Privacy Policy

English
|This statement is effective as of October 1, 2023.

Introduction

We respect the privacy of our users when they use our websites,
mobile and other applications, and products and services (collectively, the
“Sites”). By using the Sites, you consent to the use of your information and
information about you in accordance with this Privacy Statement. This Privacy
Statement applies to information collected through the Sites and does not
describe the collection, use and disclosure practices of any of our corporate
affiliates or third parties. The Sites utilize information from corporate
affiliates, third parties, and publicly available vehicle information. For
information on the collection, use and disclosure practices of any company with
whom you are doing business, whether or not affiliated with Central Dispatch,
please review their privacy policies.

Central Dispatch is a business-to-business vehicle logistics
marketplace accessible to buyers and sellers of vehicles at wholesale, dealers,
and to their duly authorized agents and representatives. Our Service is not
intended for consumers. Services offered by the Sites are not directed to
individuals under the age of eighteen (18). If you are under eighteen (18),
you should not provide any personal information to us.

This
Privacy Statement covers:

The
Information We Collect

Information is gathered from the Sites by us, our service
providers, advertisers, sponsors and partners.

Information You Provide.We may collect
information that you choose to provide on the Site in a variety of ways, which
may include your name, address, telephone number, location, email address,
dealer or company name, AuctionACCESS number(s), the last four digits of your
social security number or other valid government-issued identification number
and bank account, payment and other financial information, such as when you:

1. Register
for one of our products or services;

2. Download
or use one of our applications;

3. Provide
payment information or authorize electronic ACH transfers or other payments;

4. Make
information available to us via social networking logins;

5. Participate
in chats, web forums or other interactive sessions;

6. Subscribe
to newsletters or provide feedback; and

7. Participate
in surveys, sweepstakes or other promotions.

Automated Information.Information
regarding your use of the Sites may be collected and/or aggregated through the
use of automated means. This automatically collected information may include
information such as:

1. Your
IP address, the type of browser, and operating system used;

2. Date
and time you access the Sites and pages you visit, and if you linked from or to
another website, the address of that website;

3. Emails
you open and links you click on within those emails;

4. Your
location; and

5. Your
ISP or mobile carrier, and the type of handheld or mobile device that you used.

Data Technologies.Various technologies
are used to automatically collect information, such as cookies, pixels, local
shared objects, and web beacons (generally referred to as “Data Technologies.”)
“Cookies” are small identifiers sent from a web server that are stored on your
device for the purpose of identifying your browser or storing information or
settings in your browser. “Local shared objects,” sometimes known as Flash
cookies, may be used to store your preferences or display content based upon
what you have viewed on various websites to personalize your visit. A “web
beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages
to web servers and their cookies. Anonymous advertising identifiers are
increasingly being used on mobile devices and otherwise in a manner similar to
cookies. When we refer to Data Technologies, we are including all current and
similar future technologies.

One or more Data Technologies may be used on the Sites and other
websites and mobile applications (that may not be the Sites) by us, by another
party on our behalf, or by third parties in accordance with their privacy
policies. Data Technologies may be used by us and others, on our behalf and on
their own behalf, to transmit information to you or about you and connect
information about you from different sources, websites, devices, and mobile
applications.

We may use a uniquely generated trackable toll-free telephone
number on the Sites or in advertisements. If you call one of these uniquely
generated toll-free numbers, we (or a service provider acting on our behalf)
may collect non-personally identifiable information about the call (e.g., date,
time, duration), as well as personally identifiable information (e.g., your
name, the number from which your call originated).

Biometric Information. Some of our
applications and Sites are accessible by devices that have the capability of
using biometric access credentials, such as a fingerprint, thumbprint, or face
scan. We do not actually receive, collect, use, or store any this biometric
information from your device.

Camera
Information. Some of our applications require that you use your device’s
camera. If so, you must activate the settings on your device. We may collect photos
and other data when your camera is used in connection with our Sites or
Services.

Location Information.We may collect
GPS and physical location information that is sufficiently precise to allow us
to locate a specific person or device (“Location Information”). We only collect
Location Information with your consent (e.g., such as when you agree to use or
download an application or use a Site). We may use Location Information and
provide it to shippers (if applicable), and/or to third parties to provide you
with content and services that are relevant to a particular location, such as
advertising, search results, auctions in the area, and directions.

Publicly Posted Information.Information
that you make available to us and others via social media networks, forums,
blogs, list serves, chat rooms or similar functionality is public information
that we or others may share or use in accordance with the law.

Combined Information and Information from Other Sources.We
may combine information that you provide to us with information we receive from
our affiliates and other sources, as well as with other information that is
automatically collected. The combined information may include information about
your use of the Sites, your use of other websites, devices and mobile
applications and information from our affiliates and other sources.

How
We May Use the Information We Collect

We may use information we collect for the following purposes:

For
everyday business purposes, such as establishing and managing your user
account, providing products and services you request, and providing customer
support;
To
offer our other products or services and/or the products or services of others
to you;
To communicate about, and administer your participation in, special events, programs, surveys, contests, sweepstakes and other offers or promotions;
To enable you to interact with the Sites and our users, dealers, and others through various means, such as through our message boards, blogs and social media;
To evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications and websites;
To diagnose and address technical and service problems;
To perform data analyses, including market and consumer research, trend analysis, demographic analysis and financial analysis;
To deliver content (including advertising) correlating to your interests and browsing and usage history, both within the Sites and on other websites and applications;
To comply with applicable legal requirements and our policies
To provide vehicle sale and location information, transaction data and other information and material to third parties directly involved in vehicle sales, transportation, or logistics;
To help sellers understand buyers’ preferences for inventory and services; and
To contact you via telephone, text or chat (and by using the Site and agreeing to the Terms of Use, you agree to be contacted by Central Dispatch by telephone, text or chat at any number or other contact information that you may provide or make available on or through the Site).

Applications, Widgets and Social Media

We may include applications or widgets from social media
providers that allow interaction or content sharing by their users. These
widgets, such as a Facebook “Share” or “Like” button, are visible to you on the
web page you visit. Integration between the Sites and social media networks may
allow social media networks in which you participate to collect information
about you, even when you do not explicitly activate the network’s application
or widget. Please visit the applicable social media network’s privacy policy to
better understand their data collection practices and choices they make
available to you.The privacy policy of the social media network controls
the collection, use and disclosure of all personal information transmitted to
that network.

Advertising Networks

Advertising that is customized based on predictions generated
over time from your visits across different websites, devices and mobile
applications is sometimes called “online behavioral” or “interest-based”
advertising. We may partner with advertising networks, which are companies that
deliver targeted advertisements to consumers and generate statistics and
metrics related to the delivery of interest-based advertisements. They may
utilize information collected through a variety of Data Technologies to provide
customization, auditing, research and reporting for us, our affiliates and
other advertisers. This data collection takes place both on the Sites and on
third-party’s websites and mobile applications. This process allows the Sites
and third parties to deliver targeted advertising, enhance marketing programs
and help track the effectiveness of such efforts. Our advertising networks also
may use this information for determining or predicting the characteristics and
preferences of their respective advertising audiences and measuring the
effectiveness of their advertising in accordance with their privacy policies.

We do not provide information that is directly associated with a
specific person (such as name and address) to an advertising network when you
interact with or view a customized advertisement. However, when you view or
interact with an advertisement, the advertiser may make an assumption that you
are interested in the subject matter of the advertisement.

Some companies disclose when they are using interest-based
advertising programs on the Sites to deliver third-party ads or collecting
information about your visit for these purposes and give you the ability to
opt-out of this use of your information. You may see an icon in or around
third-party advertisements on the Sites that use interest-based advertising
programs and on pages where data is collected and used for online
interest-based advertising. Clicking on this icon will provide additional
information about the companies and data practices that were used to deliver
the ad. You can opt out of delivery of targeted advertising to you by multiple
companies by visiting

www.aboutads.info/choices
,

www.networkadvertising.org/managing/opt_out.asp
and

www.ghosteryenterprise.com
.

Please note that even if you opt out, you will continue to receive
advertisements, but they will not be tailored to your specific interests.

Information We Share

We do not sell or otherwise share information about you that we
collect or receive, except as described below:

1.Affiliates,
Dealers, Shippers, Franchisors and Manufacturers.Information
collected, including personal information and Data Technologies, may be shared
with affiliates, dealers, shippers, franchisors and manufacturers, and
theiragents and third-party service providers, who will use that
information in accordance with their own privacy policies. Please visitwww.CoxAutoInc.comfor
more information about our affiliates.

2.Our
Service Providers.We may engage third parties to provide the services
offered through or in connection with the Sites on our behalf. We require such
providers to maintain information aboutyou as confidential and to use the
information only to perform the services specified by us in a manner consistent
with this Privacy Statement.

3.Corporate
and Asset Transactions.If we sell all or
substantially all of our business or sell or transfer all or a material part of
our assets, or are otherwise involved in a merger or transfer of all or a
substantial part of our business (including any sale or transfer that may take
place as part of or in connection with any bankruptcy or insolvency
proceeding), we may transfer all information we have collected and stored,
including personalinformation, to the party or parties involved in the
transaction as part of that transaction.

4.Access
to Databases. In addition to all of the disclosures described above, we may
also allow others to search some of our databases and to analyze the data they
find there or aggregate it with other data, either for their business purposes
or ours.

5.AuctionACCESS
Information.We may also collect your AuctionACCESS number and use it
to link your registration information with the information maintained by
AutoTec, LLC in your AuctionACCESS membership profile. To create an
AuctionACCESS profile and learn more about what types of information AutoTec,
LLC collects about its members and discloses to Manheim and other wholesale
auction operators, please visithttps://www.auctionaccess.com.
AutoTec, LLC is not affiliated with Central Dispatch and collects information
about its members under its separate privacy policy using processes that we
don’t control. Supplying registration information is voluntary; however, users
who don’t supply the information necessary to register for the Service may not
be able to take advantage of the majority of features and content available
through the Service.

6.Other.We
may access or disclose information, including personal information, to:

1. Protect
or defend our interests and the legal rights or property of Central Dispatch
and our affiliates;

2. Protect
the rights, interests, safety and security of users of the Sites or members of
the public;

3. Protect
against fraud or for risk management purposes; or

4. Comply
with prudent legal practice as we may determine, and applicable law or legal
process.

Your
Choices

You are entitled to make certain choices about how we
communicate with you.

1. You
may choose not to provide personal information, even though that might impact
your ability to register or open an account on the Sites or receive a
particular product or service.

2. If
you do not want to receive marketing email from the Sites, you can follow the
unsubscribe link provided in those emails.

3. If
you do not want to receive interest-based advertisements, you can opt out as
discussed in the “Advertising Networks” section above.

4. You
have a number of choices regarding certain Data Technologies. Most web browsers
automatically accept cookies, but you can usually modify your browser’s setting
to decline cookies if you prefer. You may also render some web beacons unusable
by rejecting their associated cookies and disable or delete similar data used
by browser add-ons, such as Flash cookies, by changing the add-on’s settings or
opting out at Ghosteryenterprise.com or the website of the technology provider.
If you choose to decline cookies or similar technologies, however, please note
that certain features on the Sites may not function properly or at all as a
result. You may be able to adjust the use of advertising identifiers on mobile
devices through the settings on your device. Finally, if you do not want to use
a uniquely generated telephone number, you may choose to not call us.

5. If
you do not want us to use Location Information, you can decline our initial invitation
to provide that information or opt out by changing the location services
settings on your mobile device. However, please note that certain applications
require Location Information and some features may not function properly or at
all as a result if you opt out.

Data
Transfers

We may transfer the personal information we collect about you to
countries other than the country in which the information originally was
collected. Those countries may not have the same data protection laws as the
country in which you initially provided the information.

Links

The Sites may contain links to websites not operated by us, as
well as third party widgets and applications discussed above. Once you leave
the Sites, we suggest that you review the applicable privacy policy of the
third-party website or application. We are not responsible for the content or
use of any websites or applications other than on the Sites or the privacy
practices of those websites or applications.

Data
Security

We use commercially reasonable administrative, technical,
personnel, and physical security measures designed to safeguard information
about you in our possession against loss, theft and unauthorized use,
disclosure or modification. Of course, despite these measures, we cannot
guarantee perfect security of networks, servers and databases we operate or
that are operated on our behalf.

Disputes

If you choose to visit the Sites, your visit and any dispute
regarding privacy is subject to this Privacy Statement and the Visitor
Agreement or Terms of Use applicable to each Site, including limitations of
liability, arbitration and dispute resolution provisions and provisions
relating to governing law or jurisdiction or venue that may be included in any
of the foregoing.

Updates
to this Privacy Statement

We may update this Privacy Statement to provide clarification or
notice of changes to our practices. We will provide you with notice of material
changes by posting notice of the changes on the Site, or by providing you with
notice by email or when you log into your account on the Site. By using our
Sites on or after the effective date of any such amendment, you agree that your
use, and any dispute over privacy, is governed by this Privacy Statement, as
amended.

How
to Contact Us

If you have any questions or comments about this Privacy
Statement, or if you would like us to update information we have about you or
your preferences, please contact us by email atprivacy@coxautoinc.com.

YOUR
CALIFORNIA PRIVACY RIGHTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the
information contained in the Privacy Statement of Central Dispatch and its
subsidiaries (collectively, “we,” “us,” or “our”), a Cox Automotive, Inc.
company, and applies solely to consumers who reside in the State of California
(“consumers” or “you”). We adopt this notice to comply with the California
Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.
Any terms defined in the CCPA have the same meaning when used in this notice.

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 an individual consumer, household, or device (“personal
information”). We have collected the following categories of personal
information from consumers within the last twelve (12) months:

The following examples are taken directly from California
Consumer Privacy Act, (Central Dispatch) collects at least one of the example
items from each category.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

We obtain the categories of personal information listed above
from the following categories of sources:

Directly
from our customers or their agents. For example, from documents that our
clients provide to us related to the services for which they engage us.
Indirectly
from our clients or their agents. 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 (www.CentralDispatch.com). For
example, from submissions through our website portal or website usage
details collected automatically.
From
third-parties that interact with us in connection with the services we
perform.

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
California Customer Records personal information categories.

Category
DCommercial
information.
Category
F
Internet or other similar network activity.

Category G: Geolocation data.

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

Our
affiliates, dealers, shippers, franchisors and manufacturers
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.

In the preceding twelve (12) months, we have not sold any
personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights
regarding their personal information. This section describes your CCPA rights
and explains how to exercise those rights.

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.

California Civil Code Section 1798.83 entitles California users
to request information concerning whether a business has disclosed certain
information about you to any third parties for the third parties’ direct
marketing purposes. California users who wish to request further information in
compliance with this law or have questions or concerns about our privacy
practices and policies may contact us as specified in the “How to Contact Us”
section below.

Deletion Request Rights

You have the right to request that we delete any of your
personal information that we collected about you and retained, subject to
certain exceptions in the CCPA. Once we receive and confirm your verifiable
consumer request, we will delete your personal information from our records,
unless an exception applies, and we will direct our service providers to
similarly delete your personal information from their records.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights
described above, please submit a “verifiable consumer request” (defined below)
to us by either:

Calling
us at 800-928-7869
Visiting
Centraldispatch.com

Only you or someone you authorized 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.

A verifiable consumer request must:

Provide
enough information that allows us to reasonably verify you are the person
about whom we collected personal information or an authorized
representative; and
Describe
your request with enough detail that allows us to properly understand,
evaluate, and respond to it.

You may only make a verifiable consumer request for access or
data portability twice within a 12-month period.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your
CCPA rights. Unless permitted by the CCPA, 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, or suggest that you may
receive a different price or rate for goods or services or a different level or
quality of goods or services.

Do Not Track

Online Tracking Policy for California Residents. As of the
effective date of this Privacy Statement, there is no commonly accepted
response for Do Not Track signals initiated by browsers, therefore we do not
respond to them.

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 California law, please do not hesitate to contact us at:

Website: Centraldispatch.com

Email: privacy@coxautoinc.com

Postal Address: Cox Automotive, Inc.
Attn: Chief Compliance & Privacy Officer
6205 Peachtree Dunwoody Rd. NE
Atlanta, Ga 30328