REWISE, INC.

PRIVACY POLICY

Last Updated: April 3, 2020

This privacy policy (this “policy”) describes how Rewise, Inc. (“we”, “our” or “us”) collects, uses, shares and discloses the personal information of users of www.startmycar.com (our “website”) and related software, services and features that we offer, including without limitation any messaging tools, search technologies (together, or individually, our “service”) belonging to, provided by, created by or operated by us.

INTRODUCTION

We respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information that we may collect from you or that you may provide when you visit our website and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information that we collect (a) on our website; (b) in email, text and otherelectronic messages between you and our website; (c) through mobile and desktop applications you download from our website,which provide dedicated non-browser-based interaction between you and our website; and (d) when you interact with our advertisements and applications on third-party websites and services, if those applications or advertisements include links to this policy. This policy does not apply to information collected by us offline or through any other means (including on any other website operated by us or any third party (including our affiliates and subsidiaries)), or collected by any third party (including our affiliates and subsidiaries), including through any application or content (such as advertising) that may link to or be accessible from (or on) our website.

HOW YOU ACCEPT THIS POLICY

Please read this policy carefully to understand our policies regarding your information and how we will treat it. If you do not agree with our policies, your choice is not to use our website. By accessing or using our website, you agree to this policy. This policy may change from time to time (see “Changes and Updates to Our Privacy Policy” below). Your continued use of our website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

INFORMATION THAT WE COLLECT

The information that we collect from you falls into two categories: (a) personally identifiable information (i.e., data that could potentially identify you as an individual) (“personal information”) and (b) non-personally identifiable information (i.e., information that cannot be used to identify who you are) (“non-personal information”). This policy covers both categories.

We may collect a variety of personal information, including:

  • Information That You Give Us Directly. We may collect your‎ name, email address, phone number, user name, password, demographic information (such as your gender and occupation) and uploaded files, as well as any other information that you directly input into our website (such as by filling in forms on our website about the make or model of your vehicle); we also may keep records of your correspondence if you contact us, or your search queries on our website and of your responses to our surveys; and
  • Information That We Get From Third Parties.Information from third-party services such as our business partners, or to which you explicitly give us access.

We may also collect a variety of non-personal information that you provide automatically as you navigate through our website, such as usage details and information collected through cookies, web beacons, and other tracking technologies, including analytics data such as:

  • the IP address of the computer you use to access our website; 
  • the type of browser software you are using; 
  • the operating system you are using; 
  • the date and time you access or use our website; 
  • the website address, if any, that linked you to our website; 
  • the website address, if any, that you travel to after leaving our website; and/or
  • other non-personally identifiable traffic data.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our website, or transmitted to other users of our website or third parties (collectively, “user contributions”). Your user contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our website with whom you may choose to share your user contributions. Therefore, we cannot and do not guarantee that your user contributions will not be viewed by unauthorized persons.

HOW WE COLLECT INFORMATION

Information Collected Directly from You

When you access our website or our service through any device, including a mobile device, we may collect certain information automatically, including without limitation the type of device you use, your operating system, the type of Internet browser you use, your location information and other statistics (depending on the permissions you have set on your device). We also may store information that we gather from you. We may use this information to provide features of our website or our service and/or to improve and customize our website and/or our service. If you use or create a profile on our website, we may request certain personal information such as your name, organization, email address, phone number and billing information. You also may have the option to provide us with information about your social media accounts.

If you contact us in person, by phone or by email, instant message, live chat, social media or some other means (either through our website or through a third-party service), we may keep a record of your contact information and correspondence for later reference, including without limitation in order to help improve our website or reach you if necessary.

Information Collected Automatically 

We may automatically log certain information about you and your computer and mobile devices when you use certain pages of our website. We do this by incorporating technologies such as “pixel tags,” “web beacons” and/or “cookies.” Pixel tags or web beacons are small electronic-file tracking devices (also referred to as clear gifs and single-pixel gifs) on websites or in emails that monitor the behavior of the user visiting the website or receiving the email. Cookies are small files that web servers may place on the hard drive of your computer when you visit a website.

We use both session cookies (which expire once you close your web browser) and persistentcookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. This type of information is collected to make our website more useful to you and to tailor the experience with us to meet your special interests and needs. You may refuse to accept browser cookies by activating the appropriate setting in your browser or on your mobile device, but disabling cookies may cause you to be unable to access parts of our website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information” below.

Weuse Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. While we only use the information that we receive from Google Analytics to improve our website, and do not combine the information collected through the use of Analytics Tools with personally identifiable information, we reserve the right to combine information in the future. You may prevent Google Analytics from recognizing you on return visits to our website by disabling cookies on your browser. You may opt out of having your activity on our website made available to Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) for your web browser. The Google Analytics opt-out browser add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on Google’s privacy practices, please visit the Google Privacy & Terms webpage:http://www.google.com/intl/en/policies/privacy/. For more information on the Google Analytics terms of use, please visit the Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html).

Information Collected by Third-Party Services

We may obtain other information (including personal information) from third parties (such as advertisers, ad networks and servers, content providers and application providers) and combine that with information that we collect through our website (collectively “third-party services”) in order to run our website. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information (including personal information) about your online activities over time and across different websites and other online services. These third parties may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE THE INFORMATION THAT WE COLLECT

We primarily use the information that we collect and store to enhance the website experience. We do not rent, trade or sell your personal information, except as otherwise described below (or if we sell all or a portion of our business). We may use your personal information:

  • to present our website and its contents to you;
  • to contact you when necessary, including to provide you with notices about your account;
  • to provide you with recommendations;
  • to provide you with information, products and/or services that you request from us;
  • to respond to your comments and questions and provide customer service;
  • to provide you with additional information according to your preferences;
  • to customize and personalize your experience;
  • to generate aggregated statistics to help us improve the customer experience;
  • to make our website easier and more convenient for you, including to allow you to participate in interactive features on our website;
  • to send you information and marketing materials about services and products available on our website;
  • to communicate about promotions, upcoming events and other news about products and services offered by us and our affiliates and partners;
  • to notify you about changes to our website or any products or services we offer or provide though it;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to train our team members; 
  • for other internal business purposes; or
  • for any other purpose with your consent, except where such disclosure may be required by law without your consent.

SHARING OF PERSONAL INFORMATION

We may share personal information as follows: 

Aggregated Personal Data and Non-Personal Information

Wemay share or disclose aggregated personal information or non-personal information with contractors, service providers or other third parties that we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. We may disclose such information for any other purpose disclosed by us when you provide such information, or otherwise with your consent (except where such disclosure may be required by law without your consent). Our contractors, service providers or other third parties also may share with us aggregated non-personal information that they have independently developed or acquired. Additionally, we may disclose such information to our subsidiaries and affiliates, and we may combine aggregated information from the pixel tags, web beacons and cookies with similar data that we collect from other visitors to help us improve our website. We also may share aggregated and/or anonymized data with others for their own uses.

Agents or Third Party Partners

We may provide your personal information to our employees, contractors, agents, service providers or designees in order to enable them to perform certain services for us exclusively, including:

  • to carry out requests by you;
  • website-related services such as web hosting;
  • improvement of website-related services and features;
  • maintenance services; 
  • distribution of advertisements and other marketing materials on our behalf; or 
  • allowing third parties to market their products and/or services to you, if you have consented to/not opted out of these disclosures.


Buyers or Successors

We may choose to enter into a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our website users is among the assets transferred. By accepting this policy, you acknowledge the possibility of (and consent to) any such transfer.

Protection of Us and Others

Notwithstanding anything in this privacy policy to the contrary, we reserve the right to access, read, preserve and disclose any information that we reasonably believe is necessary or appropriate to: (a) comply with any court order, law or legal process, including to respond to any government or regulatory request; (b) cooperate with law enforcement; (c) enforce or apply our terms of use (see Terms of Use) and other agreements, including for billing and collection purposes; or (d) protect the rights, property or safety of us, our users, employees or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHANGES TO YOUR PERSONAL INFORMATION

        

Once you sign up for an account or otherwise provide us with your personal information, we may provide you with various options that enable you to delete or revise your personal information. You may change, alter or amend personal information that you provide to us by visiting your account settings or contacting us atprivacy@startmycar.com.

You may also contact us directly to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your user contributions from our website, copies of your user contributions may remain viewable in cached and archived pages, or might have been copied or stored by other website users. Proper access and use of information provided on our website is governed by our terms of use (seeTerms of Use).

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

        

We strive to provide you with choices regarding the personal information that you provide to us. We have created mechanisms to provide you with the following control over your information:

  1. Tracking Technologies and Advertising. You may typically set your browser to disable or reject some or all browser cookies, or to alert you when cookies are being sent. Many browsers are set to accept cookies until you change your settings. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or reject cookies, some parts of this website may become inaccessible or function improperly.
  1.  Promotional Offers from Us. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt-out by logging into our website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request (see “Contact Information” below). If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

While we do not control third parties’ collection or use of your information to serve interest-based advertising, these third parties may provide you with ways to choose not to have your information collected or used in this way.

If you decide that you do not want to receive email or other communications from us, you may select the “opt out” provision in our marketing communications to unsubscribe. Unsubscribing will stop you from receiving most types of communication, but may not apply to emails about orders or transactions you place through our website or to responses to your specific requests.

DATA RETENTION AND SECURITY

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration ordisclosure

We are committed to making sure your information is protected and to the extent that we use third-party vendors, we work to choose vendors that help keep your personal information safe. We do not, however, control any such third party and therefore cannot guarantee complete security. We also employ several physical and electronic safeguards to keep your information safe, including encrypted user passwords and securing all connections with industry-standard transport layersecurity.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our website like message boards. The information that you share in public areas may be viewed by any user of our website. If you log into your account on a shared computer, be sure to sign out of your account when finished. If you believe that a third party has access to your account, please let us know as soon as possible.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website, against the access, disclosure, alteration or deletion of data through events such as hardware or software failure or unauthorized use. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website.

Data Retention

If you wish to close your account, we will keep some of your data even after your account is closed. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed, but will destroy your personal data when it is no longer needed for the foregoing purposes, or we may remove your personal information to render it anonymous.

PRIVACY OF CHILDREN AND MINORS

Only persons age 18 or older have permission to access our website. Our website is not intended for children under the age of 13. No one under age 13 may provide any information to our website, and we do not knowingly collect personally identifiable information from children under the age of 13. If you are under 13, do not use or provide any information on our website or on or through any of its features/ register on our website, make any purchases through our website, use any of the interactive or public comment features of our website or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If you believe that we might have any information from or about a child under 13, please contact us (see “Contact Information” below). If we become aware that we have collected personal information from a child under the age of 13 without verification of parental consent, we may attempt to remove that information from our servers.

ONLINE TRACKING AND HOW WE RESPOND TO “DO NOT TRACK” SIGNALS

Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his or her online activity and behavior tracked. If an online service elects to respond to a particular DNT signal, the service may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many website operators including us do not take action to respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

CHANGES AND UPDATES TO OUR PRIVACY POLICY

We reserve the right to update and revise this policy at any time.  We occasionally review this policy to make sure it complies with applicable laws and/or conforms to changes in our business. If we revise this policy, we will update the “last modified” date of this page so that you can tell if it has changed, and we will do our best to notify you. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on our website.

Please review this policy regularly to ensure that you are aware of its terms. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this policy to check for any changes. Any use of our website (or our products or services) after a revision to our policy constitutes your acceptance to the revised agreement.

INTERNATIONAL PRIVACY LAWS

If you are visiting our website from outside the United States, please be aware that you are sending information (including personal data) to the United States, where our servers are located. That information may be transferred within the United States or back out of the United States to other countries outside your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in the country of your residence. Our collection, storage and use of your personal data, however, will at all times continue to be governed by this policy.

YOUR RIGHTS AS A CALIFORNIA RESIDENT

California Civil Code Section 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email or contact us using another contact method (see “Contact Information” below).

EXTERNAL LINKS

Our website contains links to other sites. Unless we expressly state otherwise, we make no representations whatsoever concerning the content of those sites. The fact that we have provided a link to a site is not an endorsement, authorization, sponsorship or affiliation with respect to such site, its owners or its providers. There are risks associated with using any information, software, or products found on the Internet, and we caution you to make sure that you understand these risks before retrieving, using, relying upon or purchasing anything via the internet.

Please be aware that we are not responsible for the privacy practices of other sites. Our Privacy Policy applies to all web pages under our domain (and not to any web pages not under our domain), regardless of any hyperlinks from a web page under our domain to a web page not under our domain.

GOVERNING LAW

You agree that your use of this website, and your consent to this policy and any disputes relating thereto, shall be governed in all respects by the laws of the State ofNew York. Any dispute relating to this website and this policy shall be resolved solely in the state or federal courts located inNew York.

CONTACT INFORMATION

We welcome your comments or questions about this policy and our privacy practices. You mayemail us directly at privacy@startmycar.comYou also may contact us at our mailing address: 2093 Philadelphia Pike #5882. Claymont, DE 19703, USA.

Exhibit A

Form of “Cookie Consent”

THIS WEBSITE USES COOKIES TO IMPROVE YOUR EXPERIENCE

Cookies are small data files that can be stored on a computer’s hard drive. These cookies would only be stored in case the user’s Web browser setting permits such storage. In case a user chooses not to allow cookies, the user can adjust the browser settings to refuse the same. However, some parts of our sites may not function optimally if the browser is set to refuse cookies.

We use cookies for the following general purposes:

  • To help us recognize the particular browser as a previous visitor. We may also retain a user’s registration details on the cookie, if instructed to do so (such as if the user ticks the box that says that he should be signed in automatically in the future).
  • To help us customize the content provided on our websites and on other websites across the Internet.
  • To help research the effectiveness of our website features, advertisements, and email communications. We may also use a technology called web beacons, which are similar to cookies, and are used to measure the effectiveness of email campaigns to determine which emails have been viewed and acted upon.

The website may use the following types of cookies:

  • “First party cookies” are technical cookies used by the site itself with the purpose of optimizing the use of the website (e.g., settings the user has modified on previous visits).
  • “Third Party cookies” are cookies not from the website itself but from third parties, such as plugins for marketing purposes. Examples of such third party cookies are cookies from Facebook or Google Analytics. For these cookies a user must authorize the use of such cookies. This can be done through accepting the use of cookies on a banner placed on top or below the webpage. Use of the website will not be hindered by refusing to accept the use of third party cookies.

You may change the settings of your internet browser in such a way that it does not accept cookies or that you receive a warning whenever a cookie is installed or when cookies are deleted from your hard drive. This can be done by changing the settings of your browser. Be aware that modifying these settings may cause graphic elements not to be shown correctly on the website or may disable the use of certain functionalities on the website.

By using Startmycar, you agree that the website uses cookies.

This website uses Google Analytics, a web analysis service offered by Google Inc. Google Analytics uses “cookies” to help analyze the use of the website by its visitors. The cookie generated information about your behavior on the website (including your IP-address) is sent to Google and stored on servers in the United States. Google uses this information to store how you use the website, to create reports of website activity for the website owners and other services with regard to website activity and internet usage. Google may share this information with third parties where required to do so by applicable law, or where such third parties process the information on Google’s behalf. Google will not combine your IP address with other information that Google possesses. You may refuse the use of cookies by modifying the settings of your browser. Be aware that by modifying these settings you may be unable to use all the website’s functionalities. By using this website, you agree to the use of information by Google as described above.

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