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OpenTrade Privacy Policy

Thank you for choosing OpenTrade! This Privacy Policy describes how OpenTrade collects, uses and handles your information when you use our web site, software, and services (“Services”). By submitting personal information to OpenTrade, by conducting business with OpenTrade or by using OpenTrade Services, you agree to the terms of this Privacy Policy statement and expressly consent to the collection, processing, use and disclosure of your personal information for the purposes set out in this Privacy Policy. The OpenTrade Service is intended for use by an adult general audience. The OpenTrade Service is not directed to children under the age of 13 and OpenTrade does not knowingly solicit personal information from or market to children under the age of 13. If we learn that anyone under the age of 13 has provided any personal information through the OpenTrade Service, we will use commercially reasonable efforts to promptly delete it. This Privacy Policy does not apply to other companies' web sites or services or links that you may access via the OpenTrade Service. Information collected or received by these third parties is subject to third party privacy policies. If you are located outside the United States, please note that personal information collected via the OpenTrade Service may be transferred to the United States and other countries which might not provide an equivalent level of protection as the data protection laws in your own country

Information We Collect and Usage

OpenTrade collects and uses Customer's account, information like your name, email address, phone number, and physical address. OpenTrade may also collect, and associate with Customer's account, information related to your dealership, such as dealer registration number, vehicle purchases and sales, and tax information. OpenTrade may also receive personal information from our business partners and other third parties. The information we collect is used to improve the content and quality of the OpenTrade Service.

OpenTrade uses information that is collected for the following general purposes:

• to verify the information that you provide to OpenTrade; • to assist with the collection of any amounts owing by you to OpenTrade; • to contact you in response to any transactions, requests, complaints or comments you may have; • to contact you to provide you with information regarding OpenTrade’ business; • to provide advertisements to you through our web site, email messages, mobile applications or other methods of communication; • to administer surveys, contests or other promotional activities or events sponsored by us, our vendors or other third-party service providers; • to help us to develop, evaluate and improve our sales and marketing strategies and techniques; • to operate and improve our web site; • to provide third parties with information necessary to permit that third party to conduct business with OpenTrade and/or effectively provide you with services. • to assist OpenTrade and third parties in evaluating the vehicle industry; and • to respond to legal process and reasonable inquiries from regulatory and/or investigative authorities.

Information is not shared with or sold to others for commercial purposes, except to provide the products or services you've requested, when we have your permission, or under the following circumstances:

• It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law, regulation or governmental request. • We may share and/or transfer information in the event of a potential or actual acquisition of OpenTrade or its merger with another company. • OpenTrade may use agents and contractors in order to help operate the OpenTrade Service. OpenTrade shares credit information concerning dealer with its affiliated companies, third party auctions and certain service providers. We require agents and contractors that have access to OpenTrade subscriber information to protect this information in a manner consistent with this Privacy Policy, and prohibit them from using the information for any purpose other than to carry out the services they are performing for the OpenTrade Service

Services

When Customers use our Services, we store and process your information and information related to your use of the services (for example, photos, transaction history, feedback, signature, etc.) If Customer gives us access to Customer contacts, OpenTrade will store those contacts on our servers for Customer to use. This will make it easy for the Customer to buy and sell vehicles, send emails, and invite others to use the Services.

Cookies

OpenTrade also collects information from and about the devices the Customer uses to access the Services. This includes things like IP addresses, the type of browser and device you use, and identifiers associated with the Customer’s devices. Customer devices, depending on their settings, may also transmit location information to the Services. A cookie is a small amount of data, which often includes an anonymous unique identifier, and is sent to your browser from a web site computer and stored on your computer's hard drive. Cookies are required to use the OpenTrade Service. We use cookies to record current session information. We may, from time to time, use similar technologies, including web beacons, pixel tags, flash objects, location tracking and/or third party widgets for purposes of enhancing your web or mobile experience and/or for purposes of allowing you to share information on another platform, such as a social media platform. OpenTrade uses technologies like cookies to provide, improve, protect and promote our Services. For example, cookies help OpenTrade with things like remembering a Customer’s Customer name for your next visit, understanding how Customers are interacting with our Services, and improving them based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Services.

Who We Share Information With

OpenTrade may aggregate data collected by the Services and sell that aggregated data to advertisers and other third parties. The aggregate data may or may not be anonymized. OpenTrade uses certain trusted third parties to help us provide, improve, protect, and promote our Services. These third parties will access Customer information only to perform tasks on our behalf and in compliance with this Privacy Policy. OpenTrade may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of OpenTrade or our Customers; or (d) protect OpenTrade’s property rights.

Security

OpenTrade takes commercially reasonable technical, physical and administrative measures to protect the confidentiality, integrity and security of your personally identifiable information. Of course, we cannot guarantee the security of your personally identifiable information on the Internet. The password-protected areas of the OpenTrade Service are secured by industry standard encryption. However, it is your responsibility to maintain the confidentiality of your password(s) and other user credentials. You are also required to log-in to your OpenTrade account after a certain period has elapsed to protect you against others accidentally accessing your account. Retention, Data Storage and Transmission All personally identifiable information you provide to OpenTrade is secured on servers with restricted access. We reserve the right to use third party agents and service providers, who are bound by strict confidentiality guidelines, to perform storage and processing functions. We will store your personal information for as long as there is a business need for it in accordance with applicable record retention policies and a range of legal and regulatory recordkeeping requirements To provide you with the Services, we may store, process and transmit information in locations outside the United States. Information may also be stored locally on the devices you use to access the Services.

Change of Control

If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

Opt-Out, Changes and Questions

OpenTrade may periodically update this Privacy Policy. Consequently, you should review the Privacy Policy periodically. We may also notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your OpenTrade primary account holder account or by placing a prominent notice via the OpenTrade Service. If you have any questions about this Privacy Policy or its implementation, if you would like to update personal information previously submitted to OpenTrade or request to have outdated personal information removed, or withdraw consent to the use or disclosure of your personal information, you may contact us by sending an email to contact@OpenTrade.com or by phone at 1-800-553-9993.