Privacy Policy

This Privacy Policy ("Privacy Policy") applies to the tools, features, and services (collectively, the "Services") created and/or offered by EZLeads Management, Corp. ("EZLeads") including each and every of its owners, agents, officers, directors, shareholders, employees, contractors, sub-contractors, independent contractors, partners, members, managers, parents, subsidiaries and affiliates (together, "the EZLeads Representatives", "we" or "our"), through any EZLeads application, including, without limitation all web-based and mobile applications ("Apps") that reference or link to these Terms. This Privacy Policy is incorporated into EZLeads' Terms of Service. Capitalized terms not defined in the Privacy Policy are defined in the Terms.

1. Scope and Consent

This Privacy Policy covers:

1. Information collected from those who use our Services ("you" or "your"); and
2. Information that our Business Partners (defined below) share with EZLeads or that we share with our Business Partners.

You accept and agree to be bound by this Privacy Policy when you access or use one or all of the Services that link to this Privacy Policy. This Privacy Policy does not cover the information practices of: (i) third-party individuals or entities who perform tasks on our behalf ("Service Providers"); (ii) our third-party business partners who provide websites, applications or other products or services that you may encounter or access through the Services ("Business Partners"); or (iii) any other third parties (collectively with Service Providers and Business Partners, "Third Parties"), even if you access, encounter or interact with such Third Parties through the Services. While we attempt to facilitate access only to those Third Parties that share our respect for your privacy, we are not responsible for the privacy policies or practices of Third Parties, and you are responsible for reading and understanding those Third Parties' privacy policies.

2. Information Collected or Received

When you use the Services, EZLeads may collect "Non-Personal Information" and "Personally Identifiable Information" (defined below) (collectively, "Information") about you, your use of the Services, or the device you use to access the Services.

A. Non-Personal Information

"Non-Personal Information" is any information that does not enable identification of an individual, such as, without limitation, technical information, behavioral information, and aggregated information, including service usage information, web traffic information, content viewed on the Services, your preferences, and information about your operating system, browser, device, keyboard language and hardware.

B. Personally Identifiable Information

"Personally Identifiable Information" (or "PII") is information that identifies you. Examples of PII that may be collected through the Services include, without limitation:

• Name
• Email address
• Mailing address
• Telephone number(s)
• Login information
• Social networking handle or username
• Photos (e.g., for profiles)
• Date of birth
• Social Security number
• Driver's license state and number
• Financial information
• Employment information
• Residency or credit-proof information (e.g., utility bill, copy of paystub, references)
• Insurance information

The specific Information actually collected by EZLeads will depend on the portion of the Services you access. If Non-Personal Information is connected or linked to PII, we treat the Non-Personal Information as PII.

3. How Information is Collected

A. PII Provided Directly by You

You may voluntarily provide us with PII when using the Services, including, without limitation, when you perform the following activities:

• Use Interactive Areas
• Make submissions, post comments, or provide reviews or testimonials
• Submit online forms or make requests for communication or support
• Initiate or complete transactions through the Services
• Send or receive Texts
• Conduct and/or save searches
• Electronically sign agreements

Please note that content posted to Interactive Areas may be publicly viewable. Therefore, if you upload or share any Information to Interactive Areas, unless otherwise expressly stated by EZLeads, such Information may be non-confidential and may become publicly available. This means the Information may be collected, used, or redistributed by others, so please proceed with caution before posting anything sensitive or confidential.

B. Information Collected Automatically

We and certain Third Parties may also automatically collect Non-Personal Information about you and your devices when you interact with the Services, including:

• Computer or device operating system information
• IP address
• Network information
• Browser type and language
• Connection speed
• Mobile device ID
• Device hardware type
• Referring website or application
• Parts of the Services accessed
• Access times and length of time on a page or feature
• Content viewed
• Geographic location

C. Information Collected Through Tracking Tools

When you access our Services, we or Third Parties may use technologies such as "cookies", local storage capabilities, or other similar technologies to monitor usage of the Services ("Tracking Tools"). For full details, see our Cookie Policy.

Cookies

Cookies are small data files stored on your hard drive by a website, and may include session cookies (which expire once you close the browser) and/or persistent cookies (which stay on your browser and may be used by the browser on subsequent visits to the Services, unless deleted by you). Among other things, cookies help us see which parts and features of our Services are popular, count visits, and improve or tailor the Services to make them more relevant to you. You can turn off your web browser's ability to accept cookies, but certain parts of the Services may not work for you.

Unique Identifiers

We may use unique identifiers to collect information about your use of the Services on an individual basis, such as length of time spent on a particular page and pages viewed during a particular log-in period. We use this information to evaluate and improve the Services.

Web Beacons

Web beacons (clear GIFs / pixel tags) are small graphic image files that can be embedded in web pages or emails to collect information about your use of our Services or the correspondences that we send.

Analytics

We use Google Analytics and similar services to help analyze how you use the Services. These services may use cookies, including first- and third-party cookies, as well as other Tracking Tools. Google's ability to use and share information collected by Google Analytics about your visits is subject to the Google Analytics Terms of Use and Google's Privacy Policy. You may opt out using the Google Analytics Opt-out Browser Add-on.

Mobile Device Identifiers

Mobile device identifiers are stored on your mobile device and track how you use the Services through your mobile device. They enable collection of Non-Personal Information (such as usage and traffic data) and help EZLeads learn more about your preferences and internet behaviors in order to operate and improve the Services.

4. Use and Sharing of Information

A. To Provide the Services

We use the Information collected, and may share such Information with Third Parties to provide, operate, and maintain our Services, including for the following purposes:

• Personalizing, improving, and operating our business and the Services
• Better understanding the needs and interests of you and others who may use the Services
• Fulfilling requests you make related to the Services, including responding to support requests or processing and facilitating transactions
• Processing and facilitating payments
• Providing Service announcements or further information, recommendations, and offers
• Complying with applicable law, regulation, legal process, subpoena, or governmental requests
• Resolving disputes or security or technical issues
• Enforcing our agreements or investigating potential violations
• Protecting against fraudulent, harmful, unauthorized or illegal activity
• Performing statistical analysis and research activities
• Processing or storing Information through EZLeads' affiliated companies and authorized Third Parties
• Other commercial purposes (including, without limitation, offering you insurance, financing, service contracts, or other products in connection with the purchase or sale of a vehicle)

If we share your PII for a purpose not mentioned in this Privacy Policy, we will receive your express approval prior to the disclosure.

B. Marketing and Advertisements

We may use your Information to send you information about our Services or the services of our Business Partners. Some advertisements may come from Third Parties called "ad networks". We do not provide PII to any ad networks for use not related to the Services. By using the Services, you consent to us providing you with marketing materials, including:

• Direct Marketing: Communications or advertisements sent directly to you via telephone, mail, email, text, or other methods.
• Advertisements: Advertisements and commercials from us or Third Parties.
• Interest-Based Advertisements: Content and advertisements personalized to your interests, inferred from activity on our Services and based on information gathered using Tracking Tools.

You may withdraw your consent through the Contact Us portal of the Website. Even if you opt out, you will still see advertisements while browsing online; they may simply be less relevant.

C. Uses and Disclosure of Non-Personal Information

EZLeads may transfer and disclose Non-Personal Information to Third Parties at its own discretion for industry analysis, marketing and advertising, facilitating data collection, fighting spam/malware and other business purposes.

5. Third Parties

You consent to our sharing of Information, which may include PII, with Third Parties such as:

• Social media networks (Facebook, Instagram, WhatsApp, TikTok, X/Twitter, LinkedIn)
• Payment processors (e.g., Stripe)
• Credit check and financing Service Providers (e.g., Capital One)
• Vehicle inspectors
• Vehicle history providers (e.g., Carfax, Inc.)
• Shipping providers
• Web hosting services (Microsoft Azure)
• Analytics and advertising Service Providers (Google Analytics, Meta, Google Ads, TikTok)
• Sales management tools
• Marketing and promotion partners
• Law enforcement or other legal authorities pursuant to a subpoena or court order

For our complete list of sub-processors, see our Sub-processors page.

6. Ad-Platform Data (Meta / Google / TikTok / Microsoft)

EZLeads operates an ad-platform connector that allows our dealership customers ("Dealers") to authorize EZLeads to retrieve lead-form submissions and related advertising data from their advertising accounts on Meta (Facebook & Instagram), Google, TikTok, Microsoft Advertising and similar platforms.

A. Data we receive from these platforms

With the Dealer's authorization (granted via OAuth), we may receive: lead form responses (e.g., name, email, phone, vehicle interest, free-text answers); page and form metadata; campaign, ad set and creative identifiers; ad-account information; conversation messages from Click-to-WhatsApp, Messenger and Instagram Direct (when the Dealer enables this scope); and aggregate ad-performance metrics.

B. How we use platform data

Solely to (i) deliver leads to the Dealer's CRM, (ii) attribute leads to source campaigns, (iii) sync inbox conversations, (iv) generate reporting for the Dealer and (v) maintain the Services. We do not sell platform data, do not use it to build or augment user profiles for advertising, and do not retain it after the Dealer disconnects unless retention is required by law.

C. Your rights as an end user

If you submitted a lead via a Dealer's Lead Ad, Lead Form Extension, Click-to-WhatsApp campaign or similar, you may request access to or deletion of that data at any time at /legal/data-deletion. The Dealer is the data controller of that lead; EZLeads acts as a data processor.

7. Financial Information

If you make a purchase or sale through the Services, or otherwise use the Services in a way that involves sending or receiving payment, we may request information to process and complete the transaction such as: credit card information; name and contact information of financial institution; account type; routing number; account number.

This Information is collected and stored by our third-party payment processing company, Stripe, Inc. (the "Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable terms of service and privacy policy.

If you fill out a credit application through our Services, we may collect and store your credit application details that are eventually shared with EZLeads' Business Partners or Service Providers, such as Capital One, and which may contain some or all of the following Information:

• Name
• Email address
• Mailing address
• Phone number
• Date of birth
• Driver's license number
• Employment information
• Income information

By submitting your Information, you expressly authorize (i) EZLeads to transfer such Information to its Business Partners or Service Providers, and (ii) EZLeads, and any of its Business Partners or Service Providers, to use that Information in accordance with their respective privacy policies.

8. Ways to Limit our Information Collection and/or Use

If you want to limit our collection and/or use of your Information, you have several choices:

• Limiting Information provided to EZLeads: You can opt not to disclose certain Information; however, certain features may not be accessible without it.
• Terminating your Account(s): You may limit our collection and use of some Information by terminating your Account(s).
• Tracking Tool choices: Most browsers will let you erase cookies, block their acceptance or warn you before storage. See our Cookie Policy for granular categories.
• Do Not Track: We do not currently respond to Do Not Track signals because no industry standard has emerged.

9. Your Privacy Rights (GDPR / CCPA)

Depending on your location, you may have the following rights:

• Access the personal data we hold about you;
• Correct inaccurate personal data;
• Delete personal data ("right to be forgotten");
• Restrict certain processing;
• Port your data in a structured, machine-readable format;
• Object to processing for direct marketing or based on legitimate interests;
• Withdraw consent where we rely on consent;
• Lodge a complaint with your local data-protection authority;
• Opt out of "sale" or "sharing" of personal information (CCPA / CPRA);
• Limit use of sensitive personal information (CCPA / CPRA).

To exercise any of these rights, email privacy@ezleads.io or use the dedicated Data Deletion Request form. We respond within 30 days as required by law.

10. Deletion of Information

If for any reason you wish to close your Account or delete or modify your PII, you can use our self-service Data Deletion Request form, contact us through the Contact Us portal, or email privacy@ezleads.io. We will make reasonable efforts to action your request within 30 days, subject to applicable laws, rules, regulations or court orders.

Public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public. Aggregate and/or anonymous information derived from your Account and/or use of the Services may remain on our servers indefinitely.

11. Retention

We retain personal information only for as long as necessary to provide the Services and fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law (e.g., tax, financial, fraud-prevention or audit obligations). When we no longer need it, we delete or anonymize it using a documented destruction procedure.

12. Security

EZLeads maintains commercially reasonable administrative, technical and physical safeguards designed to protect personal information, including encryption in transit (TLS 1.2+), encryption at rest (AES-256), least-privilege access controls, formal change management, vulnerability scanning, and 24/7 monitoring. Despite these safeguards, no method of transmission or storage is 100% secure. See our Security page for the complete program description.

13. Children's Privacy

We do not intend to and do not knowingly collect PII from children under the age of seventeen (17). We reserve the right to request proof of age at any stage so that we can verify that children under seventeen are not using the Services.

14. International Transfers & Business Transfers

Our infrastructure is located in the United States. By using the Services from outside the United States, you consent to the transfer, storage and processing of your information in the United States.

In the event of a business transfer, your Information is typically one of the transferred business assets. If we, or substantially all of our assets, are acquired, or if we go out of business or enter bankruptcy, your Information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer may continue to use your Information as set forth in this policy.

15. Changes to the Privacy Policy

EZLeads reserves the right to make changes to its Privacy Policy at any time and for any reason without prior or subsequent notification. All changes are effective as of the date modified and your continued use of the Services after the indicated date will constitute acceptance to be bound by those changes. EZLeads reserves the right to stop, temporarily or permanently, the operation of any and all Services without notice, at any time.

16. Contact Us

EZLeads is a fully online service. To contact us about this Privacy Policy, exercise privacy rights, or report concerns, email our Privacy Office at privacy@ezleads.io. EZLeads Management, Corp. is incorporated under the laws of the State of Florida, United States.

Interpretation

The section and paragraph headings in this Privacy Policy, as well as all summaries included, are for convenience only and shall not affect the Privacy Policy's interpretation. Any use of "including", "for example" or "such as" shall be read as being followed by "without limitation" where appropriate.