Privacy Policy

PRIVACY POLICY

Updated: December 31, 2025

OUR APPROACH TO PRIVACY

We are committed to protecting the privacy of personal information and the responsible use of that information to deliver personalized, relevant content to our customers. This Privacy Policy applies to this website or mobile application and the websites and mobile applications that display this Privacy Policy(collectively, Sites). We may also operate additional websites or mobile applications that are governed by their own privacy policies. This Privacy Policy describes our policies and procedures for the collection, use and disclosure of your information and data on these Sites and the services available through them (Services).

Our Sites also contain a link to our Terms of Use which govern your use of these Sites and the Services available through them. You understand that by using these Sites or Services you agree to the terms of both this Privacy Policy and the Website Terms of Use.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

The personally identifiable information we collect may include your name, address,zip code,phone number, email address, and other identifying information, and may also include information about vehicles you own or lease such as sales and service transaction history, vehicle payments, VIN, and mileage(collectively, Personal Information or PI). We collect PI in a number of different ways and from a number of different sources.We collect PI you provide us through our Sites or when using certain aspects of our Services. We may also collect PI you provide to manufacturers, our authorized vendors, or affiliates, as well as information we obtain from third party databases(collectively, our Partners).

As part of our Services, we may communicate with you via email, call, chat or text. In this capacity, we would have the ability and authorization to read or listen and retain the content of those communications, including contact information.In all cases, the information we may retain and how we may use it are subject to this Privacy Policy and applicable law.

We may also collect usage information about how our Sites and Services are accessed and used. This may include information such as your computer’s IP address, browser type, type of device used, pages on our Sites that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

HOW WE USE AND SHARE YOUR INFORMATION

We use your PI to provide information you request about our products or services, to respond to your inquiries,and to customize information and advertising that we believe may be of interest to you. We may also use your PI to provide you with marketing materials, as well as other information we believe may be relevant to you. We also use remarketing services to advertise to you on third party websites, such as Google, Bing, YouTube and Facebook and their partners. To control or opt out of any of their ad services, or to review their privacy policies, please visit their sites.

We may also use your PI by combining it with non-personal information and aggregating it with information collected from others. We use this aggregated data in a number of ways, such as to improve the quality and value of our Services and to analyze and understand how our Services are used. In addition, we may provide aggregated data to our Partners so that they may understand how people use our Services or their own.

Your PI may be shared with our Partners, and may also be disclosed to third parties who work with us or our Partners. Vehicle manufacturers, for example, may use that information to contact you. We may also work with third parties that provide certain functions or services on our behalf, such as marketing,communications, analyzing data or authenticating contact information.

We require our third party service providers to contractually commit to protecting your PI in accordance with both industry standards and applicable law. While we have implemented policies and procedures to protect PI, we cannot control, and are not responsible for, the manner in which our Partners or other third parties use that PI.Accordingly, you should review their privacy policies, as well.

EXTERNAL LINKS

Our Sites or Services may contain links to other third-party websites. After you leave our Sites, we have no control over the information collected from or about you. We are not responsible, and assume no liability, for the privacy policies and/or practices on any third-party websites. This Privacy Policy only governs information collected by us on our Sites.

COOKIES,ETC.

We use a number of technologies to automatically collect information, including cookies, tracking pixels and web beacons. “Cookies” are small text files sent from a web server that are stored on your device and enable a site to remember you or your preferences. We may use cookies to recognize you and optimize your experiences when visiting our Sites and using our Services. Tracking pixels are small images utilized to track a user, typically for advertising or analytics purposes. Web beacons allow data to be exchanged between systems. Our Sites may also be monitored by one or more third-party monitoring software(s), and may capture information about your visit that will help us improve the quality of our Services. We may use one or more of these technologies on our Sites to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications. For data being collected through one of these technologies, Apollo Capture, you may opt out by clicking here: Unsubscribe.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. However, if you do not accept cookies, you may not be able to use all of the features of our Sites or Services.Some browsers incorporate a “Do Not Track” (DNT) feature that, when turned on, signals to websites and online services that you do not want to be tracked. However, as there is no accepted standard for how to respond to DNT signals, we do not currently support DNT signals, other than cookies.

HOW WE PROTECT YOUR DATA

We use safe guards that satisfy generally accepted industry standards to preserve the integrity and security of your PI. However, we cannot guarantee the security of information you provide us with certainty or warrant it will not be accessed, disclosed, altered, or destroyed by unauthorized persons. We will make all legally required disclosures of any breach of the security, confidentiality,or integrity of your PI, in the manner and within the time periods required by applicable law.

JURISDICTIONS

Your PI is collected and used by us within the United States.We make no representation that our Privacy Policy complies with the laws of any foreign jurisdictions, including the European Union’s General Data Privacy Regulation. If you choose to provide us with PI from outside the United States, you do so at your own risk and are responsible for compliance with any applicable foreign laws.

COMPLIANCE WITH LAW ENFORCEMENT

We cooperate with government and law enforcement officials, as well as private parties,to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties that we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process,including, but not limited to, subpoenas, to protect our property and rights or that of a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or subject to legal action.

OUR POLICY TOWARDS CHILDREN

Our Sites and Services are not targeted to or intended for use by children. We are concerned about the privacy and safety of children when they use the internet.Accordingly, we will not knowingly request PI online from anyone under the age of 13 without prior, verifiable parental consent.Unfortunately, we cannot always determine the age of a visitor to our Sites or user of our Services.

CORPORATE TRANSFERS

In connection with a corporate merger, acquisition, divestiture, asset sale, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves some or all of our assets, including your PI.

OPTING OUT

If you wish to stop receiving email communications from us, you may “unsubscribe” using the link at the bottom of the email you receive. If you wish to be placed on our postal mailing Do Not Contact list, see the “How to Contact Us” section below and provide the name and address as listed on the mailing. To stop text communications, respond to the text with the words “STOP”. You may also control ads appearing on your browser or mobile device by adjusting your settings or using third party ad blocking tools.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain rights concerning your personal information, including the right to know how and for what purpose businesses collect it, the right to access your data, the right to opt-out of it being sold to third parties and, subject to certain exclusions for legitimate business purposes, the right to have it deleted.If you have further inquiries about your information under the CCPA or wish to opt-out, please contact us as specified below under How to Contact Us.

CHANGES TO OUR PRIVACY POLICY

We may modify our Privacy Policy, at any time and for any reason, by posting the revised Privacy Policy on our Site.Your use of our Sites or Services after any such posting indicates your acceptance of our modified Privacy Policy.

HOW TO CONTACT US

If you have any questions or concerns regarding your privacy when using our Sites or Services, or wish to exercise your rights under the CCPA, please click here to email us: Contact Us. California residents may also call us toll free at 1-800-624-7094. In certain circumstances, you may have the right to access, update or to delete the information we have on you.We will make every effort to respond promptly and address your concerns.

Foureyes® Supplemental Privacy Notice

We use the analytics and reporting system, Foureyes®, (the "Tool") provided by our website analytics vendor, Adpearance Holdings, LLC dba Foureyes, a Delaware limited liability company.

When used in this Foureyes® Supplemental Notice ("Foureyes Privacy Notice"), "we", "us", and "our" may refer to us, ATLANTIC MITSUBISHI, ("Dealer"), and/or Foureyes, its affiliates or subsidiaries (collectively, "Foureyes"), as applicable. This Foureyes Privacy Notice may be posted or displayed separately on the site or may be appended to another privacy notice or policy posted or displayed on the site ("Additional Privacy Notices"). To the extent an inconsistency or conflict arises between the terms of this Foureyes Privacy Notice and any Additional Privacy Notices, the terms of this Foureyes Privacy Notice will control with respect to the Tool. However, this Foureyes Privacy Notice applies only with respect to the Tool, and not any other features or functions of the site.

This Foureyes Privacy Notice describes how the Tool works when you visit this site, and how it collects, uses, and discloses your personal information. Please read this Foureyes Privacy Notice carefully. We may also update or modify this Foureyes Privacy Notice at any time by posting it to this site. Please refer to “Effective Date and Modifications” below for the effective date of this Foureyes Privacy Notice.

By using this site or our phone system, you consent to the collection, use and disclosure of your personal information as described herein. If you do not consent, you may opt-out of the use of the Tool (as set out below). You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below.

How the Tool Works. For each visit to the site, the Tool: (1) identifies the traffic source for the visit; and (2) issues a unique visitor ID number and visitor traffic number. As the user navigates the site, the Tool may track and store the pages visited and features used. The Tool also collect and link information provided through forms featured on the site or during phone calls with a visitor ID number. Using local storage, the Tool may also store data in the user's Internet browser or in a data repository on the user's device for purposes of associating the user with his or her user profile. The Tool operates only on the site and our phone system – it does not track information regarding your use of other sites or activities on other sites.

Purpose of Collection. Using the Tool, we collect personal information for purposes related to managing, marketing and developing our businesses as further described herein and including:

establishing and managing business relations with you providing us with information in order to allow us to analyze usage of the site, improve the site, the Tool, and for development of new services and products; marketing products and services to you; and for other purposes related to the management of our relationship.

Foureyes further collects personal information for purposes of operating and administering the Tool for subscribers of the Tool, such as the Dealer and other third parties.

Information Collected and Usage of Information. The Tool creates a user profile including the user's visitor ID number and any information the user directly provides through the site or other interactions with the site and/or the company associated with the site (e.g., phone calls and chats). This information may include a user's personal information, such as name, personal phone number, home address, email address, and similar information, whether or not this information is complete or partially entered by the user. We will not ask for or knowingly associate financial information with your user profile. Unless the user provides us personal information, the information we collect using the Tool and which is associated with the user profile is limited to information automatically collected as a user browses and interacts with the site, such as the user's browser type, available plugins, Internet service provider, Internet protocol ("IP") address and/or mobile device ID, and pages visited, features used, and activities performed on the site. Except as otherwise expressly set forth herein, the information collected and associated with a user profile is used, maintained and disclosed in accordance with the restrictions, consents, and permissions in this Foureyes Privacy Notice and any Additional Privacy Notices (if any), including obligations of confidentiality and restrictions on disclosure to third parties.

You expressly acknowledge and agree that the information associated with your user profile may be used to understand and analyze the usage of the site, and for the purposes of marketing products or services to you. In particular, where it is lawful to do so (please see additional note below on Canada’s Anti-Spam Legislation), the Tool may automatically generate and send email marketing communications to you (to the extent you have provided your email address as part of your interactions with the site and/or the company associated with the site). The content of those email marketing communications may be based on the pages that you have visited and/or the features you have used on the site. To opt-out of receiving the email marketing communications generated by the Tool, please see the Opt Out instructions below.

Third Party Disclosure. Unless required or permitted by law, the information associated with your user profile will not be used or disclosed to third parties other than for the purpose for which it was collected, without the user's prior consent.

For purposes of clarity and in addition to any disclosure to third parties described in any Additional Privacy Notice, the information collected by the Tool and/or associated with your user profile may be disclosed by Foureyes to the following category of third-parties or as otherwise authorized or required by law:

(i) OEMs: Foureyes, or its affiliates, partner with various automotive manufacturers (“OEMs”) as a part of their respective certified marketing programs and their affiliate partners that manage the OEM’s digital marketing, traffic generation, lead optimization, online-offline retail integration, customer retention, and loyalty strategies.

(ii) Unite Digital or its affiliates (“Unite Digital”): Foureyes, or its affiliates, partners with Unite Digital to provide certain OEM’s digital marketing, traffic generation, lead optimization, online-offline retail integration, customer retention, and loyalty strategies.

(iii) Third Parties: Foureyes, or its affiliates, are parties to certain agreements with third parties with whom such parties conduct business regarding the Tool and/or the information collected by the Tool and/or associated with your user profile. Foureyes may disclose your personal information to such third parties who may provide services that facilitate the operation of the Tool, assist us in providing an improved customer experience to you, or assist us in providing improved services to Foureyes’s customers.

Blocking and/or Disabling the Tool. The Tool gathers information about the user's computer hardware and software configurations to identify the user each visit and associate the user with their existing user profile. Unlike a "cookie", and except for local storage discussed below, the system does not store a file on the user's computer; therefore, the user information gathered is not deleted when the user clears their cache and/or deletes their cookies. In order to disable the tool, see the Opt-Out instructions below.

Opt-Out. The Tool's opt-out functionality is cookie based, so for it to work for you, your browser must allow third party cookies. If you change computers or browsers or delete this cookie, we will no longer know you have opted out, so you will need to opt-out again. To opt out, Click Here. Note that opting out of cookies on the Dealer’s site will not be an opt out with respect to the Tool.

You may also opt-out of, or withdraw your consent to (where the Canadian Anti-Spam Legislation applies), receiving email marketing communications generated by the Tool by sending a request to support@foureyes.io, or by clicking the unsubscribe link on any such email marketing communication you receive. Please note that clicking the unsubscribe link may only result in your no longer receiving marketing communications generated by the Tool; you may still receive other email marketing communications from the Dealer. If you opt out or withdraw consent with the Dealer or on the Dealer’s site, you will still also need to opt-out or withdraw your consent regarding the Tool as set out in this paragraph.

As noted above, the Tool may also collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches. Browser web storage enables websites to store data in a browser on a device. When used in "local storage" mode, it enables data to be stored across sessions. Similarly, an application data cache is a data repository on a device. You may stop local storage from being used by modifying your Internet browser settings, but stopping local storage may result in the site having impaired or limited functionality. Furthermore, disabling local storage will not block the Tool from operating; rather, it will only prevent the Tool from collecting and storing information locally on your device. To disable the Tool, see the Opt-Out instructions above. Further, you should refer to the help provided by your Internet browser for the most up-to-date and accurate instructions on disabling local storage.

Do Not Track Signals. IF YOU DO NOT WANT THE TOOL TO GATHER INFORMATION ABOUT YOUR USER PROFILE AND SITE VISIT, NOW AND FOR FUTURE BROWSING SESSIONS, PLEASE REFER TO THE OPT-OUT PROCEDURES ABOVE /OR REFRAIN FROM USING THE SITE. WE DO NOT CURRENTLY RESPOND TO DO NOT TRACK (DNT) SIGNALS.

Accessing, Correcting, Updating Your Personal Information. You have a right to know what personal information we have about you and correct any inaccuracies. To review your information that is collected using the Tool, contact Foureyes by email at support@foureyes.io or by regular mail addressed to Foureyes Holdings, LLC, 2035 NW Front Ave, Suite 300, Portland, OR, 97209.

Data Retention We keep information associated with your user profile for as long as we think is necessary or advisable to fulfill the purposes for which it was collected, and we reserve the right to retain it to the full extent permitted by law. If required by law, a governmental order, or similar legal process, we will disclose your information.

Children.The site is intended for adults who have reached the age of majority in their state, province or territory of residence. The site is not directed at children under age 16. We do not knowingly collect personal information from children under age 16, and if we learn that the Tool has collected information of a child under age 16, we will delete the information.

Canada’s Anti-Spam Legislation We are committed to complying with Canada’s Anti-Spam Legislation and will only send you email marketing communications (or other commercial electronic messages, as defined in Canada’s Anti-Spam Legislation) where it is lawful to do so. If you have consented to receiving marketing materials from us, you can withdraw your consent to receiving email marketing communications generated by the Tool by sending a request to support@foureyes.io, or by clicking the unsubscribe link on any such email marketing communication you receive. Please note that clicking the unsubscribe link may only result in your no longer receiving marketing communications generated by the Tool; you may still receive other email marketing communications from the company associated with the site.

European Union Privacy. If the processing of your information in connection with the Tool is subject to the General Data Protection Regulation 2016/679 ("GDPR"), we have additional obligations and you have additional rights under the GDPR. These rights and obligations are as follows:

We will process your personal information using the Tool in order to support our provision of services in connection with your use of the site. The lawful bases for processing your personal information may include:

When you have given consent; When processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; When processing is necessary to protect Foureyes's or our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights; When processing is necessary for compliance with a legal obligation to which we or Foureyes are subject; and When processing is necessary to protect the vital interests of the data subject or of another natural person.

You have many rights with respect to our processing of your personal information. Depending upon the lawful basis of processing, you may have the right to withdraw consent or object to our processing your personal information.

You have the right to be informed about your personal information and how it is being processed, to access, correct and erase personal information, to restrict further processing, to obtain and reuse your data for your own purposes across different services and to object to our processing. You also have the right to lodge a complaint with the relevant EU supervisory authority.

If we transfer your personal information to a recipient in a country outside the European Economic Area, we will do so in compliance with applicable laws with respect to such transfer.

Storage in the United States. The Tool is operated and controlled from offices in the United States. If you access the site from locations outside the United States, you do so at your own risk and are responsible for compliance with applicable local laws. Your access to the site constitutes your agreement to our storage of your personal information within the United States. You understand that your personal information may be stored and/or processed in the United States, notably at the address indicated above, that it may be subject to the laws of the United States and that it may be accessible to tribunals, courts, law enforcement and regulatory agencies in the United States.

Effective Date and Modifications.This Foureyes Privacy Notice is effective on October 15, 2022. We review this Foureyes Privacy Notice at least annually and may amend it from time to time. Except as otherwise required by applicable law, our only notification will consist of posting a new policy.

Supplemental California Privacy Information. We are required by law to provide California residents with certain additional information about their privacy rights under the California Consumer Privacy Act. This information is available at the following link: foureyes.io/privacy-policy/ccpa-privacy-addendum.

Contacting Us.If you have any questions, complaints, or comments about this Foureyes Privacy Notice, your information, our third-party disclosure practices or your consent choices in connection with the use of the Tool, please contact Foureyes’s privacy officer at privacy@foureyes.io.