Effective date: February 12, 2018

VIN Voyager, LLC (“VIN Voyager,” “we,” or “us”) provides a website, software, and mobile application platform that enables end users to generate and publish content to advertise motor vehicles for sale, and search for vehicles to purchase. Through the VIN Voyager Vingo app, users can post and search vehicle listing information at various online advertising channels, including VIN Voyager’s own automotive dealer network.

This VIN Voyager Privacy Policy explains how we collect, protect, share, and use information related to our website, software, and mobile app services (collectively, the “Services”), and your options concerning the collection and use of your information. By using VIN Voyager Services, you understand and agree that we are providing a platform for you to post and publicly share content to the Services, including vehicle identification numbers (“VIN”), year, make, model, trim, color, options, mileage, condition, vehicle asking price, vehicle photos, seller and vehicle location, purchaser location, and other materials (“User Content”). Other Users may see, search, use, or share User Content that you make publicly available through the Services, consistent with the terms and conditions of this Privacy Policy and our Terms of Use (which can be found at vingo.car/tou). Our Privacy Policy applies to all visitors, users, and others who access the Services (“Users”).

1. Information Collected by VIN Voyager.

User Entered Data. VIN Voyager allows Users to input User Content concerning vehicles that the User wants to advertise, buy, or sell, including vehicle VIN, year, make, model, trim, color, options, mileage, condition, vehicle asking price, vehicle photos, seller and vehicle location, purchaser location, and related information (“Vehicle Listing”). VIN Voyager uses mobile location services to determine the location of vehicles offered for sale, and the location of buyers and sellers. Such location services are required for vehicles to be posted to online advertising channels, including the VIN Voyager Dealer Network. If a User does not consent to our use of location services, such User must manually input their zip code in their account profile. The VIN Voyager app uses a camera and photos to scan VIN barcodes and upload images of vehicles for sale. The mobile location and photographic services may be referred to collectively as “Mobile Services.” To connect vehicle buyers and sellers, VIN Voyager allows advertising and selling Users to provide contact information including their name, zip code, telephone number, and email contact information, along with preferred methods of contact (“Seller Contact Information”). VIN Voyager allows Users to search for and locate vehicles to purchase and provides them an option to describe vehicles they would be interested in purchasing (the “Vehicle of Interest”). VIN Voyager allows Users to manage preferences for receiving notification of events within our Services, such as received purchase offers. VIN Voyager further allows User to opt into receiving text messages related to their purchase or sale of vehicles.

In providing VIN Voyager Services, we collect: (a) your name, username, password, and email address when you register for a VIN Voyager account; (b) the profile information you provide for your user profile (first and last name, picture, address and zip code, phone numbers, email addresses, and text message opt-in); (c) the above-described User Content, Vehicle Listing, Seller Contact Information, and other information that you post to the Services; (d) communications between you and VIN Voyager, including service-related emails, account verification, changes or updates to the Services, and technical and security notices; and (e) your mobile location information. If you participate in the VIN Voyager Referral and Cash-Back Program, you will submit personal information about you and the customers you refer, including without limitation names, telephone numbers, and email addresses. For the cash-back award, you will submit information about the purchase, sale, and/or trade-in of your vehicle. You agree to receive communications from us in connection with your participation in the Referral and Cash-Back Program, and to allow us to communicate with referred customers and Dealers about your participation, including without limitation disclosing to them that you referred them and provided their contact information.

Analytics Information. VIN Voyager uses third-party analytics tools to measure traffic volume and usage trends for the Services. These tools collect information sent by your device or our Services, including web pages you visit and other information that assist us in providing and improving the Services. We collect, aggregate, and use this analytic information with analytic information from other Users so that it cannot reasonably be used to identify any particular User.

Cookies and Similar Technologies. VIN Voyager collects device information to help us track bugs and ensure the security of our Users, including device model, platform, universally unique identifier (“UUID”), version, manufacturer, and serial number. We also log Internet Protocol (“IP”) addresses. When you visit the Services, VIN Voyager may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Services. We may ask third-party advertisers or other partners to deliver ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. VIN Voyager may store encrypted cookies on your device with the session ID associated with the login.

Log File Information. Log file information is automatically reported by your browser each time you make a request to access a web page or app, and such information can be provided when the content of the web page or app is downloaded to your browser or device. When you use VIN Voyager Services, our servers automatically record certain log file information, including your web request, IP address, browser type, referring and exit pages, URLs, number of clicks, how you interact with links on the Services, domain names, landing pages, pages viewed, and other similar information. We may also collect similar information from emails sent to other Users which help us track which emails are opened and which links are clicked by recipients. This information provides for more accurate reporting in and improvements to the Services.

Device Identifiers. When you use a mobile device to access VIN Voyager Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device which uniquely identify your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by VIN Voyager. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports, personalized content, and advertising material. Some features of VIN Voyager Services may not function properly if the use or availability of device identifiers is impaired or disabled.

Metadata. Metadata is technical data that is associated with User Content. For example, metadata can describe how, when, and by whom a piece of User Content was collected and how that content is formatted. Users can add or may have metadata added to their User Content including a hashtag to mark keywords when you post a vehicle photo, geotag to mark your location to a photo, or other data. If you geotag your VIN Voyager photos and make them public, your latitude and longitude will be stored with the photo and searchable through a location or map feature.

2. How VIN Voyager Uses Your Information.

Vehicle Listing and Seller Contact Information. Vehicle Listings can be posted to the VIN Voyager Dealer Network by the consumer to advertise vehicles for purchase and sale. When a vehicle is posted in the VIN Voyager Dealer Network, Vehicle of Interest data are shared with auto dealers participating in the network. Mobile Services are used to collect vehicle location and photographic information required for vehicle advertising, such as zip code, scanned VIN barcodes, and vehicle images. VIN Voyager may also use the Seller Contact Information to contact you concerning service updates and promotions.

Third-Party Advertising Sites. As a convenience to Users—and to maximize the market for advertising, purchasing, and selling vehicles—VIN Voyager by default recommends and selects appropriate third-party advertising channels and websites, including the VIN Voyager Dealer Network. The User is responsible for manually de-selecting any channels or sites to which the User does not wish to submit their data. Where required by the selected advertising channels, Seller Contact Information may be shared together with the Vehicle Listing data. All data and information provided to third-party advertising sites will be subject to the terms of use and privacy policies of such third-party sites. VIN Voyager will not be responsible for third-party terms of use or privacy policies, and the User will be responsible for reading and accepting such terms and policies.

VIN Voyager Dealer Network. When Users post Vehicle Listing data to the VIN Voyager Dealer Network, the Vehicle Listing, Vehicle of Interest data, and related information will be transmitted to affiliated auto dealers to enable them to identify listings they are interested in and make purchase offers. VIN Voyager will withhold the Seller Contact Information until the User chooses to accept an offer from a specific dealer (“Accepted Dealer”), at which time the User will be alerted that their contact information is being shared with the Accepted Dealer. VIN Voyager will also provide the Accepted Dealer’s contact information to the User.

Vin Voyager Analytics and Marketing. Within the VIN Voyager Services, we may use your information to provide analytic metrics concerning automotive markets, operation of the Services, traffic volume, number and types of vehicles listed and sold, geographic distribution of vehicle listings and sales, consumer behavior and preference trends, and similar business purposes. This information may be also used for internal operational purposes and external marketing, but such use will not include personally identifiable information.

In addition to the specific uses of information described above, VIN Voyager may use the information we receive to: (a) help you efficiently access your information after you sign in and otherwise use the Services; (b) remember information so you will not have to re-enter it during your visit or the next time you visit the Services; (c) provide personalized content and information to you and others, which may include online ads or other forms of marketing; (d) provide, monitor, and improve the effectiveness of our Services, and develop new products and features; (e) monitor operational metrics such as the total number of visitors, traffic volume, and demographic patterns; and (f) diagnose or fix technology problems, and automatically update the VIN Voyager app on your device.

3. Sharing Your Information.

Third Parties. VIN Voyager may share User Content, Vehicle Listing, Seller Contact Information, and your other personal information (including information from cookies, log files, device identifiers, location data, and usage data) with third parties to provide and improve the Services to the User, including using contractors or third-party partners to perform core application functions. VIN Voyager may share your information with third-party advertising partners to allow them to deliver targeted advertisements to you. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information. We will not sell your information to third parties outside VIN Voyager or its affiliated companies without your consent, except as provided in this Privacy Policy. If you participate in the VIN Voyager Referral and Cash-Back Program, you will submit personal information about you, the customers you refer, and the Dealers involved in the purchase, sale, and/or trade-in of your vehicle. You agree to receive communications from us in connection with your participation in the Referral and Cash-Back Program, and to allow us to communicate with referred customers and Dealers about your participation, including without limitation disclosing to them that you referred them and provided their contact information.

User Content Shared by You. User Content, Vehicle Listing data, Seller Contact Information, and other information that you voluntarily disclose for posting to VIN Voyager Services may become available to the public, subject to specific privacy settings that you select in your profile. Once you have shared User Content or other information or made it public, that User Content and information may be searchable and re-shared by others. If you remove information that you posted to the VIN Voyager Services, copies may remain viewable in cached and archived pages of the Services, or other Users or third parties may have copied or saved that information.

Change of Control. In the event that VIN Voyager sells or transfers its assets to another party (such as in a merger, acquisition, bankruptcy, dissolution, or liquidation), the User Content, Vehicle Listing, Seller Contact Information, and other information collected through VIN Voyager Services may be among the assets sold or transferred; provided that you will continue to own your User Content and personal information and the sale or transfer will be subject to this Privacy Policy.

Legal Requests. VIN Voyager may share your personal information in response to a legal request (such as a search warrant, subpoena, or court order) if we have a good faith belief that the law requires us to do so, within or without the United States. We may also share personal information when we have a good faith belief that it is necessary to: (a) detect, prevent, and remedy any fraudulent or other illegal activity; (b) protect VIN Voyager, our affiliated companies, you, and others from harm. User Content and other information we receive about you may be accessed and retained for an extended period of time when it is the subject of a legal request, governmental investigation, investigation concerning possible violations of our terms or policies, or otherwise to prevent harm.

4. How We Store and Protect Your Information. The User Content, Vehicle Listing, Seller Contact Information, and other information collected through VIN Voyager Services may be stored and processed in the United States or any other country in which VIN Voyager or its affiliated service providers maintain storage or processing facilities. VIN Voyager or its service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. By registering for and using the Services, you consent to the transfer of information to the U.S. or to any other country in which VIN Voyager or its service providers maintain storage or processing facilities, and the use and disclosure of information as described in this Privacy Policy.

VIN Voyager optionally allows the End User to create a username and password for the purpose of retrieving information from another device. To help ensure account security, VIN Voyager encrypts passwords with a one-way encryption and provides Users with an option to use two-factor authentication on their accounts. VIN Voyager complies with applicable Payment Card Industry Data Security Standards (PCI-DSS) and Payment Application Data Security Standards (PA-DSS). VIN Voyager uses encrypted connections through a transport layer security (TLS) protocol to secure connections between you and the Services. VIN Voyager uses commercially reasonable safeguards to help secure information collected through the Services and we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, VIN Voyager cannot ensure the security of information you transmit to VIN Voyager Services or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and VIN Voyager. We are not responsible for the functionality, privacy, or security measures of any other person or organization.

5. Removing Content from VIN Voyager Services. Users can review, change, and deactivate Vehicle Listing data, Seller Contact Information, and any personally identifiable information from the VIN Voyager app. When you deactivate a Vehicle Listing, the listing information will be removed from online advertising websites that have your active Vehicle Listing, subject to such site’s normal update cycle. If a User wishes to deactivate their VIN Voyager account, such User may request deactivation of their account by sending a request to support@vinvoyager.com. Following termination or deactivation of your account, VIN Voyager or its service providers may retain your User Content and information for a commercially reasonable time for backup, archival, and/or audit purposes.

6. Account Information and Profile/Privacy Settings. You may review and update your VIN Voyager account at any time by logging in and changing your profile settings. You may unsubscribe from VIN Voyager email communications by clicking on the “unsubscribe link” provided in such communications. As indicated above, you may not opt out of service-related communications (such as account verification, purchase and billing confirmations and reminders, changes or updates to features of the Services, and technical and security notices).

7. Other Websites. As indicated above, VIN Voyager is not responsible for the policies and practices employed by third-party websites or services linked to or from our Services. Please note that when you use a link to go from our Services to another website or service, our Privacy Policy does not apply to those third-party websites or services. Information concerning your browsing and interaction on third-party websites or services, including those having a link in VIN Voyager Services are subject to such third-party's own policies. In addition, VIN Voyager is not responsible for third-parties that you authorize to access your User Content and other information.

8. How to Contact VIN Voyager. If you have any questions about this Privacy Policy or the VIN Voyager Services, please contact us by email or telephone using the appropriate support channel on the VIN Voyager website, support@vinvoyager.com. Otherwise, you may write to us at VIN Voyager, LLC, 15328 SE 94th Ave, Clackamas, OR 97015.

9. Privacy Policy Changes. VIN Voyager may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of VIN Voyager or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.