Party Providers and encourage you to review their privacy policies.

Communicating With Us. If you elect to communicate with us through the Sites, we will collect the information, including personal information, you supply through the Sites. We will use this information to respond to your request, to provide the products and/or services you requested, to contact you about our services and about other information, products, and/or services that we believe may be of interest to you. For example, if you complete an online-contact form on a Hosted Site, you may be contacted by the dealer associated with that Hosted Site in response to your inquiry. We also may use this information in conjunction with information we collect to track activity, analyze usage, and improve our products, services, features and content of the Sites, as well as for marketing and promotional efforts.

We may provide a trackable toll-free telephone number for many of the listings that appear on a Hosted Site. This toll-free telephone number may be used to contact the dealer about a particular advertised vehicle. If you call a listing using one of these toll-free numbers, we (or a service provider acting on our behalf) may collect the date, time, and duration of your call, as well as the number from which your call originated and an audio recording of your call.

If you use a Hosted Site’s live chat feature to ask questions about a vehicle, the service provider that manages this feature may send a copy of your chat transcript to us. The chat service provider collects and uses chat transcripts in accordance with its own privacy policy which may be accessible via a link shown during the chat session. If you do not want this information to be shared with us, do not use the chat service.

To help them monitor and improve dealer performance, we may also provide vehicle manufacturers with the information you send via a Hosted Site using the online contact form. If you do not wish to share your email address or other contact information in this manner, you should not use the online contact form.

We collect personal information from you, such as your name, address, phone number, e-mail address, and date of birth when you provide it to us in connection with a service on the Sites, such as when you request a trade-in valuation, use a “contact us” form, and/or register to use the Sites. If you use a Hosted Site to apply for credit for a car loan or refinancing, we and the Hosted Site will collect personal information from you. This information may include, but is not limited to, your name, email address, date of birth, Social Security Number, address, credit history, and/or credit score. VinSolutions, on behalf of a Hosted Site, may transmit such personal information to third parties for the purpose of obtaining additional information about you, your credit history, and/or credit score, combine the information we obtain from these third parties with the personal information you provided; and/or store the information.

If you provide your email address to us, we may email you about the Sites or services, or to inquire about your experience using the Sites. From time to time, we will also send you emails that may include special promotions and other commercial offers that we think may be of interest to you. Though we hope you will find these communications informative and useful, if you do not, you can always unsubscribe from our commercial emails by following the simple instructions included in each email. If you provide a Hosted Site with your email address, please see the Hosted Site’s privacy statement for more information on its email practices.

When you use one of the social network sharing tools available on the Sites, we and the social network operating the tool may collect information about you based on such use. The social network’s use of that information will be subject to its own privacy policy, which may be different from this Privacy Statement.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

Cookies To help us tailor the Sites, and the tools and applications on each Site, to the needs and interests of visitors, we keep track of visitor interactions with the Sites through the use of “cookies.” Cookies are small text files stored on your web browser when you use websites and applications. The “Help” function on most web browsers contains information on how to set your browser to notify you before accepting a cookie or to disable cookies entirely. However, if you do not accept cookies, you will not be able to take advantage of some features on the Sites that are available to other visitors.

We use cookies to improve the visitor experience on the Sites by making them more responsive to the needs of visitors, and to make it easier for us to recognize you when you return. Cookies cannot read unrelated data off your computer.

Web Beacons To help us (and in some cases our advertisers and Third-Party Providers) keep track of how many visitors are accessing particular pages and listings within the Sites, and to track how visitors respond to ads we place on third-party websites, we may place a small file, called a web beacon, on some pages of the Sites and on ads we distribute. We may also place a web beacon in the emails we send to you. When you open one of our emails or click on links within these emails, we track this click-through data to help us determine your interest in particular topics and measure the effectiveness of our communications to you. If you prefer not to be tracked in this way, you should not open these emails or click text or graphic links in the emails. You also may unsubscribe from our commercial emails by following the simple instructions included in our emails.

Browser Level Information Our web server (and/or any web server operated by our service provider(s) on our behalf) automatically collects and may store some limited information about your computer configuration when you visit the Sites, including the type of browser software you use, the operating system you are running, the resolution of your computer monitor, the website that referred you, and your IP address. Your IP address is a numerical address that is used by computers connected to the Internet to identify your computer so that data (such as the web pages you want to view) can be transmitted to you. We also use IP address information for systems administration (including fraud detection and prevention) and troubleshooting purposes. We may also collect information about the website you were visiting before you came to the Sites and the website you visit after you leave the Sites.

Use of Data Collection Technologies Cookies, beacons, browser level information and other data collection technologies may be used individually or in combination in order to provide and/or administer our services, to help us understand visitor behavior, to monitor site performance, optimize ads, and measure advertising performance.

We may collect, or have a third party collect on our behalf, aggregated statistical information about how visitors use and navigate around the Sites, such as the number of visitors who visit various pages within the Sites, what they click on, whether they scroll up or down on particular pages, fill out forms, etc. We use this information to improve the Sites. We may also disclose this aggregated information to third parties.

Data Collected in Connection with Ad Serving and Targeting

We (or a service provider acting on our behalf) have relationships with certain third-party advertising networks and advertising services ("Advertising Services") that collect data, target and serve some of the advertisements, promotions, or other marketing messages you see on the Sites and other websites and mobile applications, including the sites owned and/or operated by our affiliates. Our Third-Party Providers and the Advertising Services we use may, through processes that we do not control, assign cookies or use web beacons or browser level information to collect clickstream data from your activities on the Sites and other websites, including the websites of our affiliates. Their use of this data is subject to their own privacy policies, which may be different from this Privacy Statement.

We (or a service provider acting on our behalf), our Advertising Services, our advertisers, and/or our Third-Party Providers may use clickstream data collected using cookies, beacons, and/or browser level information to, among other things, help tailor the content of advertising, marketing, and promotional messages (including, but not limited to, landing pages) on the Sites to the perceived interests of our visitors.

VinSolutions and our Hosted Sites support the Self-Regulatory Principles for Online Behavioral Advertising from the Digital Advertising Alliance, which regulates the practices relating to the collection of clickstream data. To opt out of interest-based advertising programs or to learn more about these data collection practices, please visit http://www.aboutads.info or http://www.evidon.com. Pages of a Hosted Site that collect information that may be used by such advertising partners for interest-based advertising purposes are identified by a link to AdChoices on the page.

USE AND DISCLOSURE OF INFORMATION

When we use other companies to help us operate the Sites or improve the services offered to you, we may provide them with information about visitors that is necessary for them to perform their services. We require that these companies commit to use the information only to perform the services that we request.

If you click on a third-party link, including a social media graphic link on the Sites, you will be taken to the third party’s Web site, and your information will be subject to the third party’s privacy policy.

In some cases, to provide you with a customized experience and/or enhance our services, we (or service providers acting on our behalf) may combine information (including personal information) that we collect through the Sites with information about you and/or your computer from other sources, including offline interactions with us, public databases, and third parties.

In addition, VinSolutions may track, share and combine visitor information and behavior among our affiliated companies within AutoTrader Group, Inc. so that such affiliated companies may provide you with information, products, and services that VinSolutions and/or AutoTrader Group, Inc. believe may be of interest to you.

OTHER DISCLOSURES

We may release or use information about our visitors when appropriate to comply with laws; enforce our Visitor Agreement; or protect the rights, property or safety of visitors to the Sites, our customers, the public or VinSolutions. As our business grows, we may buy or sell various assets. In the unlikely event that VinSolutions, one of its business units, or substantially all of its assets is acquired by another company, information about our visitors would be among the transferred assets.

SECURITY

VinSolutions takes commercially reasonable steps to ensure information we gather from the Sites is stored in a secure manner. While we work hard to protect your privacy, no physical or electronic security system is impenetrable, or invulnerable to attack, including your own, and the ones used to transmit your data to us. We cannot and do not guarantee that our systems, or your information, will be secure.

INTERNATIONAL VISITORS

The Sites are intended for use by visitors within the United States. If you reside outside the United States, please be aware that (i) our databases are stored on servers and storage devices located in the United States, (ii) your information (including personal data) may be transferred to the United States for processing and storage, and (iii) the United States, and the localities within the United States where our databases are located, may not guarantee the same level of protection for personal data as the locality or country in which you reside. By using the Sites, you expressly agree to our collection, use, disclosure, and transfer of your information (including personal data) for the purposes identified herein, and you consent to the transfer of such information outside of your country.

PROTECTING THE PRIVACY OF CHILDREN

The Sites are not directed at or intended for children under 13 and we will not knowingly allow anyone under 13 to provide us any personally identifying information; if you are under 13, please do not provide any information about yourself on the Sites.

CHANGES TO THIS PRIVACY STATEMENT

If we need to change our privacy policy at some point in the future, we will post the revised Privacy Statement on our website together with an updated reference to its Effective Date to reflect the date of the amendment. Your continued use of the Sites following the posting of such a revised Privacy Statement will be deemed to constitute your consent to its terms.