Privacy Policy

Last updated: 02/26/2025

Connected Dealer Services, LLC cares about your privacy. This privacy policy explains who we are, how we collect, share and use information relating to individuals (“Personal Information”), and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed. To make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections:

  • Privacy for Organizations (Section 2)
  • Privacy for Organization Customers and End Users (Section 3)
  • Privacy for Website Visitors (Section 4)

If you have any questions or concerns about our use of your Personal Information, please contact us using the contact information provided at the end of Section 14.

  1. ABOUT US
  2. PRIVACY FOR ORGANIZATIONS
  3. PRIVACY FOR ORGANIZATION CUSTOMERS AND END USERS
  4. PRIVACY FOR WEBSITE VISITORS
  5. YOUR PRIVACY CHOICES
  6. INTERNATIONAL TRANSFERS
  7. CHILDREN’S PRIVACY
  8. REQUESTS AFFECTING MULTIPLE END USERS
  9. DO NOT TRACK
  10. COOKIE POLICY
  11. CHANGE OF CONTROL
  12. DATA RETENTION
  13. SECURITY PROTECTIONS
  14. POLICY CHANGES
  15. CONTACT INFORMATION

 

1. ABOUT US

Connected Dealer Services, LLC provides in-vehicle products and services and a mobile application (the “App”) to provide connected vehicle services (collectively “Services”). A reference to “CDS,” “we,” “us” or the “Company” is a reference to Connected Dealer Services, LLC and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Information.

2. PRIVACY FOR ORGANIZATIONS

This section applies to the Personal Information we collect and process from our customers who are dealers, licensees, and partners (collectively “Organizations”) that use our connected vehicle Services to manage their vehicle fleets and provide dealership, repair, maintenance, and other services to their customers and End Users. If you are not an Organization, the other sections of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Organizations.

  1. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

Information You Give Us. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service, or communicate with us in any other way.

The categories of information include:

  • Identifiers such as real name, address, email address, phone number;
  • Personal Information under California Civil Code section 1798.80;
  • Commercial information such as purchases of the Services;
  • Internet or other electronic network activity information, such as IP address and browser type; and
  • Inferences drawn from any of the above information

Information We Automatically Collect. Like many website and App operators, we collect information that your browser or device sends whenever you visit our website and the App. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookies section below.

The categories of information include:

  • Device information: We collect information about the device and applications you use to access the Services and the App, such as your IP address, your operating system, your location, your browser ID, and other information about your system and connection.
  • Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
  • Product usage data: We collect usage data about you whenever you interact with the Services and App, which may include the dates and times you access the Services and the App and your browsing activities (such as what portions of the Services and App are used). We also collect information regarding the performance of the Services and App.

Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, and third-party data providers.

  1. How We Use Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

  • To provide you with the
  • To communicate with you about your account and provide customer
  • To market our products and/or services to
  • Through our website cookies, which you may manage through our cookie banner, to share with third-party marketing platforms that provide tailored advertising on our websites and other websites that you may visit.
  • To analyze website and App usage and improve the services
  • For market research, project planning and troubleshooting
  • For detecting and protecting against error, fraud or other criminal
  • To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our customers and third parties, as well as our This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
  1. How We Share Personal Information.

Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality.

Third Party Links and Websites. Our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners, to provide tailored advertising on our Sites and other websites that you may visit.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

3. PRIVACY FOR ORGANIZATION CUSTOMERS AND END USERS

This section applies to the Personal Information we collect and process from Organization Customers and End Users. These terms have the following meanings:

  • In connection with a vehicle sale, lease, rental, or other Organization services, Organizations (e.g. dealerships, licensees, and partners) may provide us with an individual’s Personal Information in connection with the vehicle and Organization information. These individuals are considered the “Organization Customers”.
  • An “End User” is an individual that opts-in to our connected vehicle services directly through the Organizations may have Organization Customers who are also End Users.

If you are an Organization Customer, please note that we received your information from an Organization, and the Organization may use and share your Personal Information for its own purposes. We encourage you to refer to the Organization’s privacy policy for more information on how your Organization uses and shares your data.

  1. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

Information You Give Us. You may choose to give us information about you directly. You may also provide us information in the following ways:

  • By using the App and
  • By contacting our customer service
  • By contacting us directly through a webform, email, social media message, or otherwise submit inquiries through our websites.

The categories of information include:

  • Identifiers such as real name, address, email address, or phone number;
  • Personal Information under California Civil Code section 1798.80, such as name, address, and telephone number;
  • Information about your vehicle, including but not limited to vehicle identification number (VIN), mileage, oil/battery status, fuel or charging history, electrical system function, and diagnostic trouble codes;
  • Electronic, visual, and similar information about the use of your vehicle, including operational and safety related information, speed, crash detection alerts, impact data, braking and swerving/cornering events, vehicle direction (heading), camera image and sensor data, and security/theft alerts;
  • Commercial information and information about your vehicle such as your vehicle purchases, rentals, repairs, and check-ins;
  • Internet or other electronic network activity information; and
  • Inferences drawn from any of the above information

Sensitive categories of information include:

  • Geolocation data such as your vehicle GPS
  • Login information such as your username, password, and/or

Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookies section below.

The categories of information include:

  • Device information: We collect information about the device and applications you use to access the App and Services, such as your IP address, your operating system, your location, your browser ID, and other information about your system and connection.
  • Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into the App and Services.
  • Product usage data: We collect usage data about you whenever you interact with the App and Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services.

Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public vehicle databases and third-party data brokers.

  1. How We Use Personal Information.

We may use the Personal Information we collect about Organization Customers and End Users for a range of reasons, including:

  • To offer the App and Services to you and our
  • To share your information with Organizations that may be of interest to
  • To communicate with you and provide customer
  • To evaluate and improve the quality, safety, and security of the App and
  • To develop new products and
  • Through our website cookies, which you may manage through our cookie banner, to share with third-party marketing platforms that provide tailored advertising on our websites and other websites that you may visit.
  • To market our products and/or services to
  • To analyze website usage and improve the services
  • For market research, project planning and troubleshooting
  • For warranty administration and
  • To provide product and service
  • To verify eligibility for vehicle purchase or incentive
  • For detecting and protecting against error, fraud or other criminal
  • To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our customers and third parties, as well as our This may include developing tools and algorithms that help us monitor the use of the App and Services and prevent violations.
  1. How We Share Personal Information.

Organizations. If you are an Organization Customer, we share Personal Information collected from you and your vehicle with the relevant Organization. If you are an End User that has directly opted into the App and Services, we also share Personal Information collected from you and your vehicle with your Organization and other Organizations that may be of interest to you.

Emergency Service Providers. We share your Personal Information with emergency service providers, such as law enforcement to deliver related Services (for example, Stolen Vehicle Recovery Services).

Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality.

Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners to provide tailored advertising on our Sites and other websites that you may visit.

Third Party Links and Websites. Our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Social Media. Our website may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable features to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

De-identified and Aggregate Data. We may share de-identified and aggregate data with third parties to analyze sales and customer trends. This data cannot be reasonably identified to an individual and is not Personal Information.

  1. Disclosures that May Qualify as Selling Personal Information.

We may disclose the Personal Information listed below to the categories of third parties listed in this subsection. These disclosures may, depending on the jurisdiction, qualify as “selling” Personal Information under some U.S. state privacy laws:

  • Personal Information under California Civil Code section 1798.80, such as name, address, and telephone number; and,
  • Information about your vehicle, including but not limited to, vehicle identification number (VIN), mileage, oil/battery status, fuel or charging history, electrical system function, and diagnostic trouble codes.

We may disclose the Personal Information listed above to the following categories of third parties:

  • Organizations With Whom You Have a Direct Relationship. If you are an Organization Customer, we may disclose Personal Information collected from you and your vehicle to the relevant Organization. This may include, for example, the dealership from which you purchased, rented, or leased a vehicle. These Organizations may use your Personal Information for their own benefits, including offering trade-in incentives, running marketing campaigns based on vehicle mileage and vehicle health, or offering extended vehicle
  • Organizations With Whom You Do Not Have a Direct Relationship. We may disclose Personal Information collected from you and your vehicle to Organizations with whom you may not have a direct This may include, for example, dealerships, repair shops, and insurance companies. These Organizations may use your Personal Information for their own benefits and purposes.

4. PRIVACY FOR WEBSITE VISITORS

This section applies to Personal Information that we collect and process through our websites and in the usual course of our business, such as in connection with our sales and marketing activities, recruitment, and events. In this section “you” and “your” refer to website visitors.

  1. Information We Collect.

The Personal Information that we may collect broadly falls into the following categories:

Information You Give Us. If you are a website visitor, you may choose to give us information about you directly. You may also provide us information in the following ways:

  • By contacting us directly through a webform, survey, email, social media message, or by otherwise submitting inquiries through our websites.
  • By attending our events or other business interactions and providing your contact
  • By entering into our sweepstakes or
  • By applying for a role with

The categories of information include:

  • Identifiers such as name, email address, job title, company, or phone
  • Internet or other electronic network activity information;
  • Employment information and job history for individuals who apply for a role with us; and
  • Inferences drawn from any of the above information

Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookies section below.

The categories of information include:

  • Device information: We collect information about the device and applications you use to access the websites, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
  • Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses.

We generally collect this information in the aggregate to improve the performance of our websites. We do not associate this information with you or your computer, unless we need to investigate a violation of our Terms.

  1. How We Use Personal Information

We may use the Personal Information we collect for a range of reasons, including:

  • Through website cookies, which you may manage through our cookie banner, we share information with third-party marketing platforms that provide tailored advertising on our websites and other websites that you may visit.
  • To market our products and/or services to
  • To analyze website usage and improve the services
  • For market research, project planning, troubleshooting
  • For detecting and protecting against error, fraud or other criminal
  • To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our customers and third parties, as well as our This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
  1. How We Share Personal Information.

Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality.

Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners, such as Google, to provide tailored advertising on our websites and other websites that you may visit.

Third Party Links and Websites. Our websites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Social Media. Our website may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable features to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

5. YOUR PRIVACY CHOICES

  1. General

Marketing Opt-Out: We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will continue to receive service-related messages concerning our Services.

Exercising Your Privacy Rights: We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

Please note that if you are an Organization Customer, we may also refer your privacy request to the relevant Organization.

  1. Additional Disclosures for Certain U.S. State Residents

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. Please contact us using the contact information below to make a request.

Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we are processing your Personal Information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

  • The categories of Personal Information we collect about
  • The categories of sources from which your Personal Information is
  • The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your Personal Information, and the categories of Personal Information disclosed for such purpose(s).
  • The categories of third parties with whom we share your Personal
  • The categories of Personal Information we have sold, if any, about you and the categories of third parties to whom your Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
  • The specific pieces of Personal Information we have collected about

In addition, you may have the right to request that we delete your Personal Information.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in their Personal Information.

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their Personal Information that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information. If you are an End User that has directly opted into the App and Services, we may sell or share Personal Information collected from you and your vehicle with your Organization and other Organizations that may be of interest to you. To opt out of such selling and sharing, please submit a request using the “Your Privacy Choices” link at the bottom of our website.

Opting Out of Cookies and Sale/Sharing Using Online Tracking Technologies. Our use of online tracking technologies may be considered a “sale” / “sharing” under applicable law. Residents of certain U.S. states may have the right to opt out of being tracked by these third parties by clicking the “Your Privacy Choices” link at the bottom of our website and selecting your preferences.

If you do not have an account or if you are not logged into your account, your request to opt out of selling / sharing will be linked to your browser identifier only and not linked to any account information, because the connection between your browser and your account is not known to us.

Residents of certain U.S. states may opt out by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use the browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive Personal Information only for providing goods or services, or as otherwise minimally permitted under applicable law.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your Personal Information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.

  1. Additional Disclosures for Residents of Canada & Quebec Province, Canada

Right to Access. Residents of Canada have the right to know whether we collect, use, and disclose their Personal Information. If we collect your Personal Information, you may also request access to that Personal Information.

Right to Rectify. Residents of Canada have the right to request the correction or rectification of inaccurate or incomplete information in their Personal Information.

Privacy Officer. If you are a resident of Quebec Province, you may direct inquiries regarding your Personal Information to the following individual: President, Shane Wilson, privacy@connecteddealerservices.com.

6. INTERNATIONAL TRANSFERS

Any data that you provide to us may be accessed, shared, or processed by our offices located in the United States and our service providers located in the United States. This may entail the transfer of your Personal Information across international borders. International data protections standards may differ and be lower than the standards enforced in your jurisdiction.

7. CHILDREN’S PRIVACY

The App and websites are not directed at individuals under the age of 16. We do not knowingly collect Personal Information from children under 16. If you become aware that a child has provided us with Personal Information, please contact us using the contact details provided in the “Contact Information” section below. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information.

8. REQUESTS AFFECTING MULTIPLE END USERS

The Services, including the App, allow access for multiple End Users who jointly utilize, lease, or own the same vehicle and/or account. Upon receipt of a request from one End User to restrict or cancel the access of another End User on the same account, it is our policy to remove access for all End Users until proper lawful access can be determined, either by agreement of the parties or by entry of a court order from a court of competent jurisdiction determining the access rights of one or more affected End Users.

9. DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

10.  COOKIE POLICY

To make our websites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

Google Analytics. We use Google Analytics. We use the information we get from Google Analytics to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

Email Campaigns. We may also place cookies in our emails to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email and any URL accessed through our email message.

You may wish to restrict the use of cookies. Please be aware that some of the features of our website may not function correctly if you disable cookies.

Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We also use advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices.

Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

11.  CHANGE OF CONTROL

Personal Information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.

12.  DATA RETENTION

We may retain your Personal Information for a period of time consistent with the original purpose of collection or as long as required to fulfill our contractual or legal obligations. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of or access to such data.

13.  SECURITY PROTECTIONS

We implement a variety of security measures to maintain the safety of your Personal Information when you enter, submit, or access your Personal Information. For example, when possible, we use encryption to transfer and store data. We further limit access to this data using access controls and confidentiality commitments.

However, no website, application, or transmission can guarantee security. While we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of Personal Information obtained through the websites, we cannot ensure or warrant the security of any information you transmit to us.

14.  POLICY CHANGES

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on our websites. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.

15.  CONTACT INFORMATION

If you have questions or comments about this policy, you may email us at privacy@connecteddealerservices.com.