Privacy Policy

1. Introduction & Scope

Car Mom LLC (“The Car Mom”) provides digital content, tools, services and advisory offerings designed to help consumers research, evaluate, select and purchase vehicles and automotive-related products, including family-focused vehicle reviews, product recommendations, ratings, rankings, educational content, virtual consultations and shopping support services. In delivering these offerings, The Car Mom collects, analyzes and applies information to develop content, generate insights, support consumer decision-making and facilitate connections with relevant products, services and partners.

This Privacy Policy explains how we collect, use, disclose, share, publish, retain and protect Personal Information across our websites, applications, content platforms, community features, CRM systems, marketing channels and advisory services. It also describes how information may be transferred to third parties in connection with consumer requests, referrals, partnerships and marketing activities, and how such information is stored and maintained in accordance with our operational and legal requirements.

This Policy applies to:

Visitors to The Car Mom websites or The Car Mom-managed landing pages;

Consumers and automotive shoppers who engage with The Car Mom’s content, tools and services, including vehicle and product reviews, ratings, rankings, educational resources, personalized recommendations, virtual consultations, car shopping support, or who request information, guidance or connections to dealers, lenders or other partners through The Car Mom;

Dealers, lenders, OEMs and other business partners who receive consumer inquiries, referrals or click-through traffic from The Car Mom, or otherwise interact with The Car Mom in connection with facilitating vehicle transactions;

Service providers, analytics providers, advertising partners and other vendors that support The Car Mom’s operations, including communications, data processing and marketing services; and

Job applicants applying for roles with The Car Mom.

Depending on the context, The Car Mom may act as a Controller (for information we collect and use to operate our websites, tools and services) or as a Service Provider / Processor (when we process information on behalf of and under the direction of a partner in connection with your request or interaction with The Car Mom Services, such as facilitating communications with dealers, lenders or other partners). These roles are explained throughout this Policy.

Across all activities, The Car Mom follows core principles of transparency, purpose limitation, data minimization and safeguarding personal information, including limiting use of Personal Information to what is reasonably necessary to provide our services and support our business operations.

By using The Car Mom websites or services, or by requesting information, quotes or assistance through The Car Mom, you acknowledge that you have reviewed this Privacy Policy. If you have any questions, please contact us hello@TheCarMomOfficial.com.

2. Definitions

“Aggregated Data” Data combined into statistical or summary form that cannot identify any individual and that may be used by The Car Mom to develop insights, content, ratings, rankings or recommendations.

“Consumer” An individual who uses The Car Mom websites, applications or Services for personal, family or household purposes, including automotive shoppers who research vehicles, engage with content, reviews, recommendations or educational materials, request information or quotes, engage with dealers or partners, participate in consultations, or otherwise interact with The Car Mom content, tools or communications. A Consumer may provide Personal Information directly to The Car Mom or authorize The Car Mom to share such information with Customers or other third parties in connection with a Consumer’s request or interaction with The Car Mom Services.

“Customer” A dealer, dealer group, OEM, agency, lender, warranty provider, insurance provider or other business partner that receives consumer inquiries, referrals, introductions or click-through traffic from The Car Mom, or otherwise engages The Car Mom to support marketing, content, advisory or lead generation services, and controls the purposes for which Personal Information is processed once received.

“Customer Data” Information relating to a Customer or provided by or on behalf of a Customer, including inventory information, lead information, referral activity and other information provided by—or collected for—a Customer under its agreement with The Car Mom or in connection with consumer-initiated requests.

“Consultation Data” Information provided by a Consumer in connection with virtual consultations, vehicle selection support, product recommendations, transaction assistance or similar services, which may include preferences, household needs, budget considerations, prior purchase history or other contextual information used to provide personalized guidance.

“Controller” An entity that decides why and how Personal Information is processed.

“CRM Data” Lead and customer records stored in a Customer’s CRM system, including contact, communication, purchase and service information, as provided to The Car Mom or processed through Customer-authorized integrations and solely as permitted under the applicable agreement between Customer and The Car Mom. For clarity, CRM Data does not include Consumer data collected independently by The Car Mom unless and until such data is shared with a Customer.

“De-identified Data” Information that cannot reasonably be linked to an individual and is protected by safeguards against re-identification, and that may be used by The Car Mom to support analytics, content development, rankings, recommendations or service improvements.

“Marketing Segment Data” Audience segments, behavioral classifications or marketing attributes used to support campaigns, content personalization or partner marketing activities, where applicable and authorized.

“Expert Content” Reviews, recommendations, rankings, ratings, opinions and commentary created by The Car Mom or its contributors based on proprietary methodologies, editorial judgment, consumer inputs or Aggregated or De-identified Data, and which may incorporate User Content, Consultation Data or third-party information.

“Interaction Data” Behavioral signals collected through The Car Mom websites, social channels, applications, communications and marketing channels, including page views, clicks, scroll behavior, referral paths, click-through activity to third-party sites and engagement metrics, which may be used to measure performance, improve content and support recommendations or marketing activities.

“Inferences” Predictions or insights generated from Personal Information or Interaction Data, such as shopper intent, product preferences or potential vehicle interest, used to personalize content, recommendations or services.

“Tags or Pixels” Code-based tracking technologies and related functional elements, such as tags, scripts and pixels, deployed on The Car Mom-owned or operated digital properties or on partner websites where authorized, to collect Interaction Data and support analytics, content performance measurement, marketing and referral services.

“Personal Information” Information that identifies or can reasonably be linked to an individual.

“Service Provider / Processor” The role The Car Mom plays when processing Personal Information solely on behalf of and at the direction of a Customer, pursuant to a written agreement and/or documented instructions, and only for the purposes authorized by the Customer and permitted under applicable law.

“Sale or Sharing” Selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating a Consumer’s Personal Information to a third party for monetary or other valuable consideration, including through lead generation, referrals, affiliate relationships or marketing activities where such activity is deemed a “sale” or “sharing” under applicable law.

“Sensitive Personal Information” Categories defined by law, including precise geolocation, account access data, government-issued identifiers, financial account information or highly personal behavioral signals, which The Car Mom does not intentionally collect except as necessary to provide requested services.

“The Car Mom Services” The websites, applications, platforms, tools and services owned or operated by The Car Mom, including consumer-facing features such as content, reviews, recommendations, ratings, rankings, educational resources, virtual consultations, car shopping support, communications (including email, chat and SMS), community features, and referral or affiliate experiences, as well as any related content, functionality or integrations.

“Sub-Processor” A third-party service provider engaged by The Car Mom to process information on The Car Mom’s or a Customer’s behalf and only under The Car Mom’s written instruction.

“Third-Party Data” Data provided by external partners that may be combined with consumer data or used to support content, analytics, recommendations, attribution or service delivery, subject to contractual and legal restrictions.

“Unique Identifiers” Persistent identifiers such as hashed emails, cookie IDs, device IDs or similar technologies used for analytics, attribution or personalization.

“User Content” Reviews, comments, opinions, feedback, testimonials, survey responses, ratings or other materials submitted by Consumers, including content that may be published or displayed on The Car Mom platforms, and which may be used, reproduced or shared in accordance with this Privacy Policy.

3. How We Collect and Use Data

The Car Mom collects information in a few ways. We receive data you provide directly, information collected automatically through cookies and similar technologies on The Car Mom-owned pages, and information generated through your interactions with our content, communications, consultations and recommendations, as well as limited data supplied by Customers or collected through authorized partner integrations.

The Car Mom acts as a Controller when it determines the purposes and means of processing Personal Information, including for its websites, consumer-facing Services, content creation and publication, reviews and recommendations, consultations, CRM and marketing communications, analytics, limited data enrichment, attribution and product improvement activities. Additionally, in certain circumstances, The Car Mom may process Personal Information for its own business purposes, including developing proprietary content, insights, ratings and rankings, data enrichment, attribution, analytics and product improvement, in which case The Car Mom acts as a Controller.

The Car Mom acts as a Service Provider when we process Personal Information on behalf of a Customer in connection with referrals, lead generation, marketing support or other partner-directed activities, including limited CRM data or Interaction Data collected through Customer-authorized technologies, and we process that data only under the Customer’s instructions. The Car Mom does not independently use such data for its own marketing purposes while acting in this role. The Car Mom may use Sub-Processors to process information on The Car Mom’s or a Customer’s behalf.

This Section 3 describes the data The Car Mom collects as a Controller, the data it processes as a Service Provider under Customer instructions and the role of Sub-Processors in supporting those activities, including how information is used to support content, recommendations, consumer services and partner interactions.

Data We Collect Directly from You as a Controller

We collect Personal Information that you voluntarily provide when you use The Car Mom websites, applications or Services in our capacity as a Controller, including when you:

Create an account, subscribe to Services or sign up for newsletters, marketing communications or promotional offers

Request information, guidance or assistance, including vehicle research, product recommendations, consultations or car shopping support

Submit inquiries, communicate with us, or engage through forms, chat, SMS, social media or community features

Provide preferences, inputs or feedback, including vehicle criteria, household needs, surveys, polls or other submissions

Request to be connected with or learn more about dealers, lenders or other partners

Submit reviews, ratings, comments or other User Content, or otherwise participate in content or community features

Apply for employment or communicate with us in any other way

We also collect information about your interactions with The Car Mom Services, including your engagement with content, communications, recommendations and platform features.

We use this information in our capacity as a Controller to:

Provide, operate and improve The Car Mom Services, including content, reviews, recommendations, consultations and car shopping support

Respond to requests, provide customer support and facilitate consumer-directed connections with dealers, lenders or partners

Create, publish and distribute content, including User Content and Expert Content

Develop proprietary ratings, rankings, insights and recommendations relating to vehicles, automotive products and services

Personalize content, recommendations and advisory services based on your preferences and use cases

Operate CRM systems and send communications, including updates, product recommendations and promotional offers

Analyze usage, improve performance and enhance our content, tools and Services, including through Aggregated or De-identified Data

Maintain business operations, relationships and platform integrity

3.2 Data We Collect Indirectly from You as a Controller

We collect certain information automatically when you visit The Car Mom websites or interact with The Car Mom-managed pages, applications, tools or online services. This includes your interactions with content, reviews, recommendations, communications, and digital experiences, as well as click-through activity to third-party websites or partners.

This Section 3.2 outlines the information that we collect indirectly from you as a Controller.

We may also use Interaction Data to understand how users engage with content, reviews, recommendations and editorial materials, and to analyze performance, improve content relevance, refine ranking methodologies and enhance overall user experience.

3.2.1 Cookies and Similar Technologies

As a Controller, we use cookies, pixels, tags and similar technologies to understand how our websites, applications, tools and digital campaigns perform. These technologies may be deployed on The Car Mom Services and, in certain cases, in connection with advertising or referral activities involving third-party partners.

These technologies help us measure traffic, personalize experiences, facilitate referrals and click-through activity, and improve our Services, content and marketing effectiveness.

Interaction Data

When you interact with The Car Mom websites, The Car Mom-owned or managed social channels, The Car Mom-managed landing pages, applications, tools, communications or digital advertisements, we may collect certain Interaction Data, such as:

Page views and browsing paths;

Clicks on ads, links or navigational elements, including clicks that direct you to third-party websites or partners;

Referral sources showing how you arrived at our site;

Time spent on site, scroll behavior, dwell time and engagement patterns;

Device type, browser information and IP address; and,

Hashed identifiers used for analytics or attribution.

This Interaction Data may also include engagement with reviews, recommendations, editorial content, communications and other content features available through The Car Mom Services.

We use this information to understand how visitors use our pages, measure performance, analyze referral and engagement activity, and improve the relevance and effectiveness of our content and Services, including refining recommendations, rankings and overall user experience. We may also use this information to support consumer-directed referrals or connections to third-party partners based on your interactions with The Car Mom Services. For this data, The Car Mom acts as a Controller.

3.2.3 Log and Device Data

Log and device data is technical information automatically generated when you access The Car Mom websites or Services, such as IP address, browser type, device identifiers, operating system details, error logs, performance metrics and similar system-level information.

We use this information to maintain security, troubleshoot issues, monitor system performance, and improve reliability. The Car Mom collects only approximate location information based on IP address to support fraud detection, security, analytics and performance measurement. We do not collect or use precise geolocation in our capacity as a Controller.

Any collection of precise geolocation would occur only where explicitly enabled by you or where required to provide a specific requested service, and otherwise only where permitted by applicable law.

3.3 Data We Collect Through Customer-Authorized Integrations as a Service Provider

The Car Mom processes Customer Data that is provided directly by Customers or collected on their behalf through authorized integrations in limited circumstances and primarily in connection with referrals, lead generation, marketing support or other partner-directed activities. This may include CRM Data, referral or lead information, Interaction Data collected through Customer-authorized technologies, and data supplied through approved third-party integrations.

The Car Mom does not typically ingest or operate on dealer management system (DMS) data or complex data management platform (DMP) segments, except where expressly authorized and required under a specific Customer engagement.

In this role, The Car Mom uses Customer Data to operate and support the services contracted by each Customer and to facilitate consumer-directed interactions between Consumers and Customers. The Car Mom may generate Aggregated or De-identified Data derived from Customer Data and Customer-authorized measurement signals solely to support analytics, content performance insights and service improvements.

These non-identifiable outputs may be used solely in Aggregated or De-identified form to maintain and improve The Car Mom’s proprietary datasets, analytics models and platform features, including content performance insights, audience engagement trends and recommendation quality, and do not identify any individual Consumer or Customer.

This Section 3.3 provides further detail about specific processing activities—including limited CRM-related support, analytics, Interaction Data collection and the handling of third-party data, and The Car Mom does not use Customer Data for independent purposes outside the scope of the applicable Customer engagement.

3.4 Data We Receive from Third Parties

This Section 3.4 outlines how we use data received from third parties. We may receive information about vehicles, products, services, consumer interactions or referral activity from authorized third-party sources. These sources may include:

Analytics or measurement providers that help us understand engagement, performance and referral activity

OEMs, manufacturers or automotive program partners that provide vehicle information, specifications or related insights

Automotive data providers (such as DataOne, J.D. Power or similar partners) that provide vehicle specifications, pricing data, configuration details and market insights

Affiliate, marketplace or service partners that support consumer-requested services, such as insurance quotes, financing options, accessory purchases, vehicle valuations or other related offerings

Advertising or media partners that provide limited campaign performance or engagement information

We use this information to:

Support and enhance consumer-facing Services, including content, reviews, recommendations, ratings, rankings and related insight

Facilitate consumer-directed referrals, connections or requests involving third-party partners

Measure performance, engagement and referral activity, and improve the effectiveness of our content and Services

Develop Aggregated or De-identified Data used to improve content quality, recommendations, analytics and platform performance

Any information we receive from third parties is used only in the manner permitted under our agreements with such third-party data providers and applicable law.

We do not use third-party data to create independent consumer profiles across unrelated partners or for purposes inconsistent with this Privacy Policy.

When information is received directly from third-party providers and is used to support The Car Mom’s consumer-facing products, content, analytics or marketplace features, The Car Mom may act as a Controller with respect to such data where it determines the purposes and means of processing, subject to applicable law and contractual obligations.

3.5 How We Use the Data We Collect

This Section 3.5 provides additional detail about how we use the information collected across our products and services.

3.5.1 To Provide and Improve Products and Services

We use Personal Information, Consultation Data, User Content, Interaction Data and Aggregated or De-identified Data to deliver and improve our products and Services. This includes using information to:

Provide and enhance consumer-facing Services, including content, reviews, recommendations, ratings, rankings, educational resources, virtual consultations and car shopping support

Respond to Consumer inquiries, provide guidance and facilitate consumer-directed connections with dealers, lenders or other partner

Create, publish and distribute content, including User Content and Expert Content, in accordance with this Privacy Policy

Develop proprietary insights, recommendations, ratings and rankings relating to vehicles, automotive products and services based on consumer inputs, editorial judgment and aggregated trends

Personalize content, recommendations and advisory services based on Consumer preferences, use cases and interactions with The Car Mom Services

Measure engagement, analyze usage and improve the relevance, effectiveness and performance of our content, communications and Services

Operate, maintain, secure and improve our websites, tools and platform features

Detect, prevent and investigate fraud, misuse or unauthorized activity

We may also use Aggregated or De-identified Data, which does not identify you, to improve our content, recommendations and Services.

3.5.2 To Support Security, Compliance and Safety

We use certain information to protect the integrity of our platform, maintain compliance and ensure the security of Customer Data. This includes:

Detecting, preventing and investigating fraud, misuse or unauthorized access

Maintaining system reliability and performance

Monitoring for security threats or vulnerabilities

Meeting legal, regulatory or audit requirements

When this information includes Customer Data or Interaction Data collected through Customer-authorized integrations, The Car Mom processes it as a Service Provider.

When we use system-level logs or aggregated security data that cannot identify a consumer or Customer, The Car Mom acts as a Controller of that non-identifiable information.

3.5.3 To Communicate With You

We may use contact information you provide directly to The Car Mom to:

Respond to questions and support requests

Send updates about platform features, transactions or changes

Communicate in connection with your requests for information, quotes, referrals, car buying courses and/or related services

Share information about events, resources, products or special offers from our marketing partners

You may opt out of non-essential communications at any time.

For all direct communications, The Car Mom acts as a Controller of the information you provide.

3.5.4 How We Do Not Use Data

To provide additional clarity and transparency, we also explain how we do not use information:

We do not sell Personal Information in the traditional data broker sense, and we do not share Personal Information except as necessary to fulfill your request, support consumer-directed interactions with partners or as otherwise permitted under applicable law

We do not use Personal Information to create profiles about you across unrelated third-party services or partners

We do not use Personal Information obtained in connection with a specific partner interaction for independent purposes unrelated to that interaction

We do not use identifiable Personal Information to develop content, recommendations or insights where Aggregated or De-identified Data can be used instead

We do not collect or use precise geolocation information except where explicitly provided by you or required to deliver a specific requested service

We do not use Personal Information in ways that are inconsistent with this Privacy Policy or applicable law

We do not attempt to re-identify Aggregated or De-identified Data

These commitments help ensure that The Car Mom processes information responsibly, maintains user trust and remains aligned with applicable privacy laws.

3.5.8 SMS and Text Messaging Communications

The Car Mom may communicate with you via text message (SMS or MMS) in connection with your use of The Car Mom Services, including responding to inquiries, providing concierge or negotiation support, sending transaction-related updates or facilitating communications with dealers or other partners in connection with your request or interaction with The Car Mom Services.

By providing your mobile phone number and opting in, you consent to receive text messages from The Car Mom and, where applicable, from dealers, OEMs or other partners in connection with your request. Such messages may be sent using automated technology, where permitted by law, and may include informational, transactional or, where you have consented, promotional content.

Message frequency may vary depending on your interactions with The Car Mom Services. Message and data rates may apply.

You may opt out of receiving text messages from The Car Mom at any time by replying “STOP” to any message or by contacting us as described in Section 12. For assistance, reply “HELP” or contact us at hello@TheCarMomOfficial.com.

The Car Mom does not charge for text messaging services; however, your mobile carrier’s standard messaging and data rates may apply.

Third-party partners that communicate with you directly are responsible for their own messaging practices and must obtain any required consents in accordance with applicable law.

You may revoke consent to receive communications at any time using the methods described above or by contacting us.

3.6 Processing by Partners Acting Under Customer Instructions

The Car Mom may engage certain third-party partners to support services such as enrichment, identity resolution or technology integrations requested or authorized by a Customer. These activities occur solely under the Customer’s written agreement and documented instructions, and The Car Mom does not determine independent purposes for this processing.

All such partners act as service providers or Sub-Processors, and are bound by written agreements that:

Limit their use of data to the specific services requested by the Customer

Prohibit re-identification or combining The Car Mom-processed data with unrelated datasets or any attempt to reverse aggregation or de-identification

Restrict any secondary use, sale or sharing of the information

Require appropriate security, confidentiality and compliance safeguards in accordance with applicable laws

The Car Mom exercises reasonable oversight to ensure that Sub-Processors process information only as permitted under their agreements and the applicable Customer instructions, and maintain safeguards consistent with applicable privacy laws.

In addition, when The Car Mom shares Personal Information with third parties at the direction of a Consumer or Customer—such as dealers, lenders, insurance providers, warranty providers or other partners in connection with a request, referral or click-through interaction—those third parties may use such information in accordance with their own privacy policies and applicable law. In these circumstances, The Car Mom does not control and is not responsible for the independent use of Personal Information by such third parties after it has been disclosed.

The Car Mom may also share limited information with third-party partners that support consumer-facing features (such as insurance quotes, financing options or instant cash offers). These partners may use the information solely to provide the requested service, respond to the Consumer’s inquiry or complete a transaction, and are contractually restricted from using the information for unrelated purposes where required by applicable law.

In certain cases, The Car Mom may receive compensation or other consideration in connection with facilitating referrals, introductions or consumer-requested services. Such activities are conducted pursuant to contractual arrangements, at the direction of the Consumer or Customer where applicable, and consistent with the purposes disclosed in this Privacy Policy and applicable law.

4. Data Disclosures – How We Share Data

The Car Mom discloses information only in the circumstances described in Section 4 below. How we disclose data differs depending on whether we are acting as a Controller or a Service Provider / Processor.

4.1 Disclosures When The Car Mom Acts as a Controller

The Car Mom acts as a Controller for Personal Information it collects directly through its websites, content platforms and Services, including information you provide (such as reviews, ratings, comments, feedback and other User Content), Interaction Data, communications, requests for information or support, referrals, click-through activity, job applications and related operational data.

We may disclose this information as necessary to operate our Services, create, publish and distribute content (including User Content and related materials), provide recommendations and insights, facilitate consumer-directed interactions with third-party partners, and support the functions described below.

4.1.1 Sub-Processors or Service Providers Supporting The Car Mom Operations

We may disclose information to sub-processors or service providers who are under contract with The Car Mom to perform operations including website hosting, analytics, security, customer support, HR systems and cloud infrastructure. These partners are contractually restricted from using the information for their own purposes.

4.1.2 Marketing, Analytics and Measurement Partners

We may disclose Controller-collected data (such as website analytics, Interaction Data or campaign performance signals) to partners that help us:

Analyze site performance

Understand marketing effectiveness

Improve user experience

Deliver, measure or optimize advertising and referral activity or dealer performance

4.1.3 Legal, Compliance and Security Disclosures

The Car Mom may disclose Personal Information in its capacity as a Controller where necessary to comply with legal, regulatory or security obligations. These disclosures are limited to circumstances where The Car Mom has a good-faith belief that such action is required or appropriate under applicable law or to protect the integrity of The Car Mom Services.

This may include disclosures:

To comply with applicable laws, regulations, legal process or enforceable governmental requests (such as subpoenas, court orders or regulatory inquiries)

To establish, exercise or defend legal claims or rights

To investigate, prevent or take action regarding suspected fraud, misuse, unauthorized access or other illegal activity

To protect the rights, property or safety of The Car Mom, Consumers, Customers or the public

To enforce The Car Mom’s Terms of Use, contractual rights or other applicable agreements

In connection with corporate transactions, such as a merger, acquisition, financing, reorganization or sale of assets, where Personal Information may be disclosed as part of due diligence or transferred as part of the transaction, subject to appropriate safeguards

The Car Mom may also disclose Personal Information to service providers and advisors (such as legal counsel, auditors, security vendors or compliance consultants) that support these activities, provided that such parties are contractually required to maintain the confidentiality and security of the information and to use it only for the purposes described above.

4.1.4 Consumer Requests, Disclosures and Communications

When you provide information to The Car Mom, we collect and use that information as a Controller to deliver, manage and improve our Services, including content, reviews, recommendations, educational resources, virtual consultations and car shopping support. These Services are designed to help you research, evaluate and make informed decisions about vehicles and automotive-related products and services, including understanding your preferences, providing personalized recommendations and offering guidance based on your inputs and interactions.

In providing these Services, The Car Mom may use your information to respond to your inquiries, provide recommendations, and facilitate connections with dealers, lenders or other third-party partners at your request or based on your interaction with The Car Mom Services. Where you request information, referrals or assistance, we may share your Personal Information with relevant partners as necessary to fulfill that request or enable the requested interaction.

For example, this may include sharing information with dealers, lenders, insurance providers or other partners to respond to your inquiry, provide quotes or support a potential transaction. These parties act as independent businesses and may use your information in accordance with their own privacy policies and applicable law. The Car Mom does not control and is not responsible for the independent use of Personal Information by such third parties after it has been disclosed.

4.1.5 Limited Data Enrichment

In limited circumstances, The Car Mom may perform data enrichment, validation or attribution activities in its capacity as a Controller to support the accuracy, quality and performance of The Car Mom Services.

These activities may include:

Verifying or correcting contact information (such as email addresses, phone numbers or mailing addresses)

Appending missing or incomplete attributes (such as ZIP code or geographic data)

Matching or linking records to support attribution, measurement or performance analytics

To support these activities, The Car Mom may disclose limited Personal Information to third-party service providers or Sub-Processors that perform enrichment, identity resolution or attribution services on The Car Mom’s behalf. These parties are contractually restricted to using such information solely to provide services to The Car Mom and are prohibited from using the information for their own independent purposes.

Enriched or validated data may be used by The Car Mom to support its Services, analytics and platform functionality, and may be provided to the applicable Customer in connection with the Services. The Car Mom does not disclose such enriched data to other Customers or third parties for their independent use.

The Car Mom may also use Aggregated or De-identified Data derived from these activities to improve data quality, measurement accuracy, pricing insights, reviews and rankings, benchmarking and overall platform performance, subject to safeguards designed to prevent re-identification. The Car Mom does not use enrichment activities to create unrelated cross-partner consumer profiles or independent data-brokering products.

4.2 Disclosures When The Car Mom Acts as a Service Provider / Processor

This Section 4.2 describes how The Car Mom discloses data when acting as a Service Provider. The Car Mom may act as a Service Provider or Processor in limited circumstances when processing Personal Information on behalf of a business partner in connection with referrals, introductions or other consumer-directed interactions. In these cases, the business partner—not The Car Mom—determines the purposes for which the information is used once received. This section applies only where The Car Mom processes or discloses information under a valid agreement and for the limited purpose of facilitating the requested interaction or service.

The Car Mom does not independently use such information for its own marketing or business purposes while acting in this role, and does not use such information to build profiles across partners or for unrelated activities.

4.2.1 Disclosures to Sub-Processors Supporting Dealer, OEM or Related Services

At the Customer’s direction, The Car Mom may disclose Customer Data or Interaction Data to partners who support:

Campaign activation and measurement

CRM Enrichment

Identity matching

Attribution and reporting

Fraud detection

Secure data storage and compute services

These partners act as Sub-Processors and are contractually required to:

Use data only as instructed by The Car Mom or the Customer

Maintain appropriate safeguards

Not re-identify, attempt to re-identify or otherwise link de-identified or aggregated information to an individual

Not sell, share or use the information for their own independent purposes

Restrict secondary use and prevent combining the data with unrelated sources

Comply with applicable privacy and data protection

The Car Mom exercises reasonable oversight to ensure Sub-Processors follow these requirements.

Additionally, when we create aggregated or de-identified analytics, we apply technical and administrative steps designed to prevent the information from identifying any person. These steps can include hashing, removing identifiers, combining information into larger groups and testing whether any dataset could reasonably be re-identified. Where The Car Mom uses tools that incorporate automated or machine-assisted processing, such tools operate on behalf of The Car Mom and in accordance with this Privacy Policy.

4.2.2 Legal, Compliance and Safety Disclosures

We may disclose information when required by law, subject to informing the Customer when legally permissible.

4.2.3 Consumer Requests, Disclosures and Communications

When you request information, quotes, offers or assistance through The Car Mom Services, when you submit reviews or ratings, when you request information on a special offer or enter a promotion, or when you click through to or engage with a third-party partner, The Car Mom may disclose your Personal Information to dealers, lenders, insurance providers, warranty providers, accessories providers or other partners to facilitate your request or transaction.

These disclosures may occur through form submissions, lead routing, referral activity or click-through interactions. The receiving parties act as independent businesses and may use the information in accordance with their own privacy policies and applicable law. The Car Mom does not control, and is not responsible for, the independent use of Personal Information by such third parties after it has been disclosed.

Where required by applicable law, The Car Mom will obtain your express consent to permit The Car Mom and/or such partners to contact you regarding your request, including through calls, text messages or prerecorded or artificial voice communications. Such consent may include agreement to receive communications at the telephone number you provide, which may be made using automated telephone dialing systems or other automated technologies, where permitted by law.

For certain features—such as insurance quotes, financing options, accessories or instant cash offer services—The Car Mom may provide you with the ability to click through or be redirected to a third-party partner. In these cases, The Car Mom does not transfer Personal Information to the third party; instead, the third party collects information directly from you on its own website or service and processes that information in accordance with its own privacy policy.

In most cases, The Car Mom receives compensation or other consideration in connection with facilitating such referrals, introductions, clicks to third party sites or consumer-requested services. These activities are conducted pursuant to contractual arrangements and as part of fulfilling your request through The Car Mom Services, and are consistent with the purposes described in this Privacy Policy and applicable law.

4.2.4 No Independent Use

When The Car Mom acts as a Service Provider, The Car Mom does not:

Sell or share Consumer Data

Use Consumer Data for The Car Mom marketing

Build Consumer profiles

Use Consumer Data for any purpose not authorized by the Consumer

Disclose precise geolocation without written Consumer authorization

Allow re-identification of de-identified Consumer Data

4.3 Summary of Roles

Controller Disclosures: Apply only to information The Car Mom collects for its own business purposes, including consumer interactions, referrals, click-through activity and marketplace features.

Service Provider Disclosures: Apply only to Consumer Data processed under instructions.

5. Protection of Personal Data and Data Retention

The Car Mom uses reasonable administrative, technical and organizational safeguards designed to protect Personal Information against unauthorized access, loss or misuse. These measures are appropriate to the nature and sensitivity of the information we process.

We limit access to Personal Information to personnel and service providers who need it to perform their responsibilities and who are subject to confidentiality obligations. To support our operations and Services, The Car Mom may use third-party service providers and technology platforms, including customer relationship management systems, communications platforms, cloud hosting providers and related operational tools that help us store, organize, process and manage information on our behalf. We use commonly accepted security practices, such as encryption in transit and other safeguards, designed to help protect information.

We retain Personal Information only for as long as reasonably necessary to provide our Services, fulfill the purposes described in this Privacy Policy, comply with legal obligations, maintain business records or resolve disputes.

We may retain Aggregated or De-identified Data, which does not identify you, for longer periods to support analytics, content improvement and overall service performance. We do not attempt to re-identify such data.

The Car Mom designs its Services to use Personal Information only as reasonably necessary to provide content, recommendations, consultations and related functionality. In many cases, the scope of information processed depends on what you choose to provide or how you interact with The Car Mom Services.

6. Consumer Rights Under State Privacy Laws

This Section 6 outlines data rights that may be available to you. Certain state privacy laws—such as those in California, Colorado, Connecticut, Virginia and other jurisdictions—give consumers specific rights regarding their Personal Information. The Car Mom extends these rights to all U.S. consumers, regardless of residency, to the extent applicable to the Personal Information for which The Car Mom acts as a Controller and subject to applicable legal requirements and limitations.

Because The Car Mom processes different categories of information in different roles, the rights described in this section apply only to the data for which The Car Mom acts as a Controller, including information collected directly through The Car Mom Services, consumer interactions, ratings and reviews, referrals and click-through activity where The Car Mom determines the purposes and means of processing.

When The Car Mom processes Personal Information as a Service Provider or Processor—including Consumer Data collected through Customer-authorized integrations—The Car Mom acts solely under the Customer’s instructions. In those cases, consumer rights are governed by the dealer’s or OEM’s own privacy policy, and any requests relating to that information must be directed to the applicable Customer.

In addition, where you interact directly with a third-party partner (such as through a click-through or redirected experience), that third party may collect and control Personal Information independently of The Car Mom, and your rights with respect to that information must be exercised directly with that third party in accordance with its applicable privacy policy.

The Car Mom will assist you in fulfilling such requests when required by law, including by providing access to relevant data or facilitating request handling, but cannot modify or expand the rights that a Customer provides to its consumers under its own policies.

6.1.1 Right to Access

You may request access to the Personal Information that The Car Mom processes as a Controller, including the categories and specific pieces of Personal Information, subject to verification and applicable legal limitations.

6.1.2 Right to Deletion

You may request deletion of Personal Information that The Car Mom processes as a Controller, subject to legal exceptions, including where retention is required to complete transactions, comply with legal obligations, detect security incidents or otherwise permitted under applicable law.

6.1.3 Right to Correction

You may request correction of inaccurate Personal Information that The Car Mom maintains as a Controller, taking into account the nature of the Personal Information and the purposes of processing.

6.1.4 Right to Data Portability

You may request a portable copy of certain Personal Information that The Car Mom processes as a Controller, in a structured, commonly used and reasonably accessible format, to the extent required by applicable law. This right does not apply to Aggregated or De-identified Data.

6.1.5 Right to Opt-Out of Certain Processing

You may request that The Car Mom not use Controller-collected information for:

Targeted advertising

Profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable

Sales or “sharing” as defined by applicable law

The Car Mom does not sell or share Consumer Data in individualized, dis-aggregated form and does not use individualized Personal Information for The Car Mom marketing. The Car Mom may use Aggregated or De-identified Data to support marketing, analytics and the improvement of consumer-facing products and Services, as well as the products and services it provides to Consumers and its Customers, provided that such data cannot reasonably identify any Consumer or Customer.

Where The Car Mom engages in activities that may constitute “sale” or “sharing” of Personal Information under applicable law (such as certain advertising or referral-related activities), you may exercise your right to opt out as described in this Section.

6.1.6 Right to Limit Use of Sensitive Personal Information

If applicable, you may limit the use of Sensitive Personal Information, subject to applicable legal exceptions and permitted uses. The Car Mom does not use Sensitive Personal Information for purposes beyond what is reasonably necessary to provide requested Services, prevent fraud, ensure security or otherwise as permitted by applicable law.

6.1.7 Facebook/Meta Data Deletion

If you have connected with The Car Mom through Facebook, you may request deletion of personal information associated with that connection by emailing hello@TheCarMomOfficial.com. Please include your name, the email address associated with your request or account, and a note that you are requesting deletion of Facebook/Meta-connected data.

Upon receiving your request, The Car Mom will review and delete applicable personal information associated with your Facebook/Meta connection, subject to legal, security, transactional, operational, or recordkeeping obligations that may require limited retention. You may also remove The Car Mom’s access through your Facebook account settings under Apps and Websites.

6.2 How to Submit a Privacy Request

You may submit a privacy request by emailing us at hello@TheCarMomOfficial.com or by using our online request form at The Car Mom.com/privacy-request.

To protect your information, we will verify your identity before completing a request. Verification may include confirming your email address, requesting additional details or matching limited information against what we maintain.

We will respond within the timeframes required by applicable privacy laws.

6.3 Requests That Must Be Directed to a Customer or Third-Party Partner

Where you interact directly with a third-party partner (such as through a click-through or redirected experience from The Car Mom Services), that third party may collect Personal Information independently of The Car Mom. In such cases, The Car Mom does not control that information, and any rights requests must be directed to the applicable third party in accordance with its privacy policy.

6.4 De-Identified and Aggregated Data

The rights described in this section do not apply to:

Aggregated or De-identified Data

Aggregated analytics, insights, ratings, reviews or outputs derived from Personal Information

Data that cannot reasonably be linked to an identifiable Consumer or household

For an avoidance of a doubt, the Car Mom may use such Aggregated or De-identified Data to support analytics, product development, pricing insights, benchmarking, compilation of ratings and reviews, marketing and other business purposes, provided that such data does not identify any Consumer or Customer.

The Car Mom maintains technical, contractual and administrative controls to prevent re-identification of such information, and does not attempt to re-identify Aggregated or De-identified Data.

6.5 Appeals Process

If your request is denied, you may submit an appeal using the instructions included in our response. The Car Mom will review the appeal and respond within the timeframes required by applicable law.

6.6 Authorized Agents

Where permitted by law, you may designate an authorized agent to submit certain requests on your behalf. The Car Mom may require verification of both your identity and the agent’s authorization before fulfilling such requests.

7. Vendor and Transfer Disclosures

The Car Mom works with a limited number of Sub-Processors and service providers to support the functionality, security and delivery of The Car Mom Services. These partners assist with services such as cloud hosting, analytics, enrichment, identity resolution, campaign activation, secure data storage, technology infrastructure and platform operations.

All vendors that may process Personal Information on behalf of The Car Mom or a Customer are bound by written agreements that:

Limit their processing to the specific services The Car Mom or the Customer has authorized

Prohibit any secondary use, sale, sharing or re-identification of the information

Require appropriate administrative, technical and organizational safeguards

Restrict further disclosure unless permitted under contract and applicable law

The Car Mom conducts reasonable diligence and oversight of vendors supporting its Services. Vendors may process information only as instructed by The Car Mom and/or the applicable Customer, consistent with The Car Mom’s role as a Controller or Service Provider, as applicable.

Where vendors process Customer Data, CRM Data or Interaction Data under Customer instructions, such vendors act as Sub-Processors and are subject to the restrictions described in Section 4.2.

Where vendors support The Car Mom’s consumer-facing Services or internal operations, they act as service providers to The Car Mom and are not permitted to use Personal Information for their own independent purposes.

The Car Mom does not transfer Personal Information outside the United States or Canada, except where a service provider or Sub-Processor may process information on The Car Mom’s behalf in another jurisdiction subject to appropriate contractual safeguards and applicable law.

The Car Mom Services are intended for users located in the United States and Canada. The Car Mom does not knowingly collect Personal Information directly from individuals located outside these jurisdictions.

This section applies in addition to the disclosure and processing details outlined in Section 4.

8. Data Governance, Security and Oversight

This Section 8 describes the internal processes and safeguards that The Car Mom maintains to ensure that Personal Information is handled responsibly, securely and in accordance with applicable law.

8.1 Governance and Risk Management

The Car Mom maintains internal policies and procedures, and may use third-party service providers and technology platforms, that govern and support how data is accessed, stored, processed and retained. These measures may include controls relating to vendor management, access management, change management, risk assessment, data retention and incident response.

8.2 Security Safeguards

The Car Mom uses a combination of administrative, technical and physical safeguards appropriate to the nature and sensitivity of the information processed. These safeguards may include encryption during transmission, access controls based on business need, monitoring designed to identify unauthorized activity and secure hosting environments and technology platforms maintained by The Car Mom and reputable third-party service providers. The Car Mom periodically reviews its systems, practices and vendor relationships to help protect information and support the security of its Services.

8.3 Oversight of Sub-Processors

Partners who process information on The Car Mom’s behalf must agree to contractual restrictions requiring them to use information only as instructed, maintain appropriate safeguards and prohibit re-identification or secondary use. The Car Mom maintains reasonable oversight of these partners.

8.4 Product and Feature Review

New or materially updated features—including product or service updates or enhancements, automated engines, or any feature involving new data flows—undergo documented data-protection and privacy reviews prior to launch. These reviews evaluate whether the feature aligns with applicable privacy laws, Customer agreements and The Car Mom’s role as a Controller or Service Provider.

8.5 Access and Accountability

Access to Personal Information is limited to personnel with a legitimate business need. The Car Mom provides internal training on data protection requirements and maintains processes to oversee compliance with its policies and obligations.

8.6 Third Party Systems and Data Sources

The Car Mom Services may rely on third-party platforms, data providers and infrastructure, and Personal Information processed through such systems may be subject to those third parties’ security practices, protocols and data-handling standards. While The Car Mom imposes contractual safeguards where appropriate, The Car Mom does not control the independent systems or data practices of third parties, and such information is subject to their applicable terms, privacy policies and controls.

9. Cookies and Tracking Technologies

The Car Mom uses cookies, pixels and similar technologies to support the operation of our websites and to help our Customers measure the performance of their marketing activities, as well as to facilitate referral and click-through activity and improve The Car Mom Services. These technologies fall into two categories:

9.1 Tracking on The Car Mom Websites

When you visit a The Car Mom-owned website, we may use cookies and similar tools to:

Maintain site functionality

Understand how visitors use our pages

Measure traffic and performance

Improve the relevance and effectiveness of our content

Analyze referral sources and click-through activity to third-party partners

We may use analytics services to help us understand Aggregated or De-identified Data reflecting usage patterns. These technologies do not track activity across unrelated websites for cross-context behavioral advertising purposes, unless you have separately consented through your browser or platform settings or as otherwise permitted under applicable law. The Car Mom acts as a Controller for these tracking tools.

You may control cookies through your browser settings. Disabling certain cookies may affect the functionality of the site.

9.3 Third-Party Cookies and Integrations

The Car Mom websites and Customer-authorized integrations may use third-party technologies such as:

Analytics providers

Media platforms

Content delivery or hosting partners

These third parties may set their own cookies or tracking technologies through their integrations. Their collection and use of data are governed by their respective privacy policies, and The Car Mom does not control those independent data practices. This includes technologies used on Customer websites or data collected directly by third parties through click-through or redirected experiences.

Where The Car Mom acts as a Controller, we support and implement consent signals and user preference settings in connection with third-party platforms, including Google and similar advertising or analytics providers. We configure our use of such technologies to respect applicable consent choices communicated through cookie banners, browser settings or other recognized preference signals, including signals indicating a preference to opt out of the sale or sharing of Personal Information, where required by applicable law.

For third-party platforms such as Google, additional controls may be available directly through those platforms. You may learn more about how Google uses data and manage your preferences by visiting:

https://www.google.com/policies/privacy/partners/

https://adssettings.google.com

9.4 Choices and Controls

You may manage cookies and tracking technologies through:

Your browser settings

Platform-specific opt-outs (Google, Meta, Amazon Ads and others)

Device-based privacy controls

Where required by applicable law, The Car Mom will honor user-enabled privacy preference signals, including signals indicating a preference to opt out of the sale or sharing of Personal Information, to the extent such signals apply to The Car Mom’s processing as a Controller.

For Customer websites, any choices regarding cookie banners, opt-outs or consent mechanisms are governed by the Customer’s own privacy policy, and The Car Mom will honor the Customer’s instructions regarding consent, opt-outs or preference signals.

9.5 Do Not Sell or Share My Personal Information (All Users)

The Car Mom offers a “Do Not Sell or Share” option to all users.

When The Car Mom acts as a Controller, you may request that we limit the use of your information for activities that some laws define as selling or sharing, including certain advertising, analytics or referral-related activities that may involve disclosure of Personal Information to third parties. The Car Mom does not sell Personal Information for monetary consideration in the traditional data broker context.

The Car Mom may disclose Personal Information in connection with consumer-directed requests, lead generation activities or referrals to dealers, OEMs or partners, and may receive compensation or other consideration in connection with such activities. These disclosures may be considered “sharing” or, in certain jurisdictions, a “sale” of Personal Information under applicable law, and you may opt out of such activities as described in this Section.

When The Car Mom acts as a Service Provider / Processor, we process data only under the Customer’s instructions.

We do not sell or share Consumer Data, Personal Information or CRM Data

Requests relating to Customer-collected information must be directed to the Customer

We support Customers in fulfilling such requests when required

Except as expressly permitted under applicable agreements with Customers and where The Car Mom has obtained contractual rights to use Customer Data for independent purposes, The Car Mom may use such data solely in its capacity as a Controller and in accordance with this Privacy Policy and applicable law

The Car Mom’s use of Aggregated or De-identified Data is not considered a sale or sharing of Personal Information and is not subject to opt-out rights where such data cannot reasonably identify a Consumer or Customer.

How to Submit a “Do Not Sell or Share” Request:

If you wish to submit a request for the information The Car Mom controls directly, you may:

Complete our online request form: The Car Mom.com/privacy-request

Email us at: hello@TheCarMomOfficial.com

Where required by applicable law, The Car Mom will also honor browser-based or device-based opt-out preference signals, including signals indicating a preference to opt out of the sale or sharing of Personal Information, to the extent such signals apply to The Car Mom’s processing as a Controller.

Requests submitted to The Car Mom apply only to information The Car Mom controls directly. If a request involves information originally collected by a dealer, OEM, partner or agency, or information collected directly by a third-party partner through a click-through or redirected experience, we will direct you to the appropriate Customer or third party.

10. Children’s Privacy

Our services are not intended for children under 16 and we do not knowingly collect their Personal Information. If we learn that information was collected from a child under 16 without required consent, we will delete it as required by law. If you believe a child has provided information to The Car Mom, please contact us using the information in Section 12.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies or legal requirements. When we make material changes, we will post the updated policy on this page and adjust the “Last Updated” date at the top of the policy. We may also provide additional notice if required by law. Your continued use of the The Car Mom Services after changes are posted means you acknowledge the updated policy.

12. Contact Information

If you have questions about this Privacy Policy, our data practices or your privacy rights, you may contact us at: hello@TheCarMomOfficial.com Address: 211 W. St. Louis Street Suite 37, Pacific, MO 63069, USA

If your request relates to Personal Information collected directly by a third-party partner (such as through a click-through or redirected experience), we may direct you to the applicable third party, which acts as an independent controller of that information.

13. Additional Disclosures for Residents of Certain States

Some state privacy laws, including those in California, Colorado, Connecticut, Virginia and other jurisdictions, require businesses to provide additional disclosures. The Car Mom extends these rights to all users to the extent applicable to the Personal Information for which The Car Mom acts as a Controller, as described in Sections 6 and 9.5.

Residents of states with specific statutory rights may contact us using the information in Section 12 to exercise their rights or submit a request through any web form that The Car Mom may make available for this purpose. Certain requests may require identity verification. Requests related to Personal Information collected directly by third-party partners (such as through click-through or redirected experiences) must be directed to the applicable third party.

14. Metrics, Reporting and Automated Decision-Making Disclosures (If Required by Law)

Where required by applicable state privacy laws, The Car Mom will provide information about:

The categories of Personal Information The Car Mom collects and processes as a Controller in the last 12 months

The categories of Personal Information The Car Mom discloses as a Controller for business purposes, including disclosures to service providers and, where applicable, third parties involved in consumer-directed requests or referrals

High-level descriptions of any automated decision-making, rating or ranking logic in The Car Mom recommendation features, including how such systems use Aggregated or De-identified Data to generate insights

Where The Car Mom uses automated or Data-driven systems to determine rankings, ratings or reviews, such systems are designed to operate on Aggregated or De-identified Data or Customer-authorized inputs, and are subject to internal governance, testing and validation processes.

Additional information may be made available through compliance reports or documentation upon request where legally mandated, subject to applicable legal limitations and verification requirements.

15. Accessibility

The Car Mom is committed to making this Privacy Policy accessible. If you need this policy in an alternative format or require assistance to review the information, please contact us using the details in Section 12.

16. Summary of Personal Information Practices (California Disclosure)

The table below summarizes the Personal Information The Car Mom collects as a Controller, how we use it and whether it is disclosed, sold or shared under the CCPA/CPRA; information processed as a Service Provider is governed by each Customer’s own privacy policy.

Category of Personal Information | Examples | Purpose of Use | Disclosure | Sold or Shared?

Identifiers | IP address, device identifiers, contact information you submit directly to The Car Mom | Site functionality, analytics, responding to requests, facilitating consumer inquiries, referrals and connections to dealers or partners | Service providers (analytics, hosting), OEMs, dealers or partners in connection with your request or interaction with The Car Mom Services | May be disclosed for consideration in connection with consumer-directed lead generation or referral activities; may be considered “sharing” under applicable law

Internet/Interaction Data | Browsing paths, clicks, session data on The Car Mom owned websites | Site operation, analytics, platform improvement, measuring referral activity and engagement with third-party partners | Hosting and analytics providers, advertising or measurement partners | May be considered “sharing” for cross-context behavioral advertising or monetized referral activity under applicable law

Commercial Information | Demos or service requests, consumer inquiries, vehicle interest, pricing or negotiation requests | Responding to inquiries, requests and customer support, facilitating transactions, pricing insights, negotiation support and marketplace features | Service providers supporting communications, dealers, OEMs or partners in connection with your request or interaction with The Car Mom Services | May be disclosed in connection with consumer-directed requests or transactions; not sold except as described in this Policy

Geolocation (approximate) | IP-derived region | Fraud detection, localization, analytics and performance measurement | Service providers | No

Sensitive Personal Information | Not intentionally collected by The Car Mom as a Controller | If collected, used only as reasonably necessary to provide requested Services, prevent fraud or comply with legal obligations | Service providers or partners only as necessary to fulfill requested services and subject to contractual restrictions | No

Aggregated or De-Identified Data | Analytics not reasonably linkable to an individual or Customer | Improving model performance, product features, pricing insights, product ratings, reviews and rankings, benchmarking and Data-driven functionality | May be shared in Aggregated or De-identified form | Not Personal Information; not subject to sale or sharing restrictions where it cannot reasonably identify a Consumer or Customer

Retention:

The Car Mom retains Personal Information only for as long as necessary to provide the Services, facilitate consumer-directed requests, referrals or transactions, meet legal requirements, resolve disputes, enforce applicable agreements, or as otherwise permitted under Customer agreements and applicable law.

Customer Data, CRM Data and Interaction Data processed as a Service Provider are retained, returned or deleted in accordance with the applicable Customer’s written instructions, contractual requirements and applicable law.

Aggregated or De-identified Data that cannot reasonably identify a Consumer or Customer may be retained for longer periods to support analytics, product development, pricing insights, benchmarking, Data-driven functionality and system performance, subject to safeguards designed to prevent re-identification.

Where Personal Information is collected directly by third-party partners (such as through click-through or redirected experiences), retention of such information is governed by the applicable third party’s privacy policy.

Service Provider Processing:

When The Car Mom processes CRM Data, Customer Data or Interaction Data under a dealer, OEM or agency’s instructions, The Car Mom acts solely as a Service Provider, processes such information only in accordance with the applicable Customer’s documented instructions and written agreement, and does not sell or share such data or use it for The Car Mom’s own independent marketing or business purposes.