Section 01

Scope of this Privacy Policy

This Privacy Policy applies to Drivesona websites,
Drivesona-powered vehicle discovery experiences, VIN-level
intelligence experiences, dealer website integrations,
widgets, dashboards, analytics tools, communications,
and other products or services that link to or reference
this Privacy Policy (collectively, the “Services”).

“Drivesona,” “we,” “us,” and “our” refer to Drivesona and
the entities operating the Drivesona platform.

This Policy does not replace the privacy policy of a dealership
or other partner. When you interact with a dealership through
Drivesona, that dealership may independently collect or use
your information under its own privacy policy.

Section 02

Information We Collect

The information Drivesona collects depends on how you interact
with the Services and which features a dealership or partner
has enabled.

Sensitive Information

Drivesona does not intentionally request sensitive personal
information unless it is reasonably necessary for a disclosed
feature, permitted by law, or provided with appropriate consent.

Unless expressly disclosed in a specific feature, the Drivesona
consumer experience is not designed to collect Social Security
numbers, full payment-card numbers, bank credentials, medical
information, government identification numbers, or consumer
credit application information.

Section 03

Where Information Comes From

We may collect information directly from you, automatically
from your browser or device, from dealerships and dealer groups,
from automotive inventory feeds and technology providers,
from analytics and communications providers, and from other
partners that are authorized to provide information to Drivesona.

We may also combine information from different sources when
permitted by law and consistent with applicable contracts.

Section 04

How We Use Information

We may use personal information to:

• operate, maintain, secure, and improve the Services;
• connect shopper preferences with relevant vehicle inventory;
• provide VIN-level and vehicle-fit intelligence;
• personalize vehicle discovery experiences;
• remember saved vehicles and preferences where supported;
• identify returning sessions or shoppers where permitted;
• measure engagement and customer journeys;
• generate shopper, inventory, demand, and market intelligence;
• route shoppers to dealerships and dealership-owned websites;
• respond to demo, support, or contact requests;
• send communications you request or consent to receive;
• detect fraud, misuse, security threats, and technical problems;
• perform analytics, testing, research, and product development;
• comply with legal, regulatory, contractual, and security obligations;
• protect Drivesona, our users, dealerships, partners, and others;
• create aggregated or de-identified statistics and analytics; and
• support other purposes disclosed when information is collected.

Section 05

Artificial Intelligence, Profiling & Inferences

Drivesona uses software, algorithms, machine learning,
semantic systems, and artificial-intelligence technologies
to help interpret vehicle information, understand shopper
requests, match inventory with stated needs, organize
discovery experiences, and generate analytics or inferred
shopper-interest signals.

For example, interactions with vehicles, searches, stated
preferences, or repeat engagement may be used to infer
potential vehicle interests or shopper intent.

Drivesona may use third-party technology providers to support
AI or machine-learning functionality. When those providers
process personal information for Drivesona, we expect them
to do so subject to applicable contractual and privacy obligations.

Section 06

Dealerships, Dealer Groups & Other Partners

Drivesona frequently operates in connection with dealerships,
dealer groups, agencies, website providers, inventory providers,
and other automotive technology partners.

When Drivesona Acts on Behalf of a Partner

In some situations, Drivesona processes personal information
on behalf of a dealership or other partner and subject to
that partner’s instructions. In those situations, the partner
may be the business or controller responsible for determining
how the information is used.

Requests concerning data controlled by that partner may need
to be directed to the partner. Drivesona may assist the partner
in responding as required by applicable law or contract.

Dealer Handoffs

If you request contact from a dealership, click through to
dealership inventory, submit a lead, request information,
schedule an appointment, or otherwise ask to engage with a
dealer, relevant information may be provided to or collected
directly by that dealership.

Once information is received independently by the dealership,
the dealership’s own privacy practices may apply.

Section 07

When We Disclose Information

Drivesona may disclose personal information to the following
categories of recipients where appropriate:

• dealerships and dealer groups when necessary to provide a
  requested experience or dealer handoff;
• service providers and processors that support hosting,
  infrastructure, databases, analytics, communications,
  security, customer support, artificial intelligence,
  and other business functions;
• technology and integration partners necessary to operate
  a particular Drivesona service;
• professional advisers such as attorneys, accountants,
  auditors, insurers, and consultants;
• law enforcement, courts, regulators, government agencies,
  or other parties where required or permitted by law;
• parties involved in an actual or contemplated merger,
  financing, investment, acquisition, reorganization,
  sale of assets, bankruptcy, or similar corporate transaction;
  and
• other parties when you direct us to disclose information
  or provide valid consent.

We may disclose aggregated or de-identified information that
does not reasonably identify an individual, subject to applicable law.

Section 08

Text Messages, Telephone Calls & Consent

Drivesona, a participating dealership, or another specifically
identified partner may offer the option to receive communications
by SMS, MMS, telephone, or similar channels.

Dealer and Partner Consent

Consent to receive communications from Drivesona does not
automatically constitute consent to receive marketing messages
from every dealership or third party.

When a form requests consent for communications from a particular
dealership or partner, the disclosure should identify that
organization. Where separate consent is legally required,
Drivesona will not treat consent to one seller or sender as
blanket consent for unrelated sellers or senders.

Mobile Opt-In Information

Drivesona does not sell mobile telephone numbers, SMS opt-in
records, or text-message consent information to unrelated third
parties for their independent marketing purposes.

Mobile information and consent records may be provided to
vendors that help deliver or administer the messaging program,
subject to appropriate restrictions, or to a specifically
identified dealership or partner when the consumer has separately
consented to communications from that party or disclosure is
otherwise permitted by law.

Opt-Out Requests

After we receive a valid request to stop text messages,
we will process the request as required by applicable law.
We may send a final non-promotional message confirming
that the opt-out request has been processed.

Consent Records

Drivesona or its messaging providers may retain records
reasonably necessary to document consent and opt-out activity,
such as the telephone number, date and time of consent,
consent language displayed, source or form used, campaign,
IP address or device information, and revocation history.

Section 09

Cookies, Pixels & Similar Technologies

Drivesona and our service providers may use cookies,
local storage, pixels, tags, server logs, software-development
kits, and similar technologies to operate the Services,
remember preferences, understand usage, maintain security,
measure performance, and improve the platform.

Depending on the Services and technologies deployed,
these tools may collect information such as IP address,
device identifiers, pages viewed, referring pages,
timestamps, interaction events, and browser information.

Where required by law, we will provide appropriate choices
regarding non-essential cookies or targeted-advertising technologies.

Section 10

Sale, Sharing & Targeted Advertising

Drivesona does not sell personal information in exchange for
money as part of our ordinary business model.

Certain privacy laws define “sale,” “sharing,” or
“targeted advertising” more broadly than an exchange of
information for money. For example, use of certain third-party
advertising, analytics, or tracking technologies may be treated
as sale, sharing, or targeted advertising under some state laws.

Where Drivesona engages in activity subject to such rights,
eligible individuals may request to opt out as described
in the Privacy Rights section below.

Where required, Drivesona will also recognize qualifying
browser-based opt-out preference signals, such as Global
Privacy Control, for the browser or device from which
the signal is received.

Section 11

Data Retention

Drivesona retains personal information for as long as reasonably
necessary for the purposes for which it was collected, including
to provide the Services, maintain legitimate business records,
support analytics, document consent, fulfill contractual
obligations, resolve disputes, prevent fraud, enforce agreements,
and comply with legal requirements.

Retention periods may vary based on the type of information,
sensitivity, contractual requirements, dealership or partner
instructions, legal obligations, and operational needs.

When information is no longer reasonably necessary,
Drivesona may delete, anonymize, aggregate, or otherwise
dispose of it in accordance with applicable requirements.

Section 12

Data Security

Drivesona uses administrative, technical, and organizational
safeguards designed to protect personal information against
unauthorized access, destruction, loss, alteration, misuse,
or disclosure.

Measures may include access controls, authentication,
encryption where appropriate, logging, monitoring,
infrastructure protections, vendor controls, backups,
and other security practices appropriate to the nature
of the information and Services.

No information system, transmission method, or storage
environment can be guaranteed to be completely secure.

If Drivesona becomes aware of a security incident involving
personal information, we will investigate and provide
notifications where required by applicable law or contract.

Section 13

Your Privacy Rights

Depending on where you live and whether applicable legal
thresholds are met, you may have rights regarding your
personal information.

These rights may include the ability to:

• confirm whether we process personal information about you;
• access personal information we maintain about you;
• obtain a copy of certain personal information;
• correct inaccurate personal information;
• request deletion of personal information;
• opt out of certain sales or sharing of personal information;
• opt out of targeted advertising;
• opt out of certain profiling used in decisions producing
  legal or similarly significant effects, where applicable;
• limit certain uses of sensitive personal information where applicable;
• withdraw consent where processing is based on consent;
• appeal certain privacy-request decisions where applicable; and
• receive equal service and pricing without unlawful discrimination for exercising privacy rights.

Submitting a Request

To submit a privacy request, contact Drivesona at:

colincarrasquillo@yahoo.com

Please use the subject line “Drivesona Privacy Request.”

We may need to verify your identity before fulfilling certain
requests. Verification may require information reasonably
necessary to match you with records maintained by Drivesona.

An authorized agent may submit a request where permitted by law,
but we may require evidence of the agent’s authority and may
separately verify the consumer’s identity.

Partner-Controlled Information

If Drivesona maintains information solely on behalf of a
dealership or partner, we may refer the request to that
organization or assist it in responding.

Section 14

California Privacy Notice

If California privacy law applies to Drivesona’s processing
of your personal information, California residents may have
additional rights regarding access, correction, deletion,
sale or sharing, sensitive personal information, and
non-discrimination.

During the preceding 12 months, depending on the Services used,
Drivesona may have collected the categories of information
described in this Policy, including identifiers, internet
or electronic-network activity, commercial or vehicle-interest
information, geolocation information at an approximate level,
professional information for business users, and inferences.

Such information may be used for the business and commercial
purposes described in this Policy and disclosed to the
categories of recipients described above.

Drivesona does not knowingly sell or share the personal
information of consumers under 16 years of age in circumstances
requiring affirmative authorization.

California “Shine the Light”

California residents may also have rights under other
California laws concerning disclosure of personal information
for third-party direct-marketing purposes, where applicable.

Section 15

Children’s Privacy

Drivesona’s Services are designed for vehicle shoppers,
dealerships, automotive businesses, and other adult users.
They are not directed to children under 16.

Drivesona does not knowingly collect personal information
from children under 13 through Services directed to the
general public.

If you believe a child has provided personal information
to Drivesona inappropriately, please contact us so the
information can be reviewed and addressed.

Section 16

International Users & Data Transfers

Drivesona is based in the United States. Information may be
stored or processed in the United States or other jurisdictions
where Drivesona or its service providers operate.

Privacy and data-protection laws in those jurisdictions may
differ from the laws where you reside.

Where legally required, Drivesona will use appropriate
mechanisms for international transfers of personal information.

Section 17

Changes to This Privacy Policy

Drivesona may update this Privacy Policy as the platform,
our data practices, technology, partnerships, or legal
requirements change.

When we make material changes, we may provide additional
notice when appropriate and will update the effective date
displayed at the top of this Policy.

Your continued use of the Services after an updated Policy
becomes effective is subject to applicable law and does not
override any consent rights that require separate affirmative
action.

Section 18

Contact Drivesona

Questions about this Privacy Policy, privacy practices,
consent, or personal-information requests may be directed to:

Drivesona
Attn: Privacy
Email:

colincarrasquillo@yahoo.com

Please include enough information for us to understand
and respond to your request, but do not send sensitive
information such as Social Security numbers, financial
account credentials, or passwords by ordinary email.