Privacy Policy

REVISION DATE: 9/26/24

Thank you for visiting www.smarterauto.com . We take your privacy seriously www.smarterauto.com , which is why we developed this privacy policy to explain our online information collection and use practices. This Policy is limited solely to online transactions and does not apply to offline privacy rights or obligations, data collection, and transfers.

Collection of Information

We collect personal data from our users during the initial registration process, notification process and when users contact us for any reason. Thus, users can determine to some extent what information they wish to provide to us. In addition to the initial registration process, we may, from time to time, ask users to answer surveys about our or third party products and services. We gather this data in order to better understand our users' interests and provide them with relevant offers and information.

Through the use of "cookies" and "pixel tags"(both described below) and online survey and registration forms, we may collect personal data including name, address, email address, phone or mobile number. We may also collect demographic information such as age, gender, income level, or technical information such as IP address, domain name, email address, site traffic, where you visited before or after visiting our website.

We use certain scripts provided by third-party service providers, such as those provided by Lead Intelligence, Inc. d/b/a Jornaya ("Jornaya"), ActiveProspect, Inc. (including its TrustedForm service) and Microsoft Clarity, to independently document users' consent to be contacted, including those users' "prior express consent" has been provided as required by the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time ("TCPA"). These scripts are embedded on our website and collect the following information when users interact with the page(s) where the scripts are present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user's computer, time on the page, date and time that the script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user's browser. For more information about the data usage, retention and collection policies and practices of these third-party service providers, please click on the links located below:

• ActiveProspect Trusted Form Script. Privacy Policy: https://activeprospect.com/privacy-policy
• Microsoft Clarity's Script. Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement
• Jornaya's Script. Privacy Policy: https://www.jornaya.com/consumer-privacy-policy/

Collection of Technology Information

"Pixel tracking" is a common process which may be used in connection with advertisements on the Website. Pixel tags that are not visible to the user of the Website and consist of a few lines of computer coding. Pixels are tracking measures to determine the effectiveness of advertisements and compiles aggregate and specific usage statistics. A "pixel tag" is an invisible tag placed on certain pages of the Websites you may visit and is used to track an individual user's activity. We may access these pixel tags to identify activity and interests that may allow us to better match our offers with your interests. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow us to track that this advertisement brought you to us. If you visit our website and we link you to another website we are able to determine that you were sent to and/or transacted business with a third party website. This data is collected for use in our marketing and research. Personally identifiable information about you is not collected by the third party advertising company, nor is any tracking information generated from the pixel tag allowed to be used by them for any other purpose other than to report website activity to us.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click data. We use this information, which does not identify you directly to analyze trends, administer the website, track your movements around our website and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

We may use Google Analytics on parts of our Website. If you prefer to not have your data used by Google Analytics you may visit the Google Analytics opt-out page and install the add-on for your browser.

The third-party advertisers, vendors, and ad networks may also use cookies to show advertisements to you. These third-party vendors may include Google DoubleClick, Media.net, and/or other ad networks. Each network uses cookies to enable it to serve ads to you based on your visit to our Website and/or other websites on the Internet. You may opt out of a third-party vendor's use of cookies for interest-based advertising by visiting aboutads.info at any time.

Sharing Information With Third Parties

When you use our website, we share information that we may collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our partner, LiveRamp Inc. and its group companies ('LiveRamp'). LiveRamp may use a cookie on your browser and match your shared information to its on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. We may also share hashed and de-identified email addresses, IP address, and advertising identifiers with LiveRamp, which uses that information to create a link between your device and its databases. This link may be shared by our partners globally to enable interest-based content or advertising throughout your online experience (e.g. cross-device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. To opt out of LiveRamp's targeted advertising, please head here (https://liveramp.com/opt_out/).

In the event of a merger, acquisition, or change of control of our company, your information would be considered a business asset and would be disclosed and transferred. We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We may also disclose personal information as required by law or to protect the safety and security of our users. Finally we will use your information to deliver our own commercial offers to you.

Opt-Out rights

Receiving email messages from us or anyone we share your information with is optional. As noted earlier, the collection, use, and distribution of personal data helps us create a more personalized, relevant, and intelligent web service for our users. While some basic data is necessary to provide certain services, there are some cases where the submission of information is optional. All users who provide their Information to smarterauto.com may modify and correct such Information through their personal profile or by contacting us here.

But if you are receiving offers from other companies, you may follow the simple opt-out procedure contained in each email at the bottom of the email. If you are receiving our emails and no longer wish to receive such communications, simply follow the "unsubscribe" instructions that appear in every one of our emails, or contact us at smarterauto.com, 1730 S Federal Highway #385, Delray Beach, FL 33483

Some of the advertisers and vendors that perform advertising-related services for us and our partners participate in the Digital Advertising Alliance Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices visit https://www.aboutads.info/appchoices and https://www.aboutads.info/choices.

No Control of Third Party Links or Privacy Practices

To the extent hyperlinks or banner advertisements incorporating hyperlinks are used on our website which provide you access to third party websites, you should be aware that these third party web sites are not controlled by us and, therefore, are not subject to this privacy policy. We recommend that you check the privacy policies of the websites to see how your personal information will be used and how to opt-out.

Security of Information

We have implemented a number of security features throughout our website and on the servers that hold all the collected data that are intended to prevent the unauthorized release of or access to the user information we collect online. The database is firewall protected and held in a secure location. Only authorized personnel have access to any stored personal information we collect from our users. However, e-mail is not encrypted and is not considered a secure means of transmitting any sensitive data. As such, the confidentiality of any communication or material transmitted over the Internet cannot be 100% guaranteed. Therefore we are not responsible or liable for illegal interception of personal data by unknown third parties.

You are responsible for maintaining the confidentiality of your smarterauto Login ID and Password. We maintain rules to help prevent others from guessing your password. We recommend that you change your Password frequently. If you believe that they have been stolen or been made known to others, you must contact us immediately via our Contact form found on our Help page at https://www.smarterauto.com/contact-us but in any event you should change your password immediately via the Service. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy and Security Policy or the smarterauto.com Terms of Use.

Personal information of Children or Persons residing outside the US

We do not target or direct collection of information from children under the age of thirteen. We do not intend to collect personal data from individuals under the age of 18 or non-US citizens. If we receive actual notice that a child under the age of thirteen has provided personal data to us or a resident from a country outside the United States, we will use reasonable efforts to remove such information from our database.

Changes to the Privacy Policy

We may decide to change this Privacy Policy from time to time. When we make material changes to our policy, we will post a prominent notice on this page so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. Please review this Privacy Policy from time to time so that you will be apprised of any changes.

Questions and Contact Information

If you have any questions or comments regarding this privacy policy or the use of personal data, please contact us at smarterauto.com, 1730 S Federal Highway #385, Delray Beach, FL 33483

Privacy Policy for Residents with State Privacy Laws

This Privacy Notice for residents in states with privacy laws like California, Colorado, Connecticut, Montana, Oregon, Texas, Nevada, Utah, and Virginia supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the those states.

Information We Collect

We 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"). We have collected the following categories of personal information from consumers within the last twelve (12) months:

Public information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the scope of state privacy laws, 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 you.
• Indirectly from you. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website.
• From third-parties that interact with us in connection with the services we perform.

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.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To improve our website and present its contents to you.
• 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 respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in an applicable state privacy law.
• 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.

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 a business purpose:

Category A: Identifiers. Category B: Customer Records personal information categories.

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

• Our affiliates.
• Service providers.
• 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.
• Third party marketers who we feel you will benefit from their services.

Your Rights and Choices

State privacy laws provide consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights if you are a resident of California, Colorado, Connecticut, Nevada, Utah, or Virginia.

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:

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct and Do Not Sell or Share

You have the right to request that we update or correct your Personal Information. You also have the right to request that we not sell or share your Personal Information.

Exercising Access, Data Portability, Correction, Do Not Sell or Share, or Deletion Rights

To exercise the access, data portability, correction, do not sell or share, or deletion rights described above, please submit a verifiable consumer request to us by either:

• Visiting smarterauto.com
• By clicking here and filling out the form.

Only you or a person 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.

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 will 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. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. 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 state privacy rights. Unless permitted by the applicable privacy law, 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.

Notice Concerning Processing of Health Data

This section applies to residents of Connecticut, Washington, and Nevada. We collect the below categories of health data, and we process such categories of health data for the purposes and in the manners described above:

• Individual health conditions, treatment, diseases, or diagnosis;
• Health-related surgeries or procedures;
• Use or purchase of prescribed medication;
• Diagnoses or diagnostic testing, treatment, or medication;
• Data that identifies a resident seeking health care services; and

We may collect these categories of health data from our website, including through your answers to survey questions. We may disclose these categories of health data to the same categories of entities as provided above. Where legally required, we obtain consent from you for these processing activities and enter into contracts to restrict non-affiliated parties' use of your health data.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under state privacy law, please do not hesitate to contact us at:

Website: www.smarterauto.com
Email: contact@smarterauto.com
Postal Address: smarterauto.com
1730 S Federal Highway #385,
Delray Beach, FL 33483