EFFECTIVE DATE: May 31, 2022

WellCar, LLC. and all of its subsidiaries collectively values your privacy. In this Privacy Policy, we describe the information that we collect from you when you apply for a vehicle service contract through our website, www.mywellcar.com (the “Site”), any mobile versions of this Site, and through other interactions with you (e.g., surveys, email/phone correspondence, etc.). We also disclose how we will use and share that information.

We describe your choices regarding the use, access and correction of your personal information. By using this Site and the online products and services (“Services”), you agree that your information, including personal information, will be handled as described in this Privacy Policy, which is incorporated by reference into our Terms of Service. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party resolution provider (free of charge) at https://feedback form.truste.com/watchdog/request

Information We Collect About You

We collect information directly from you, from third parties, and about you as you use the Site and the Services.

Information We Collect Directly From You

When You Apply for a Vehicle Service Contract. We collect personal information from you when you visit this Site, such as when you become a member (e.g., register), purchase products through this Site and request information through this Site.

When you register with our Site, we will collect your name and your email address. If you choose to apply for a Vehicle Service Contract, we collect information about your vehicle, such as the make and model, its age, mileage, Vehicle Identification Number (VIN), and other pertinent information.

We also collect billing and contact information. You have the option to provide us with more demographic information such as your gender, activities, lifestyle and automobile preferences. If you provide this information to us and are a registered member, we maintain the data as part of your profile.

Contests or Promotions. We offer regular contests and promotions. If you choose to participate, we collect the information that you submit as part of your entry. We may combine this information with information that we already have collected from and about you.

Surveys and Focus Groups. We may invite you to participate in a survey or a focus group. We will collect the responses you provide and aggregate them with those of other participants.

User Generated Content. Portions of our Site allow you to submit your own content. We may use the information that you submit in those portions with other information that we have collected about you.

Contacting Us. If you contact us via this Site, email, phone, or other means, we will collect the information that you provide to us during that contact and we may combine it with other information that we maintain about you.

Blog. Our website offers publicly accessible blogs or community forums. Any information that you provide in these areas may be read, collected, and used by others who access them. To request the removal of your personal information from our blog or community forum, contact us at support@wellcar.us. We may not always be able to remove your personal information, in which case we will let you know in writing.

Testimonial. With your consent, we may post your testimonial along with your name. If you wish to update your testimonial, you can contact us at support@wellcar.us.

Refer a Friend. If you participate in our Refer a Friend program, we will collect your email address and your friend’s email address. We store both addresses for future use, including the sending of promotional emails. Your friend may contact us at support@wellcar.us to request that we remove this information from our database.

Third Parties. We may collect information about you from third parties. Specifically, we obtain marketing data from third parties. This info is added to our existing database and we may combine it with information that we already maintain about you. We also may collect information about the claims that you make under the Vehicle Service Contract. We will use this information for analytical purposes and, where applicable, to provide services to you.

Information We Collect Automatically.

We use cookies, web beacons, and other automated devices to collect information about all visitors to this Site. Specifically, we collect the following information about your use of our Site via these technologies: your browser type and operating system; web pages you view; links you click; your IP address; your interaction with the Site; length of time you are logged into our Site; and websites visited before our site.

When using our mobile site, you may search for products and Services in the area in which you are located. If you choose to do so, we may collect your geo-location information to search for the applicable products and services. We also personalize and improve your individual viewing experiences on our Site and provide information that may be of interest to you.

We will request your permission before collecting your location information. You can disable our collection and use of your location by turning location services off on your device. If you are using a mobile device, we collect your device type and other information collected by our analytics providers. For registered users, we associate this information with your username and combine it with other information that we have collected about you.

Data Security

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Whenever we collect sensitive information, including credit card data, the information is encrypted and

transmitted to us in a secure way. This is verified by the closed lock icon at the bottom of your web browser and the “HTTPS” at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment. If you have any questions about the security of your personal information, you can contact us at support@wellcar.us.

How We Use Your Information

We use the information that you provide to us through this Site, including your personal information (collectively, “information”), for the following purposes: To provide the Site and Services to you, to communicate with you about your use of the Services available on the Site, your use of the Site, and for other customer services purposes.

Data can be used to record your automobile preferences, to issue invoices, administer accounts, collect and process payments, to provide tips or guidance and to inform you of new features on this Site. We also use it to provide other information that may be of interest to users, to personalize the service and to tailor your experience at the Site.

Our team uses the data to send you emails, including e-newsletters, personalized offers and other promotions about products and services that we believe would be of interest to you. It’s also used to send other communications about the products and services you have purchased or available by WellCar; with your consent, we also may contact you with SMS text messages.

Information is used to manage our Site, diagnose technical problems, improve content and allocate the resources of our systems so that your experience with our Site is as efficient as possible. It’s used to process and track your transactions and to send you information about our and our affiliates and business partners’ products and services and other information and materials that may be of interest to you. Plus, we use it to develop, enhance, market, sell or provide WellCar Products or Services or those of companies with which we have a commercial relationship.

Your information is also needed to evaluate credit standing and to match credit bureau or credit reporting agency information, to investigate, detect and protect us and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activities and to effect a corporate transaction in connection with the sale, merger, spin-off or other corporate reorganization of our corporation. Finally, we use the information to audit compliance with our policies and contractual obligations and we strive to always comply with any legal or regulatory requirements or provisions.

Sharing Your Information

We will share your personal information with third parties only in the ways that are described in this privacy policy. Here are a few ways your information is used.

Vehicle Service Contract Providers/Financing Companies.

The Vehicle Service Contracts made available through this Site are provided by third parties. We share all information that we collect about you with those parties, which use the information to facilitate our ability to provide the Services that you purchase from us. If you choose to finance your Vehicle Service Contract, we provide your information to a separate third party, which collects payment from you and handles the financing of your purchase. Their privacy policies should be further reviewed.

Affiliates.

We may share your personal information with our affiliates or our subsidiaries for marketing and other purposes. Their use and disclosure of your personal information will be subject to this Privacy Policy.

Service Providers.

We disclose the information that we collect about you to third-party vendors, service providers, contractors, or agents who perform functions on our behalf. These third parties may provide customer service, manage our sites and handle data processing, among other tasks. These companies are authorized to use your personal information only as necessary to provide these services to us.

Joint Partners.

We may collaborate with other companies to offer you additional products or Services, such as sweepstakes, raffles and promotions. We share personal information that is necessary for these other companies to provide the Products or Services that you have requested. This policy does not cover the use of your personal information by these other companies. Read the company’s privacy policy before requesting any of its products or services.

We also may share your information for the following reasons:

Business Transfers.

If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected about you to the acquiring company.

You will receive a notification via email and/or a prominent notice on our website for changes in ownership, uses of your personal information, and choices you may have regarding your personal information.

In Response to Legal Process.

In some situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We also may disclose the information that we collect about you to comply with the law, a judicial proceeding, court order or another legal process, such as in response to a subpoena.

To Protect Us and Others.

We may disclose the information we collect about you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy.

Cookies and Other Tracking Technologies

We and our third-party service providers use cookies or similar technologies to track user activity, collect website, application data and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website.

Cookies.

Cookies allow a web server to transfer data to a computer for recordkeeping and other purposes. We and our third-party service providers use “cookies” on this Site to, among other things, better serve you with tailored information and facilitate your ongoing access to and use of the Site. There are two types of cookies: session-based and persistent cookies. In addition, we also allow vendors to use cookies on our Site.

Session Cookies.

Session cookies only occur during an online session. They disappear from your device when the browser closes or the device is off. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site.

Persistent cookies.

Persistent cookies stay on your device after you close your browser or turn off your device. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.

Third-Party Cookies.

We engage third parties to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we allow third parties to apply cookies to users of our Site, where permitted by law, and subject to your right to opt-out through the Network Advertising Initiative (as discussed below).

We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze site usage. Such third parties may combine the information that we provide about you with other information that they have collected.

Disabling Cookies.

Most web browsers automatically accept cookies. If you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers tells you how to change cookie settings. Visitors to this Site who disable their web browsers’ ability to accept cookies can browse the Site; but many site features will not function properly if you do not accept cookies.

Web Beacons, Pixel Tags and Other Technologies.

We use web beacons, such as clear GIFs, web bugs or pixel tags, as tiny graphics with a unique identifier similar in function to cookies. In contrast to cookies, clear GIFs are embedded invisibly on web pages. We use clear GIFs in connection with our Site to track the activities of website visitors, help us manage content, and compile statistics about website usage.

We and our third-party service providers also use clear GIFs in HTML emails to our customers to help us track email response rates, measure the success of our marketing campaigns, identify when our emails are viewed and track whether our emails are forwarded. We use technologies such as scripts in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

Site Analytics

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve site functionality.

Third-Party Applications

Third-party applications are available on this Site. The owners or providers of those third-party applications can collect personally identifiable information from you. Their collection of information is bound by their own information collection policies and practices.

Third-Party Advertisers

We display advertisements on the Site. Some of the advertisements are based on the collection of personal information and others are based on the collection of aggregate information. Please see the bottom of this section for opt-out information. We use third parties such as network advertisers to serve advertisements on our Site.

Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs) and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy. We may provide these third-party advertisers with information about your usage of our Site and our Services. You can opt-out if you wish.

You may opt-out of many third-party ad networks. The website

HTTPS://WWW.NETWORKADVERTISING.ORG/OPTOUT_NONPPII.ASP provides information about the Network Advertising Initiative (“NAI”) members and your choices regarding having this information used by these companies, including how to “opt-out” of third-party ad networks operated by NAI members.

You also may contact Direct Advertising Alliance (“DAA”) at HTTPS://WWW.ABOUTADS.INFO/CHOICES/ for information about opting out of targeted advertising and your choices regarding having information used by DAA member companies, including how to “opt-out” of third-party ad networks operated by DAA members.

Opting out of one or more NAI members or About Ad members (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you, but it does not mean you will no longer receive any targeted content or ads on our Sites or other websites.

When We Advertise on Third-Party Sites

When you visit a site on which we advertise and click through our advertisement, we may place cookies on your computer or use pixel tags.

Opting-Out

You may opt-out of receiving email communications from us by following the instructions contained in the email. You also may modify your communications preferences by accessing your account.

Social Media Widgets

Our website includes Social Media Features and Widgets. These Features collect your Internet protocol address, which page you are visiting on our website and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

Links

Third-party links are available on the Site. When you click a third party’s link from the Site, you will enter that third party’s site. We are not responsible for third-party sites. You should carefully review the privacy statements to see what you agree to.

Changes to the Privacy Policy and Changes

We may change or supplement this Privacy Policy occasionally. If we make a material change to this Privacy Policy, we try to notify you of the change by posting prominently on the Site and/or by emailing registered users of the change.

How to Access, Modify or Close Your Account

Upon request, we will provide you with information about whether we hold any of your personal information. You may correct, update, amend, delete/remove or modify the information in your account by logging into your account or by emailing our Customer Support at support@wellcar.us.

We will respond to your request to access within a reasonable timeframe. If you request that we close your account, we will do so to the extent possible. Once your account is closed, you will not be able to use the services available on our Site to Members unless you re-register. We will retain your information for as long as your account is active or as needed to provide you with services. We will retain and use your information as

necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Your Texas Privacy Rights

Under Texas Law, Texas residents have the right to request in writing from businesses with whom they have an established business relationship (a) a list of the categories of personal information, such as name, email and mailing address and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties direct marketing purposes and (b) the names and addresses of all such third parties.

To request the above information, please email us at: support@wellcar.us. We will respond to such requests for information access within 30 days following receipt at the email or mailing address stated above. We are only required to respond to each customer once per calendar year.

User-Generated Content

Certain portions of our Site permit you to submit your own content. Any information that you post to our site may be viewable by any other visitor to our Site. We are not responsible for the privacy of any information that you choose to post to our Site or for the accuracy of any information contained in those postings. We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy.

Contact Information

For any questions related to this Privacy Policy, please contact us at: support@wellcar.us.