Foureyes, LLC Privacy Policy

Foureyes, LLC and its subsidiaries and affiliates (collectively, “Foureyes”, “we”, “us”, and “our”) are committed to respecting the privacy and confidentiality of personal information. Please read this Privacy Policy (“Privacy Policy”) carefully. It provides information about how Foureyes

collects, uses, discloses, and otherwise processes personal information. By visiting, accessing, or using any of our Services (defined below), you acknowledge and agree that you have received and reviewed this Privacy Policy. From time to time, we may update this Privacy Policy as described in the Changes to this Privacy Policy section below. If you have any questions, comments, or concerns please Contact Us.

1. Scope of This Privacy Policy

(a) The Foureyes Services. This Privacy Policy applies to personal information that Foureyes collects, uses, discloses, and otherwise processes when you:

• Access or use our website available at Foureyes.io, the Foureyes blog, the Foureyes help center, or any other website operated or made available by Foureyes where this Privacy Policy is posted (collectively, the “Website”);
• Access or use the Foureyes platform and tools (such as Foureyes’ analytics and reporting system and/or Foureyes’ customer communications hosted system) (collectively, the “Tool”) and any related products, services or functionality we make available through the Website; or
• Communicate with us through any written, electronic, or oral communications, including by email, text message, or phone, such as through events or marketing communications.

For purposes of this Privacy Policy, we refer to our Website, Tool, and any other online service we provide that links to this Privacy Policy as the “Services.”

This Privacy Policy applies to:

• Visitors to the Website and any individuals associated with our customers or prospective customers who communicate with or receive communications from Foureyes; and
• Foureyes’ auto dealer and dealer or automotive group customers (“Foureyes Customer(s)”) and their Authorized Users (defined below) who have registered for or created an account with Foureyes.

(b) Authorized Users and Customer Content. We provide the Tool to our Foureyes Customers under our agreement with them and solely for their benefit and the benefit of the personnel or other individuals that they authorize to use the Tool (“Authorized Users”). We are data processors of the data or other content that our Foureyes Customers and their Authorized Users input, upload, submit or otherwise make available to or through the Tool and any other data we may process on their behalf (collectively, “Customer Content”). Our processing of such data is governed by our agreement with the Foureyes Customer, and the Foureyes Customer is responsible for the collection and use of such Customer Content.

(c) Out of Scope. This Privacy Policy does not apply to individual consumers who are customers or prospective customers of any Foureyes Customer that uses the Foureyes Tool or Services. If you are a customer of any Foureyes Customer that uses the Foureyes Tool or Services, please see the Dealer Privacy Policy Supplement for information about how your personal information is processed through the Foureyes Tool or Services on behalf of the Foureyes Customer of Foureyes.

This Privacy Policy does not apply to External Websites. Please see the Third Party Links section of this Privacy Policy below.

2. Personal Information We Collect and How. As used in this Privacy Policy, “personal information” means any information that identifies or could be used to identify an individual person. For example, personal information may include name, email address, and IP address, or other unique identifier. It also includes other non-public information that we associate with such identifying information. Personal information does not include aggregated or anonymized information. The personal information we collect and how we collect it depends on how you use the Services. We collect the following types of personal information, as described below.

(a) Information You Provide. We collect personal information that you provide directly to us when you access or use the Services or when you interact with us. We collect information that you provide to us in the following ways:

1. Identity and contact information. We collect information such as your name, business email address, and business phone number if you communicate with us or register for an account to use the Services.
2. Registration and account information. If you register or create an account to use the Services, Foureyes collects personal information to set up and manage your account, such as identity and contact information, professional information, and profile information. For example, this may include your company, job title, account login credentials, and account ID.
3. Payment information. We collect payment information to process payment for using the Services. Depending on your chosen payment method, this may include credit card information, which we collect using our third-party payment processors. For more information, please see the Payment Processors section of this Privacy Policy.
4. Support requests and inquiries. If you contact customer support, we collect your identity and contact information, account information, the details of your question or request, and any other information you choose to include in your message.
5. Communications, feedback, and events. If you communicate with us, such as by submitting a contact form or sending an email, submitting a request to receive newsletters and marketing communication from us, or submitting feedback to us, we collect your identity and contact information and any content you include with your communication or feedback. We may also collect information you provide if you complete surveys or questionnaires that we make available. If you sign up for or attend a webinar or other event hosted or sponsored by Foureyes, we collect registration and attendance information, which may include your identity and contact information as well as any professional background information you may choose to share.
6. Marketing preferences and promotions. We will collect your identity and contact information in addition to your communications preferences related to marketing communications. We also collect personal information you may provide for any sweepstakes, contests or promotions that we may offer.
7. Interactions through social media and other third-party platforms. If you interact with us through any third-party platforms or through any of our pages or feeds on social media sites or platforms, such as Facebook or LinkedIn, we may collect information such as your identity and contact information, username, demographic information, location, and publicly-posted data such as your social media activity.
8. Business development and strategic partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

You may choose not to provide personal information directly to us or to not use the Services. However, some personal information is necessary so that we can provide you with the Services you have requested. Failure to provide this information may prevent us from providing you with

access to our Services.

Foureyes does not intentionally collect personal information that is considered sensitive under privacy laws, such as genetic data, health information, race or religious information, about users to provide the Services.

(b) Information We Collect Automatically. When you access or use the Services, we or our thirdparty agents or service providers automatically collect information about the device you use to access the Services and your activity when you use the Services. Depending on the Services you

use and how you use the Services, the information may include:

1. Technical Data: We collect certain information about your device and how you interact with the Services each time you access or use them.
   1. Log data includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, and how you interact with our Services.
   2. Device information may include your browser type and version, browser settings, time zone, unique device identifiers, information about your approximate location (as determined through your IP address), mobile, computer, and/or device hardware information (e.g., operating system version, hardware model, IMEI number, and other unique device identifiers, MAC address, and device settings), device event information, log information, and crash data.
2. Usage Information: Usage information may include features that you use, clickstream data, access dates and times, and how you interact with the Services. When you visit the Website, this information may also include referring / exit pages and URLs, how you interact with links on the Website, landing pages, and pages viewed. We also may collect the date and time you open an email communication from us or click on any links in an email, and we or our service provider may associate this information with the email address we already have from you. We may also use the information we collect automatically (for example, IP address, and unique device identifiers) to identify the same unique person across the Services to provide a more seamless and personalized experience to you.
3. Cookies and Other Tracking Technologies: We and our third-party service providers or agents may collect information using one or more Cookies or similar technologies such as pixels (collectively “type="i"”). Cookies may collect information such as your IP address, unique device identifiers, your browser settings, and information about how you use the Services (e.g., the pages you view, the links you click). Please refer to the Cookies and Tracking Technologies section below for more information about our use of Cookies and your choices related to Cookies.

(c) Customer Content. We collect, receive, or access Customer Content that our Foureyes Customers and their Authorized Users input, submit or make available through their use of the Tool, including any personal information contained in such Customer Content. Customer Content may include data we may collect about a consumer’s activity as they navigate a Foureyes Customer’s website or information from other Foureyes Customer systems. We process Customer Content pursuant to our agreements with our Foureyes Customers. In the event that Customer Content contains any personal information, the Foureyes Customer’s privacy notice will apply to that personal information.

(d) Information from Third Parties. Depending on the Services you use or how you use the Services, we collect and process personal information we receive from third parties, and we may combine personal information we receive from and on behalf of our Foureyes Customers with personal information we obtain from other sources. We may receive the following types of information from third parties:

• Foureyes’ Service Providers: We receive information from our service providers or agents who perform business services for Foureyes, such as Website activity information from third parties that assist us in operating our Website, support information from customer support providers, and transactional data from our third-party infrastructure service providers and security and fraud detection providers.
• Analytics, Marketing, Advertising Providers, and Foureyes Partners: We may receive information from third parties that perform data analytics, targeted advertising, marketing and/or lead generation functions for Foureyes, such as lead generation providers, third-party data enrichment tools, and analytics vendors. We may also receive contact information from Foureyes business partners with whom we operate co-branded events, webinars, services and marketing campaigns or joint offerings.

3. How We Use Personal Information. The ways we use personal information depend upon the Services you use and how you use them. We may use the personal information we collect in the following ways:

Providing the Services and Account Management:

• To provide and operate the Services.

• To create and manage your account.

• To process and manage billing and payment for Services (including through our Payment Processors).

• To provide notices, transactional updates, and other information to you about, or in connection with, our Services.

• To provide technical support for, secure, and protect the Services.

• To conduct research and analytics related to the Services, such as to understand how they are being used and where improvements may be needed.

Personalizing, Improving and Enhancing the Services:

• To personalize and improve user experience with the Services.
• To update, improve, and/or enhance the Services, and develop new features, functionalities, and/or Services.
• To better understand your personal preferences and to enable us to provide you with improved and personalized communications.
• To compile aggregate data, such as about traffic and interaction with or on the Services.

Marketing and Advertising:

• To send you newsletters, promotional and marketing communications that may be of interest to you.
• To conduct and administer promotions, sweepstakes, or contests if you have chosen to participate, in accordance with the terms of the promotion.
• For our advertising purposes, such as to display personalized advertisements to you regarding the Services on third-party sites and measure their success.
• To tailor the content and advertising we display to you or others and to analyze trends and statistics.

Communicating with You:

• To respond to your inquiries and requests, or otherwise communicate with you, and to provide you with assistance related to the Services.
• To interact with you at events hosted by Foureyes or another organization.

Meeting Legal, Security, and Other Compliance Obligations:

• To enforce our agreements, resolve disputes or otherwise to carry out our obligations and enforce our rights, and to protect our business interests and rights of third parties.
• To detect and prevent fraud, abuse, or security risks, and to troubleshoot.
• To audit our compliance with legal and contractual requirements and internal policies.
• To comply with legal and contractual obligations and requirements, law enforcement requests, and legal process.
• For our business transfers and transactions, such as a merger or acquisition.
• To keep you updated about changes to policies related to our Services (including this Privacy Policy).

For any other purpose with your consent.

We may combine any of the information that we collect from you when acting as a business/data controller with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. We will use this information for the purposes described in this Privacy Policy.

4. How We Disclose Personal Information. We transmit, disclose, grant access, make available and provide personal information to or with the following types of third parties.

(a) Corporate Account Administrators and Other Authorized Users. If you are using the Services through a corporate account, the administrators of that account may access and control your Foureyes account and other Authorized Users may have access to or be able to view some or all of your account data, depending on the level of permissions granted.

(b) Foureyes Affiliates and Subsidiaries. We may disclose personal information among our Foureyes affiliates and subsidiaries for purposes of providing the Services, for our marketing and advertising purposes, and for any of the other purposes described in this Privacy Policy.

(c) Service Providers. We disclose personal information to our third-party vendors, consultants, agents, contractors, and service providers that help us provide our Services or with any of the purposes described in this Privacy Policy. Depending on the Services you use and how you use the Services, the following categories of Service Providers may process personal information on our behalf:

• Hosting service providers,
• Analytics providers,
• Payment processing providers,
• Advertising and marketing partners,
• Sweepstakes and promotions partners,
• Providers of business operations and communication tools, such as call tracking providers and email and messaging software providers,
• Customer relationship management and customer support service providers,
• Security and fraud-prevention providers;
• Other third-party service providers that help us provide features and functions for the Services, and
• Professional advisors, agents and service providers, such as auditors, lawyers, consultants, accountants and insurers.

(d) Third-Party AI Partners. From time to time, Foureyes may partner with third-party AI platform providers, such as large language model and AI speech providers, to enable features of the Tool (“Third-Party AI Partners”). For this purpose, Foureyes may share data we collect and receive, including certain personal information and Customer Content, with its Third-Party AI Partners. Where a Third-Party AI Partner processes personal information, it is processed in accordance with that Third Party AI Partner’s privacy notice.

(e) Legal, Compliance and Regulatory Purposes. We may disclose personal information if we believe that it is necessary to:

• comply with a law, regulation, legal process, or legitimate governmental request;
• protect the safety or security of the Services, users of the Services, or any person;
• investigate, prevent, or take action regarding illegal or suspected illegal activities;
• prevent spam, abuse, fraud, or other malicious activity of actors using or accessing the Services; or
• protect our rights or property or the rights or property of those who use the Services.

Non-public information about our users will not be released to law enforcement except in response to an appropriate legal process such as a subpoena, court order, or other valid legal process that has been reviewed by Foureyes. However, if we receive information that provides us with a good faith belief that there is an exigent emergency, we may provide information to law enforcement trying to prevent or mitigate the danger, to be determined on a case-by-case basis.

(f) Business Transfers. We may disclose personal information to third parties we choose to acquire or with buyers, successors, or others in connection with a merger, divestiture, restructuring, reorganization, financing due diligence, initial public offering, dissolution, or other sale or transfer of some or all of our assets or transition of service to another provider, whether as a going concern or as part of bankruptcy, receivership, liquidation or similar proceeding, as permitted by law and/or contract.

(g) With Your Consent. There may be situations where you are asked to consent to disclose personal information with third parties for additional reasons not included in this Privacy Policy.

5. Cookies and Tracking Technologies. As described above in this Privacy Policy, we collect and may permit third parties to collect information using cookies and other similar technologies.

(a) What Are Cookies? Cookies are small data files that are placed on your device set by us or by third parties when you visit a website or other online service. In addition to cookies, we may use other technologies that are similar in function, such as the following:

• Pixels: Also called web beacons, or “clear gifs,” and single-pixel tags/gifs, or web tags, are tiny graphics with a unique identifier placed on a website or in an email that gathers information about your interaction with that website or email.
• Local or Web Storage: Local or web storage includes both your own device storage and browser cache.
• Embedded Scripts: An embedded script is a programming code that is temporarily downloaded onto your device and is designed to collect information about your interactions with the Services. We use the term “Cookie” throughout this Privacy Policy to cover all these technologies. You can find more information about cookies at: www.allaboutcookies.org.

(b) Types of Cookies. Cookies are often described by who created and placed them and how long they last. Types of Cookies generally include the following:

• Persistent Cookies and Session Cookies
  • Persistent Cookies: A persistent Cookie stays in your browser and will be read by us when you return.
  • Session Cookies: A session Cookie is temporary is deleted when you close your browser or after a short time.
• First-Party Cookies and Third-Party Cookies
  • First-party Cookies: These are Cookies set by the publisher of the website or online service you are visiting.
  • Third-party Cookies: These are Cookies that are set by a party other than the publisher of the website you are visiting.

(c) How Do We Use Cookies? We, our service providers, and/or agents acting on our behalf, use the following persistent and session Cookies (which may be first-party or third-party Cookies) on our Services:

• Necessary Cookies: These Cookies are essential because they enable our Services to work properly, and they cannot be disabled. These Cookies do not gather information about you for advertising purposes. For example, these Cookies are used to: identify misuse of our Services, load our Services uniformly to maintain accessibility; and authenticate users and prevent fraud.
• Functional Cookies: We use functional Cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these Cookies can be used to remember your name or preferences on our Services. We do not use functional Cookies for online advertising. While these Cookies can be disabled, this may result in less functionality during your use of our Services.
• Analytical Cookies: These Cookies help us understand how our Services are being accessed and used. These analytical Cookies may collect information about the content you view and your system and geographic information. The information generated by these Cookies will be transmitted to and stored by the applicable analytics services. For example, we may use analytical Cookies to: keep track of the number of visitors and length of time that each visitor spends on the pages within our Services and maintain and continually improve our Services.
• Performance Cookies: These Cookies help us understand how our Services are performing. These performance Cookies may collect information about what websites you visit immediately before and after visiting our Services and your interactions with the Services. For example, we may use performance Cookies to identify performance issues with our Services and assess which parts of our Services need improvement.
• Advertisement Cookies: These cookies are used to deliver advertisements that are relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. Advertising cookies are usually placed by advertising platforms that work with other organizations to deliver personalized experiences to you. These cookies are used to: keep track of which advertisements you’ve been shown ad how you interact with them and provide and improve reporting on campaign performance.

(d) How to Manage or Delete Cookies. You can exercise your preferences concerning Cookies served on our Services by taking the steps outlined below.

• Foureyes Cookie Manager: You can adjust your Cookie preferences through the Foureyes cookie manager. To access the cookie manager, you can click “customize” in the cookie banner on our Website or click the Cookie “consent preferences” icon on our Website.
• Browser Settings: You may alter the Cookie settings in your browser settings at any time. You may accept all or only certain Cookies. To do this, follow the instructions provided by your browser (usually located within the “Help,” “Tools,” or “Edit” settings). While adjusting your browser setting can prevent the future placement of Cookies, it does not remove existing persistent Cookies. If you disable Cookies in your browser settings, however, you may find that certain sections of our Services will not work.
• Preferences Tools: There are several services available that can assist you with managing your Cookie preferences, including industry groups, standards associations, and tools provided by the Cookie providers and social media sites. Please note that we have no affiliation with, and are not responsible for, third-party websites.
  • Global Privacy Control and Privacy plug-ins: You can block Cookies used for interest-based ads by installing browser plugins and configuring them to block third-party cookies/trackers. For more information, please visit globalprivacycontrol.org
  • Google Analytics: You may download the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
  • DAA: You may use the Digital Advertising Alliance (“DAA”) consumer choice tools to apply opt-outs for DAA participating companies by visiting optout.aboutads.info.
  • NAI: You may also manage opt-outs through the Network Advertising Initiative (“NAI”) opt-out tool at optout.networkadvertising.org
  • Web Beacons and Pixels: You may avoid web beacons and pixels by disabling the functionality that allows remote images to load in your email account and refraining from clicking on any links in email messages.

Opting out through these mechanisms does not block all online advertising. You will continue to receive generic advertisements.

6. "Do Not Track" Preferences. Foureyes Services do not monitor for or behave differently if your browser or device transmits a “Do Not Track” or similar message. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, Foureyes does not currently alter our practices when we receive a "Do Not Track" signal from a visitor’s browser except as specifically required by law. For information about "Do Not Track" please visit All About DNT.

7. Payment Processors. Foureyes does not directly collect or store your payment information. As applicable and depending on your selected payment method, we may use third-party service providers to collect and process payments on our behalf. Information collected by these third parties is governed by the applicable third party’s privacy policy. You should review the applicable privacy policy prior to submitting any information to the applicable third-party payment processors.

8. Third-Party Links. We may provide links to other websites or resources with which we do not have a contractual relationship and over which we do not have control (“External Websites”). This Privacy Policy does not apply to or cover External Websites. Such links are not paid advertisements, nor do they constitute an endorsement by Foureyes of those External Websites and are provided to you only as a convenience. By clicking on links to the External Websites, the operators of the External Websites may collect personal information. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

9. Third-Party Social Media Plugins. The Services may offer Social Media Platform sharing features and other integrated tools that enable you to share or view certain content via social media sites (such as the X (Twitter) “Follow” button). These features may function as cookies or web beacons when you interact with them and collect information such as information about your device or your interactions with the Services, such as what you are viewing through the Services. If you are logged in to your account with the third party, the third party may be able to link information about your interactions with the Services to your account with them. Please refer to each third party’s privacy policies to learn more about its data practices.

10. Children’s Privacy. Our Services are not intended for use by anyone younger than the age of 18 or under the applicable legal age of the relevant country. We do not knowingly collect personal information from children younger than the age of 18 without the consent of a parent or legal guardian, as required under applicable law. If you learn or believe that a child under the age of 18 has provided us with personal information, please contact us using the methods provided in the Contact Us section of this Privacy Policy below.

11. Your Choices

(a) Marketing Preferences

• Email Opt-Out: To stop receiving, or opt-out of, promotional email communications from Foureyes, click on the "unsubscribe" link or follow the relevant opt-out instructions within the marketing communication. If you opt-out of receiving marketing emails, we will still send you transactional emails, such as for responses to your requests or communications about your account.
• SMS Opt-Out: To stop receiving SMS marketing communications from Foureyes, you can opt out at any time by responding with the opt-out notice indicated in the SMS communication.

(b) Third Party Advertising and Analytics. Foureyes works with third-party network advertisers, ad agencies, and other advertising partners to serve Foureyes ads online. We may use information we have learned about you to target ads to you and to allow our third-party advertising partners (e.g., Meta, Google) to manage our advertising on their websites. We also use third-party analytics providers to provide us with information regarding the use of the Services and the effectiveness of our advertisements. For more information about the tracking technologies that these third parties use and your options, please see the Cookies and Tracking Technologies section of this Privacy Policy.

12. How Long We Retain Personal Information. We retain personal information for the purposes stated in this Privacy Policy and as required under applicable law. To determine how long we keep personal information, we consider the amount, nature, and sensitivity of personal information, the reasons for which we collect and process the information, and applicable legal requirements.

13. How We Protect Personal Information. At Foureyes, we take our responsibility to protect the security and privacy of personal information seriously. We have implemented what we believe to be reasonable and appropriate security measures designed to prevent personal information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot and do not guarantee that personal information is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the Internet. If you have reason to believe that your information is no longer secure, please let us know by contacting us using the methods provided in the Contact Us section of this Privacy Policy.

14. California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt-out of the sharing of certain categories of personal information with third parties for their direct marketing purposes. We do not currently share or disclose personal information with third parties for their own direct marketing purposes.

15. Notice to Nevada Residents. Under Nevada law, Nevada “consumers” (individuals who are seeking or acquiring goods/services for personal, family, or household purposes) may opt out of the sale of covered personal information. Foureyes does not currently sell covered information of Nevada consumers as defined under applicable Nevada law. You may submit an opt-out request by sending your request to the email address or mailing address specified in the Contact Us Section below, along with your full name, complete mailing address (including street address, city, state, and zip code), email address (so that we can contact you, if needed, in connection with the request) and confirmation that you are a Nevada resident.

16. International Data Transfers. The personal information that we collect or receive may be transferred to and processed in countries located outside of your country of residence to the countries where we or our third-party service providers process it. The data protection laws of the countries where personal information is processed may not be as comprehensive as or equivalent to those in your country of residence. Whenever we transfer personal information internationally, we take steps to protect it as required under applicable law.

17. Changes to this Privacy Policy. We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Last Updated and Effective Date” at the top of this Privacy Policy and post a link to the updated Privacy Policy on our Services. Changes to this Privacy Policy are effective when they are posted. If we make any material changes, we will provide you with notice as required under applicable law. Please review this Privacy Policy periodically to ensure you are aware of any such changes.

18. Contact Us. If you have any questions about this Privacy Policy or our privacy practices, please contact us by email at [email protected].