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TRUECAR TERMS OF PRIVACY

CONTACT
 * TrueCar, Inc.
 * 1401 Ocean Avenue, Suite 200
 * Santa Monica, CA 90401
 * 1-888-TRUECAR

This Privacy Notice has recently changed.
Please read below to understand your rights and how we use the information we
gather

Effective Date: 11/11/2022.

This Privacy Notice (“Notice”) applies to this website or mobile application and
the websites or mobile applications of TrueCar, Inc., and its subsidiaries and
affiliates (collectively “we”, “us” or “our”) that display this Notice (each a
“Site” and collectively, the “Sites”). By visiting the Sites, you are consenting
to our collection, use, disclosure, retention, and protection of information
about you and devices you use as described in this Notice.

This Notice only applies to the Sites and does not apply to information
collected or received by other means.

Our Sites are not directed to children under the age of 18. We do not knowingly
collect personal information from children under age 18. This Notice does not
apply to anonymized or aggregated data that does not allow us or third parties
to identify or contact you.

1. What Information Does TrueCar Gather?
Information You Give Us. We may collect and retain any information from you or
your devices provided to us when you visit a Site, including when you:

 * use our service or mobile application;
 * register for an account;
 * apply for financing with one of our lending partners;
 * communicate with us, such as to provide feedback, request support, or ask for
   additional information; and
 * subscribe to content we offer, such as newsletters, alerts, etc.

We may collect information such as your first and last name, home or other
physical address, email address, zip code, telephone number, your automobile’s
make, model, trim, model year, mileage, color, options, vehicle identification
number (“VIN”), license plate number, or information about your interactions
with us or others, and other information. If you request your credit score
through TrueCar, we may collect your social security number, income information,
and your credit score to personalize your preferred auto financing terms from
our lending partners. We may also collect a temporary copy of your driver’s
license and photo of you to securely verify your identity and prevent fraud
through our service provider, Persona. This information is not retained by
TrueCar. Persona may collect biometric information, including a scan of your
facial geometry based on the photos you provide. Please see Persona’s Privacy
Policy for how Persona treats scans of facial geometry extracted from photos.

When you apply to see if you may either pre-qualify or receive a lending/lease
offer for auto financing through one of our participating lending institutions,
that participating lending institution may require you to provide additional
information to determine your eligibility (in the case of a pre-qualification)
or finalize your eligibility (in the case of a lending or lease offer), such as
date of birth, social security number, residential history and employment
history. This information is not captured or retained by TrueCar. Please refer
to that participating lending institution’s privacy policies to learn more about
their data practices.

Social Media. You may use social networks or other online services to access our
Sites. When you do so, information from those services may be made available to
us. By associating a social network account with our Sites, you agree that we
may access and retain that information in accordance with the policies of the
social network or other online service and this Notice. For example, we may be
able to access account or profile information that you have provided to the
social network or information about your interactions with the social network to
make information available to us (such as when commenting on a blog post or
using a sign-on service, such as Facebook Connect).

Automatically Collected Information. We may collect information automatically
when you visit our Sites or use our mobile applications, such as:

 * your IP address; the type of browser, devices and operating systems you use;
 * identifiers associated with the device(s) you use to access our Sites;
 * the pages you visit, vehicles you view or configure, and the features you
   use, including dates and times;
 * if you navigated from or navigate to another website, the address of that
   website; and
 * information regarding your internet service provider.

In addition, we may collect information about your activities on our Sites via
first and third-party cookies, clear GIFs or web beacons, session logging,
heatmaps and scrolls, or through other identifiers or technologies, including
similar technologies as they may evolve over time. We refer to these
technologies collectively as Metrics Tools.

We may allow third parties to use Metrics Tools on our Sites. The information
collected by Metrics Tools may be shared with and used by us, by others acting
on our behalf, or by third parties subject to their own privacy policies.
Information collected by Metrics Tools may be used on this Site or on other
websites or services, including those that may not be operated by us.

Email. We may collect information regarding the effectiveness of our email and
other communications with you. For example, we may know if you follow a link in
an email we send to you.

Mobile. We may collect session and geolocation information from your mobile
device. Geolocation information includes data such as your device’s physical
location and may include GPS-based, WiFi-based or cell-based location
information.

Information from Other Sources. We may obtain information about you from
affiliates, partners, automobile dealers and other third parties. This
information may include information about your use of this Site or our services,
your use of other websites, your interactions with or purchases from automobile
dealers, lending institutions and insurance providers, your interests and
preferences and other information about you or your household. We may combine
the information we obtain from third parties with information that we or our
affiliates have collected about you.

2. How Does TrueCar Use Information About Me?
We and others acting on our behalf may use the information that we collect or
receive to operate our business, including our Sites, as described below:

Operate and Support our Sites and Services. We use the information that we
gather in order to operate our Sites and our services. For example, we may use
the information that we collect or receive to provide support and assistance
that you request or to diagnose or address technical problems in the operation
of our Sites or any of our services. If you establish an account with us, we may
use information about you to manage or support your account. We may identify
your use of our Sites across devices, and we may use information we collect from
you and receive from others to optimize your use of the Sites and our services
as you use different devices.

Improving and Evolving our Services. We constantly evaluate and improve our
Sites and services, including developing new products or services and use the
information we gather to do so.

To Allow You to Connect with Dealers and Vehicle Manufacturers. When you use our
service, and after you provide your contact information to request offers or
information, we may use the information you provide us to connect you with a
limited number of automobile dealers and vehicle manufacturers and/or
personalize your preferred auto financing terms. These dealers and vehicle
manufacturers may provide you with a savings certificate, offers and/or
incentives for new or used vehicles or other products or services. When you
choose to share your contact information with dealers (i.e., providing your
mobile phone for texts instead of using our text masking service), your direct
interactions with those dealers will not be controlled by this Notice. You
should review the applicable notices of those dealers to understand how they may
use your information.

To Allow You to Connect with Credit Bureaus and Lending Institutions. Our Sites
and services may permit you to provide information relevant to assessing your
creditworthiness or designed to facilitate financing (for example, in connection
a potential vehicle lease or purchase). Your direct interactions with credit
bureaus and lending institutions will not be controlled by this Notice. You
should review the applicable notices of those lending institutions to understand
how they may use your information.

To Allow You to Connect with Insurance Providers. Our Sites and services may
permit you to provide your contact information to request a free insurance quote
from a limited number of insurance providers (in connection with a potential
vehicle lease or purchase). Your direct interactions with insurance providers
will not be controlled by this Notice. You should review the applicable notices
of those insurance providers to understand how they may use your information.

Advertising and Promotions. We may use the information we gather to offer,
provide, or personalize products and services from us and third parties. For
example, we may customize content, advertising, promotions and incentives to
reflect your preferences, interests, or prior interactions with us and others.

Other Contacts. We may contact you through telephone, text, or chat for other
purposes, as permitted by law.

This Notice only addresses our own information practices. This Notice does not
apply to information you share with third parties, including but not limited to
dealers, lending institutions and insurance providers, even if we link to those
third parties from a Site. These third parties may have their own privacy
policies governing their use of information that you can access from their
websites. Our services may be offered through third party websites or mobile
applications (“Partner Sites”). This Notice does not apply to Partner Sites,
unless otherwise indicated on the Partner Site.

Please note that other parties may collect personally identifiable information
about your online activities over time and across different websites when you
use our Site.

TrueCar may use Plaid Inc. (“Plaid”) to verify your bank membership status with
one of our finance partners so you can take advantage of certain special offers.
Information shared with Plaid is treated by Plaid in accordance with the Plaid
end user privacy policy.

3. When Does TrueCar Share Information?
We only share information about you as described or permitted by this Notice,
unless you consent to other sharing. We may share information about you in the
following ways:

Corporate Affiliates. We may share information with our corporate affiliates for
their everyday business purposes, to provide services or to perform marketing.
We may also participate in joint ventures with others and we may share
information as part of that joint venture.

Partner Sites. We may share the information we gather with Partner Sites (and
the owners of those sites). For example, we may share information for
determining or verifying our economic rights and obligations.

Service Providers. We may share information with third party service providers
who help us operate our business or provide services on our behalf, including
third parties who help us operate our Sites. These service providers include
analytics companies, communication providers and advertising networks that
provide Metrics Tools on our Sites.

Promotional. We may share information with third parties to help us promote our
products and services, or to help us customize advertisements, offers, or other
communications to you.

Automobile Dealers and Vehicle Manufacturers. We may share information with
automobile dealers, manufacturers and other providers of automobile related
products and services. For example, we may share information with our
participating dealers to personalize your preferred auto financing terms, allow
you to communicate with them, and them to communicate with you when you elect to
share your information with them.

Lending Institutions. Our Sites and services may permit you to provide
information relevant to assessing your creditworthiness or facilitating
conditional pre-qualification for auto financing in connection with a potential
vehicle lease or purchase.

Business Transfer. We may share information we have collected from you in
connection with the sale or merger of our business or the transfer of assets.

Protection of Ourselves and Others. We may use and share the information we
gather to enforce our rights and protect our property and those of our
affiliates, customers and members of the public, to comply with applicable law,
legal process, legal advice and for preventing fraud, theft, and injury to you,
us or others.

Customer Comments, Reviews and Testimonials. We may publish or use customer
comments, reviews or testimonials on our Site or in other advertising
accompanied by attribution, including your name and other information that we
deem relevant to the statement, such as your geographic location. If you do not
wish your reviews, feedback or testimonials to be used in that matter, contact
privacy@truecar.com.

4. What Choices Do I Have Regarding My Information?
You may limit and control the information provided to us in several ways. You
may not be able to use all features of our Sites if you limit the information
you share with us.

For example, you can choose not to access our Sites through your social media
account. You may also be able to limit the information provided to us by third
party social media providers by altering your privacy settings with those
providers. You may unsubscribe from promotional emails from us by following the
unsubscribe link included in each such email.

Your browser and your device may provide you the option to limit the use of
cookies or other Metrics Tools. You should consult documentation for your
browser or device for more information. Your mobile device may have settings
that allow you to prevent sharing geolocation information with us. You should
consult your mobile device’s settings or help documentation for more information
about exercising these options.

TrueCar uses Google Analytics and related products, which help TrueCar better
understand its audience and target communications and advertisements based on
demographic or interest-based information. Google is subject to its own privacy
policy. To learn more about Google’s data collection and security practices, we
encourage you to review its privacy policy. You may learn more about opting out
of certain Google advertising initiatives here and here. You may also be able to
opt out of certain targeted behavioral advertising via the Network Advertising
Initiative’s opt-out.

Please note that you may still receive advertising even after opting out, but
that advertising may not be tailored to you or your interests.

5. How Can I Access and Update My Information?
If you are a registered user on truecar.com, you may access, update and change
certain information we have collected about you by accessing the “My Account”
tab after signing into your account on www.truecar.com.

6. How Does TrueCar Address California Privacy Rights?

This part of our Notice applies to consumers who reside in the State of
California.

Personal Information We Collect about California Consumers

We describe the Personal Information we have collected from consumers in the
twelve (12) months preceding the effective date of this Notice in the part of
our Notice titled, “What Information Does TrueCar Gather?”. The information we
collect includes the following:

 * Identifiers such as name, address, e-mail address, phone number and other
   identifiers that we describe above.
 * The following categories of Personal Information are described in California
   Civil Code § 1798.80(e): (1) the Personal Information listed in the preceding
   bullet point as “identifiers,” (2) vehicle identification numbers (when
   linked to identified persons), vehicle information such as model and year,
   vehicle registration information, and license plate numbers, (3) information
   you provide or that we record in connection with customer support calls or
   complaints, (4) demographic information such as age range and gender, (5)
   select financial information (e.g., social security number, income
   information, credit score) if you request your credit score to personalize
   your preferred auto financing or lease terms, and (6) the other information
   that identifies, relates to, describes, or is capable of being associated
   with, a particular individual that we describe in “What Information Does
   TrueCar Gather?”.
 * Characteristics of protected classifications under California or federal law,
   such as military service, sex or age range.
 * Commercial information, including information about records of personal
   property, orders, purchases.
 * Any data from your usage of services in connection with TrueCar Services.
 * Internet or other electronic network activity information, including, but not
   limited to, browsing history, search history, usage of, and information
   regarding your interaction with our Sites.
 * Geolocation data. When you use our Sites, it may access, collect, monitor,
   and/or remotely store session and geolocation information from your device to
   connect you with dealers in your area. Geolocation information includes data
   such as your device’s physical location and may include GPS-based, WiFi-based
   or cell-based location information.
 * Audio information may be collected when you place a call with TrueCar’s
   customer service or accounting centers for quality control purposes.
 * Inferences drawn from (1) the information we collect when you utilize our
   Sites, and (2) information about TrueCar user preferences and behavior, which
   we use for product and service enhancement and optimization purposes.

For information regarding the purposes for which we collect and use the Personal
Information we collect, please see “How Does TrueCar Use Information About Me.”

Your California Privacy Rights

If you are a California consumer, you have the following rights. We will honor
requests received to the extent required by applicable law and within the time
provided by law.

(a) Right to Access and Information regarding Personal Information. You have the
right to request that we disclose to you the categories and specific pieces of
Personal Information we have collected about you. Specifically, you have the
right to request that we disclose the following to you, in each case in the
twelve-month period preceding your request:


 * the categories of Personal Information we have collected about you;
 * the categories of sources from which the Personal Information is collected;
 * our business or commercial purpose for collecting or selling Personal
   Information;
 * the categories of third parties with whom we share Personal Information;
 * the specific pieces of information we have collected about you;
 * the categories of Personal Information about you that we disclosed for a
   business purpose.

We will deliver Personal Information that we are required by law to disclose to
you in the manner required by law within 45 days after receipt of a verifiable
request, unless we notify you that we require additional time to respond, in
which case we will respond within such additional period of time required by
law. We may deliver the Personal Information to you through your account, if you
maintain an account with TrueCar, or, if not, electronically. If electronically,
then we will deliver the information in a portable and, to the extent
technically feasible, in a readily useable format that allows you to transmit
the information from one entity to another without hindrance.

(b) Right to Deletion of Personal Information. You have the right to request
that we delete Personal Information about you that we have collected from you.

(c) Right to Opt Out. You have the right to opt out of the disclosure of
Personal Information about you to third parties for monetary or other valuable
consideration. To opt-out, click Do Not Sell My Personal Information.

(d) Right to Non-Discrimination. We may not discriminate against you because of
your exercise of any of the foregoing rights, or any other rights under the
California Consumer Privacy Act, including by:


 * denying you goods or services;
 * charging different prices or rates for goods or services, including through
   the use of discounts or other benefits or imposing penalties;
 * providing you a different level or quality of goods or services; or
 * suggesting that you will receive a different price or rate for goods or
   services or a different level or quality of goods or services.

We may, however, charge different prices or rates, or provide a different level
or quality of goods or services, if that difference is reasonably related to the
value provided to TrueCar by your Personal Information.

Requests to Exercise Your Rights

You may request to exercise the foregoing rights by:

 * Submitting a request online, or
 * Calling us toll-free at 1-833-TRUECAR, or

You may designate an authorized agent to make a request on your behalf. Please
note that we may take steps to verify your identity before granting you access
to information or acting on your request to exercise your rights, as required or
permitted by law. We may limit our response to your exercise of the above rights
as permitted by law.

Data Sharing for Direct Marketing Purposes

Residents of the State of California may request a list of all third parties to
which we have disclosed certain personal information (as defined by California
law) during the preceding year for those third parties’ direct marketing
purposes. If you are a California resident and want such a list, please contact
us via the Contact section provided below.

Do Not Track Notice

At this time, there is no worldwide uniform or consistent industry standard or
definition for responding to, processing, or communicating Do Not Track signals.
Thus, like many other websites and online services, our Sites are currently
unable to respond to Do Not Track Signals.

7. How Does TrueCar Handle Privacy Disputes?
By using this Site, you agree that any dispute arising out of or relating to the
Sites, the Sites’ content or the services or materials made available on the
Sites, or regarding information collected or shared about you, is subject to the
Choice of Law, Venue, and Class Action Waiver provisions in our Terms of
Service.

8. How Does TrueCar Protect the Security of the Personal Information it
Collects?
We use administrative, technical, and physical security designed to safeguard
personal information in our possession. We cannot guarantee the security of the
information that we collect and store. If you believe that information about you
has been subject to unauthorized disclosure, please let us know by emailing
privacy@truecar.com.

9. How Does TrueCar Provide Updates to this Notice?
When we make material changes to this Notice, we will update this web page and
change the Effective Date listed above.

10. How Can TrueCar be Contacted Regarding Privacy Issues?
You can contact us with questions or comments about our privacy practices or
this Notice by emailing us at privacy@truecar.com or you can contact us at:

TrueCar, Inc.
1401 Ocean Avenue, Suite 200
Santa Monica, CA 90401
1-888-TRUECAR



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