Our Commitment to Privacy

Information collected from those who use our Services (“you” or “your”); and

Information that our Business Partners (defined below) share with Ambar or that we share with our Business Partners.

Non-Personal Information - “Non-Personal Information” is any information that does not enable identification of an individual, such as, without limitation, technical information, behavioral information, and aggregated information, including service usage information, web traffic information, content viewed on the Services, your preferences, and information about your operating system, browser, device, keyboard language and hardware.

Personally Identifiable Information - “Personally Identifiable Information” (or “PII”) is information that identifies you. Examples of PII that may be collected through the Services include, without limitation:

PII Provided Directly by You - You may voluntarily provide us with PII when using the Services, including, without limitation, when you perform the following activities:

• Register for an Account or create a profile
• Use Interactive Areas
• Make Submissions, post comments, or provide reviews or testimonials
• Submit online forms or make requests for communication or support
• Initiate or complete transactions through the Services
• Initiate or complete credit check applications through the Services
• Make or receive payments
• Send or receive Texts
• Conduct and/or save searches
• Electronically sign agreements
• Communicate with any of the Ambar Representatives

Please note that content posted to the Interactive Areas, including your Submissions posted in such areas, may be publicly viewable or viewable by anyone who uses the Services. Therefore, if you upload or share any Information to the Interactive Areas, unless otherwise expressly stated by Ambar, such Information may be non-confidential and may become publicly available. This means that the Information may be collected, used, or redistributed by others, so please proceed with caution before posting anything sensitive or confidential to the Interactive Areas.

Information Collected Automatically - We and certain Third Parties may also automatically collect Non-Personal Information about you and your devices when you interact with the Services. This Information may include, without limitation:

• Computer or device operating system information
• IP address
• Network information
• Browser type and language
• Connection speed
• Mobile device ID
• Device hardware type
• Referring website or application accessed before or after accessing the Services
• Parts of the Services accessed
• Access times for and length of time spent on a page or using a feature
• Content viewed
• Geographic location

Information Collected Through Tracking Tools - When you access our Services, we or Third Parties may use technologies such as “cookies”, local storage capabilities, or other similar technologies to monitor usage of the Services (“Tracking Tools”). These Tracking Tools allow the collection of Non-Personal Information (such as pages viewed by you within a certain Service and the duration of the browsing) and PII (such as your login information), including over time and across different properties and devices. Among other things, Tracking Tools can enable Ambar to automatically activate certain features for you, make your experience on the Services simpler, more relevant and more convenient, and provide you with personalized, interest-based advertisements, as further described below. Tracking Tools are used widely across the industry.

Tracking Tools – In General - By accessing the Services, you consent to us setting and accessing Tracking Tools, including cookies, on your device and in the emails we send you, and to tracking your activities and your use of the Services through these Tracking Tools. For clarity, Third Parties do not have access to Tracking Tools set by Ambar on our Services except to the extent necessary to help us provide the Services. Ambar and Third Parties may use the following Tracking Tools:

To Provide the Services - We use the Information collected, and may share such Information with Third Parties to provide, operate, and maintain our Services, including for the following purposes:

• Personalizing, improving, and operating our business and the Services
• Better understanding the needs and interests of you and others who may use the Services
• Fulfilling requests you make related to the Services, including to respond to your support requests or to process and facilitate transactions conducted on the Services
• Processing and facilitating payments
• Providing Service announcements or providing you with further information, recommendations, and offers from us or Third Parties
• Complying with applicable law, regulation, legal process, subpoena, or governmental requests, or other legal obligations
• Resolving disputes or security or technical issues
• Enforcing our agreements, including this Privacy Policy or the Terms, or investigating potential violations thereof
• Protecting, investigating, and deterring against fraudulent, harmful, unauthorized or illegal activity, or otherwise as we believe to be necessary to protect the rights, property, or safety of Ambar, the Ambar Representatives, you, or the general public
• Performing statistical analysis and research activities
• Processing or storing Information through Ambar’s affiliated companies and authorized Third Parties, as reasonable for business purposes (including, as applicable, their affiliates as necessary to provide us with the requested services)
• Other commercial purposes (including, without limitation, offering you insurance, financing, service contracts, or other products in connection with the purchase or sale of a vehicle)

If we share your PII for a purpose not mentioned in this Privacy Policy, we will receive your express approval prior to the disclosure.

Marketing and Advertisements - We may use your Information to send you information about our Services or the services of our Business Partners, including new products and promotions. Additionally, we may provide your Information to our Business Partners to contact you directly about their products and services, if we think you would be interested. Some advertisements may come from Third Parties called “ad networks.” Ad networks may include ad servers, ad agencies, ad technology vendors, and research firms. We do not provide PII to any ad networks for use not related to the Services. In some cases, advertisements served through the Services may be targeted to those who fit a certain general profile category or may be based on information inferred from the Information provided by you, your Services usage patterns, or your activity on Third Party services, including over time and across properties and devices. By using the Services, you consent to us providing you with marketing materials, which may include the following:

• Direct Marketing: Communications or advertisements sent directly to you by Ambar or our Business Partners via telephone, mail, email, text, or other methods for the purpose of offering you products or services that may interest you.
• Advertisements: Advertisements and commercials from us or Third Parties. Note that if you click on any Third-Party advertisements, you may be transferred to a website of the Third Party or receive other messages, information or offers from the advertiser and/or other Third Parties, and these advertisers and/or Third Parties may use their own Tracking Tools to collect information in order to send you advertisements and for their legitimate business interests.
• Interest-Based Advertisements: Content and advertisements personalized to your interests, which are inferred from your activity on our Services and other sites and services, and based on information gathered by us or Third Parties using Tracking Tools. These advertisements may be served to you on our Services or other services, sites, or apps.

You may withdraw your consent through the “Contact Us” portal of the Website. Please note that even if you choose to remove your Information (opt out), you will still see advertisements while you’re browsing online, however they may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. Please note that if you opt-out of targeted advertising, we may still track your use of the Services for analytics, operations and security purposes.

Uses and Disclosure of Non-Personal Information - Non-Personal Information informs us how you interact with the Services. Some of this Information may be derived from PII, but, if so, we anonymize or aggregate the PII so that it does not identify the individual from whom it was derived. Non-Personal Information enables us and Third Parties we authorize to figure out how and how often you engage with different parts of the Services so that we can analyze and improve them. We may use Non-Personal Information for:

Ambar may transfer and disclose Non-Personal Information to Third Parties at its own discretion.

You consent to our sharing of Information, which may include PII, with Third Parties, such as, without limitation:

• Social media networks
• Payment processors
• Credit check and financing Service Providers
• Vehicle inspectors
• Vehicle history providers
• Shipping providers
• Web hosting services
• Analytics and advertising Service Providers
• Sales management tools
• Marketing and promotion partners
• Law enforcement or other legal authorities or bodies pursuant to a subpoena or court order; however, if permitted, we may allow you an opportunity to object to the subpoena or court order before we provide the requested Information

Some specific Third Parties include, without limitation:

• Microsoft Azure
• Google Analytics
• PayPal
• Facebook

We use commercially reasonable efforts to engage with Third Parties who share our commitment to protecting your Information, and who post a privacy policy governing their collection, processing and use of information. However, we do not control these Third Parties and are not liable for their practices, products, or services. Please read their terms of use and privacy policies to better understand their privacy practices. Please note that some Third Parties who receive your Information may be located in a country that does not have the same data protection laws as your jurisdiction.

If you make a purchase or sale through the Services, or otherwise use the Services in a way that involves sending or receiving payment, we may request Information to process and complete the transaction such as:

• Credit card information
• Name and contact information of financial institution
• Account type
• Routing number
• Account number

This Information is collected and stored by our third-party payment processing companies, which may include companies like PayPal (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.

We may, from time to time, request and receive some of your financial information from our Payment Processor for the following purposes:

• Completing transactions you initiate through the Services
• Enrolling you in discount, rebate, and other programs in which you elect to participate
• Protecting against or identifying possible fraudulent transactions
• Otherwise as needed to manage and operate our business

If you fill out a credit application through our Services, we may collect and store your credit application details that are eventually shared with Ambar’s Business Partners or Service Providers, such as, without limitation, Capital One, and which may contain some or all of the following Information:

• Name
• Email address
• Mailing address
• Phone number
• Date of birth
• Driver’s license number
• Employment information
• Income information

By submitting your Information, you expressly authorize (i) Ambar to transfer such Information to its Business Partners or Service Providers, and (ii) Ambar, and any of its Business Partners or Service Providers, to use that Information in accordance with their respective privacy policies.