WEBSITE PRIVACY POLICY

Last updated:  September 25, 2025

DCD Automotive Holdings, Inc. (“DCD”) and its affiliates^[1] are committed to respecting and protecting the privacy rights of visitors to our websites.  The following explains what personal information we collect, what we use it for, and what we share with our affiliates when you visit our websites or interact with us in other ways.

When we refer to “personal information,” we mean information about an identified individual or about an individual whom we could identify.  Subject to applicable law, personal information generally does not include publicly available information or anonymized or de-identified data.  Other privacy policies may also apply in addition to the terms of this policy.  With respect to your personally identifiable financial information, please also see our Privacy Notice.

We may change this privacy statement from time to time.  If we make changes, we will notify you by revising the date at the top of this policy or as otherwise required by applicable law.  We encourage you to review this privacy statement to stay informed about our information practices and the choices available to you.

This Privacy Policy does not apply to third-party websites, products, or services, even if they link to our websites.  We recommend you review the privacy practices of those third parties before connecting or accessing third-party websites and disclosing any personal information.  See the section titled Links to Other Websites for more information.

Without prejudice to your rights under applicable laws, this Privacy Policy is not contractual and does not form part of your contract with DCD or its affiliates or subsidiaries.

1. Personal Information DCD Collects and Why

The types of personal information we collect depend on the nature of your interaction with DCD, and the product or service you purchase with us, which we collect for the purposes stated in this chart.  We may collect the following categories of personal information:

Some of this information (such as your social security number or information necessary to complete a credit or leasing transaction) is your personally identifiable financial information.  Our Privacy Notice, not this privacy statement, describes how we collect, use, and disclose your personally identifiable financial information.

2. How DCD Collects Personal Information

We collect personal information, other than personally identifiable financial information, about you from the following sources.

We do not sell personal information we collect for monetary consideration.

3. How DCD Discloses Personal Information

We may disclose personal information, other than personally identifiable financial information, as follows:

4. Cookies, Pixels, and Tracking Technologies

1. Interest-Based Advertising

We do not display advertisements on our websites, but your visits to our websites may be used for interest-based advertising on other websites by third parties, and we participate in interest-based advertising by placing advertisements on unaffiliated sites using information you provide us when you interact with our websites.  Interest-based ads, also known as personalized ads, are ads that are targeted to you based on your web browsing and app usage over time and across websites or apps.  For example, our websites may use third-party ad servers, retargeting services, and web analytics systems, such as Google, to analyze aggregate web usage statistics and provide us the ability to display advertisements about our services to you when you have left our websites.

You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads.  Some of these third parties may use cookies and other technologies to collect information about your online activities over time and across third-party websites or online services to deliver advertising based on your interests and preferences, as inferred from your browsing history.  Some of these ads may be personalized, meaning that they are intended to be relevant to you based on information that those third-party providers collect about your visits to this site and elsewhere over time.

To learn more about this type of advertising and how to opt-out of this form of advertising, you may either visit optout.aboutads.info to opt-out of sites and services participating in the Digital Advertising Alliance (“DAA”) self-regulatory program, or visit optout.networkadvertising.org to opt-out of this form of advertising by members of the Network Advertising Initiative (“NAI”).

Note that electing to opt-out will not stop advertising from appearing in your browser or applications, although it may make the ads you see less relevant to your interests.  This opt-out works through cookies set on a particular browser, so if you delete cookies from a web browser, or use a different browser, you will need to opt-out again.

Your choice to opt-out on a particular browser or device will apply only to the collection and use of information from that particular browser or device.  Opting out on a particular device will not opt you out of information collection on other devices, nor will it limit cross-device sharing on those other devices.  If you use different browsers on a device or multiple devices, for each browser and device you wish to opt out, please opt out each device and browser separately at optout.aboutad.info and at optout.networkadvertising.org.

2. Cookies

DCD uses a number of technologies to automatically collect information including cookies, pixels, web beacons, flash cookies, local storage, and other tracking technologies (collectively, “Cookies”).  Cookies are small blocks of data created by a web server while a user is browsing a website and placed on the user’s computer or other device by the user’s web browser.  Cookies are placed on the device used to access a website, and more than one cookie may be placed on a user’s device during a session.  In most cases, you can set your web browser to prompt you when a cookie request is made and allow you to accept or decline the request.  We give our customers the option of opting out of third-party tracking cookies and honor the GPC signal, by disabling tracking cookies (for example, by clicking “deny targeting cookies”) and opting the browser out of the sale or sharing for targeted advertising, if we detect that GPC is turned on and the browser is working properly.  We do not otherwise listen for or respond to Do-Not-Track signals.  We deploy cookies and similar tracking technologies to build profiles, serve ads and personalize your experience across our websites.  Tracking pixels are small images utilized to track users, typically for advertising or analytics purposes.  Web beacons allow data to be exchanged between systems.  Our websites may also be monitored by third-party software that may capture information about your visit and interactions with our websites that will help us improve the quality of our websites and the services we provide our customers.  We may use one or more of these technologies to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications.  If you would like more information about the Cookies on our Sites, please contact us using the information in the Contact Us section.

3. Our Use of Google Services

We use Google signals, User-ID Collection and Granular location and device data collection production from Google to measure how you interact with our websites and to improve your user experience.  For more information on Google Analytics, its privacy practices, and opt-out mechanisms, please visit the “How Google uses information from sites or apps that use our services” page at https://policies.google.com/technologies/partner-sites and the Google Analytics Security and Privacy Principles page at https://support.google.com/analytics/answer/6004245?hl=en.  For Google’s privacy policy and instructions on opting out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

In addition, certain of our interest-based advertising that appears on other websites may include “Call us” buttons that you may use to contact us.  Those contact methods are provided by our advertising partners, such as Google, which may monitor or record those calls or call metadata for the purposes described in the Interest-Based Advertising section of this Privacy Policy (such as to measure the effectiveness of our advertising).  If you do not want our advertising partners to have access to or record the content of your calls with us, you should contact us directly through our websites or telephone numbers, not using a “Call us” button included in one of our online advertisements.

4. Chat-Based Communications And Discussions Disclaimer

Our website may include certain functionality permitting you to engage in real-time, direct communications with our representatives using live chat, interact with automated self-service software through a chatbot, or AI-powered voice system that assists with scheduling service appointments. When you interact with the chatbot on our website or use our AI voice system to schedule service appointments, all the information you choose to provide to the chatbot/AI voice system may be collected and associated with your name or your IP address and a transcript of your interactions or communications with or through the chatbot/AI voice system may be created and stored.  You should not enter or provide any information during a chat or AI voice interaction that you would not want saved. When you communicate with us through the chatbot or AI voice system, those communications are saved to process your inquiries, respond to your requests, and improve our services.  By interacting with the chatbot or AI voice system, you agree that your interactions with us may be stored or analyzed, including by our applicable vendors on our behalf.

Nucar does not sell information collected by or through chat functionality, chatbots, or AI voice system, to any entity outside our organization.  Nucar may share this information with its affiliates and with outside vendors who provide services to Nucar.  Such third-party vendors who have access to Nucar information have committed to protecting Nucar data and have agreed to use it for the sole purpose of serving Nucar.

5. Session Replay

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay.  Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity.  For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.  We do not use these technologies to collect information that is inconsistent with your intent, and we do not use it to record sensitive information related to credit cards.  We do not provide information gathered to third parties other than our service providers.

Aggregated, De-Identified, or Anonymous Information

We may create aggregated, de-identified, or anonymous information from personal information by removing certain data components (such as your name or email address) that make the data identifiable, or through aggregation, obfuscation, or other means.  For example, we may use aggregated, de-identified, or anonymized information to understand how to improve or enhance our Sites.  Subject to applicable law, our use of such aggregated, de-identified, or anonymized information is not personal information or subject to this privacy statement.

5. Links to Other Websites

Our websites contain links to other websites, including social networking websites, mobile applications, or Internet locations (collectively “Third-Party Sites”).  We have no control over and are not responsible for third-party websites, their privacy practices, their content, or any goods or services available through the Third-Party Sites.  Our privacy policy does not apply to Third-Party Sites; any information you provide to a Third-Party Site is subject to that Third-Party Site’s privacy policy.

The fact that we link to a website is not an endorsement or representation of an affiliation with that website.  You should carefully review the applicable privacy policies before using or engaging with any Third-Party Site on our Sites.

6. Your Choices

You have certain choices with respect to your personal information.

We may use your contact information to send you email messages regarding updates to our Sites, about vehicles, financing, or other promotional offers, or to communicate with you about DCD, our affiliated dealerships, or manufacturers.  You may opt-out of receiving these emails at any time via the unsubscribe link contained in the email message.

You may also opt-out of targeted advertising by filling in our opt-out form.

We will communicate with you only according to your preferences provided to us.  We may use your contact information to send you messages regarding updates to the Sites.  You may opt-out of receiving these messages by following the unsubscribe link contained in the message, or by contacting us through the information contained in the Contact Us section.  You may not be able to opt-out of receiving certain messages from us, such as transactional communications or legal notices.

Children’s Privacy

DCD’s websites are not directed to or intended for use by children under 13 years of age.  We do not knowingly collect or solicit personal data from anyone under the age of 13, or knowingly allow such persons to register for our services, without parental consent.  No one under age 13 may provide any personal data to DCD or on DCD’s websites.  If you are under 13, please do not attempt to send any information about yourself to us, including your name, address, telephone number, or email address.  If we learn that we have inadvertently collected personal data from an individual under age 13 without parental consent, we will take steps to delete the data as permitted by law.  If you believe that we might have any information from or about an individual under age 13, please contact us through the information contained in the Contact Us section.

7. Additional Information for Individuals
   in Delaware and New Hampshire

Beginning January 1, 2025, we may be subject to the Delaware Personal Data Privacy Act and the New Hampshire Expectation of Privacy Act based on our interactions with Delaware and New Hampshire residents and our use of their personal information.  These laws provide residents of those states with certain rights with respect to their personal information when they are not acting solely in a commercial or employment context (such as a business-to-business communication) when interacting with us.  If you are an employee, a job applicant, or an individual otherwise interacting with us in a commercial or employment capacity, this section is unlikely to apply to you.

In this section, “Regulated Personal Data” refers to personal information that is linked or reasonably linkable to an identified or identifiable resident of Delaware or New Hampshire.  Regulated Personal Data does not include de-identified or publicly available information, as defined in the either law, personally identifiable financial information regulated by federal law, and certain other exceptions spelled out in the law.

If you are a resident of Delaware or New Hampshire, you may have some or all of the following rights:

First, you may have the right to confirm whether we are processing Regulated Personal Data concerning you and to access your Regulated Personal Data.

Second, you may have the right to request we correct inaccuracies in your Regulated Personal Data we hold.

Third, you may have the right to request we delete Regulated Personal Data concerning you.

Fourth, you may also the right to request your Regulated Personal Data in a portable and, if technically feasible, readily usable format.

Fifth, you may have the right to request a list of the categories of third parties to which we have disclosed your Regulated Personal Data.

Sixth, you may have the right to opt-out of processing your Regulated Personal Data for purposes of targeted advertising, the sale of your Regulated Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.  We do not sell Regulated Personal Data in exchange for money or other consideration, and we do not use your Regulated Personal Data for automated decision-making that could have a legal or similarly significant effect on you.  As stated above, Regulated Personal Data does not include personally identifiable financial information, and for information about how practices you’re your personally identifiable financial information, please also see our Privacy Notice.

To exercise your rights, please email us using the information in the Contact Us section.  If you email us, please put in the subject line of your email your state of residence and the right you are seeking to invoke:  “Right to Access,” “Right to Correct,” “Right to Delete,” “Right to Portability,” “Right to Third-Party Categories,” and “Right to Opt Out.”

You may submit multiple requests at once through an email.  Subject to certain exceptions, ordinarily there is no cost for submitting your first request; if you submit multiple requests in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests.  For requests other than an opt out request, we are permitted to use commercially reasonable efforts to authenticate you are who you say you are and if you are making a request on behalf of another, that you have the authority to do so.  If we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you.  If we cannot authenticate you or your authority, we will deny the request.  If you submit a request to opt out, we are permitted to deny the request if we have a good faith, reasonable, and documented belief that the request is fraudulent, and we will tell you that and why.

If you submit a request, we will tell you what the result is of your request (including, if you submit an access request, your Regulated Personal Data) without undue delay and within 45 days after we receive your request.  We may extend that deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why.

Delaware’s and New Hampshire’s laws include exceptions for Regulated Personal Data regulated under other laws or maintained for certain reasons or in certain contexts.  For example, it does not apply to publicly available information, including information that we reasonably believe has been lawfully made available to the general public, or to personally identifiable financial information regulated by federal law.  As another example, we will not delete Regulated Personal Data when it is necessary to maintain it to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not.  You may appeal our decision by emailing us using the information in the Contact Us section with the subject line “Appeal of Request” and including our response to your request.  We will also include this information in our response to your request.  If you appeal our decision, we have 60 days to respond.

In addition, when you visit our website, we may use the information we collect automatically through online interactions, as described above in the Cookies, Pixels, and Tracking Technologies section for targeted advertising, which we may disclose or make available to advertising and social media networks.  You may also opt-out of targeted advertising by filling in our opt-out form.

8. Contact Us

For questions Call:  781-255-6216 or Email:  privacy@dcd.auto

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