Privacy Policy

Introduction

This website, including its related mobile and online applications (the "Site"), is operated by The-Autos ("The-Autos")

The-Autos strongly support individual privacy, customer and consumer data rights, and the protection of consumer data. We value every consumer's individual right to protect data about that consumer and exercise control over use. We give all consumers the right of access to the data we collect about them and we give all consumers the option to control our use of that data—including correction and deletion upon request. The-Autos only obtains consumer data through lawful and transparent processes and will obtain explicit consent to collection of personal information where required by law. The-Autos's consumer data usage is overseen by its Data Governance Council comprised of senior executives with reporting authority to the Board of Directors.

This Privacy Policy (the"Policy") describes The-Autos's collection, use and disclosure of personal information. This Policy applies to all uses of consumer data by The-Autos and applies to all products and services, including uses in connection with the website located at Passive Information Collection The-Autos.com, all versions of the Site that The-Autos operates (including without limitation any mobile or similar versions), and offline uses of consumer data. The-Autos does not use personal information collected from the Site except for the intended purposes more fully-described in this Policy.

For clarification, this Policy also describes The-Autos's collection, use, and disclosure practices with respect to any personal information and Usage Data (as defined below) that is provided to The-Autos by parties other than the actual consumers, such as its advertisers, data providers, and third-party distribution partners that display The-Autos vehicle listings.

Please be aware that The-Autos may share information you submit through this Site with affiliates, as described below. However, each affiliate must comply with this Privacy Policy and process data in accordance with our listed procedures. With regard to service providers and other third-parties who perform services on our behalf, we require that these parties process personal information in accordance with this Policy, only as necessary to perform services on our behalf, and in compliance with applicable law. We also require third-parties to safeguard the security and confidentiality of the personal information they process on our behalf by implementing appropriate technical and organizational security measures and confidentiality obligations binding employees who access personal information.

Please note that this Site contains links to other websites. The-Autos is not responsible for the websites, content or privacy practices of any third-party except as expressly described.

By using this Site, you acknowledge that you have read and agree to be bound by this Policy and agree that you are subject to the The-Autos Terms of Service.

Collection of Personally Identifiable Information

The-Autos is committed to obtaining user data through lawful and transparent means, with explicit consent where required by law. You are not required to provide any personally identifiable information to visit the Site. The-Autos automatically collects Usage Data (as described below) and may collect ZIP codes and other information in connection with your use of the Site (e.g., the type of car you are looking for). The-Autos collects personally identifiable information only when you make it available through your use of the Site. You may be required to provide personally identifiable information to use certain services on this Site, including, but not limited to, the "Email the Dealer/Seller" feature and to purchase and create a "Sell It Yourself" online classified listing ("Sell It Yourself Ad") and account ("Sell It Yourself Account"). In addition, you may submit personally identifiable information through the Site in other ways, including: (a) participating in online surveys, promotions, contests and sweepstakes; (b) subscribing to newsletters, editorial content, or promotional content sent via email, (c) using the Site's "Feedback" and "More Information" forms; and (d) in connection with other products, services, features, or requests made available through the Site. We also publish toll-free phone numbers for many of the dealerships that list vehicles for sale on the Site. If you dial one of these phone numbers, The-Autos or a service provider operating on The-Autos's behalf may record the date, time and length of your call and the phone number from which the call originated, along with other information that maybe captured. Any Usage Data (as defined in the next section) and/or personally identifiable information resulting from such calls may be used as described in this Policy. The types of personally identifiable information that you provide will depend on the nature of the submission, but could include your name, address, phone number, email address and credit card information.

Passive Information Collection

The Site automatically collects information and may also customize your visit through technical means, including the following:

Cookies: Cookies are small text files that are placed on your computer's hard drive by computers (or servers) to identify your computer.

Web Beacons: Web beacons (also known as pixel tags, internet tags, clear GIFs, or single-pixelGIFs) are electronic images embedded into a webpage.

IP Address Logs: The-Autos also logs Internet Protocol (IP) addresses - the location of your computer on the internet & dash; and may log device ID and information about your browser or operating system.

Cookies allow The-Autos to recognize you when you visit the Site, to personalize your experience and generally to serve you better. For example, if you enter your name, address or ZIP code on one of the Site's forms, it may be stored in a cookie, so you do not have to enter it again on other forms on the Site. Cookies and web beacons can tell us what advertising you have seen on the Site, which allows The-Autos to offer you a more diverse selection of advertising information and may also be used together to measure the effectiveness of The-Autos advertising campaigns. Cookies, web beacons and IP addresses are also used to compile data regarding Site usage (e.g., what website you came from, what pages of the Site you visit, how long you were on the Site, what type of browser you are using, what website you went to). Web beacons may also be included in emails sent by The-Autos to determine when and if such emails are opened or forwarded. You can disable cookies or otherwise manage them through tools provided with your browser software and with third-party software packages. If you turn off cookies, many of theSite's features will not work as well or at all. Information regarding use of our Site and services that is collected and/or aggregated by or on behalf of The-Autos through the use of such technical means or otherwise is referred to in this Policy as "Usage Data."

Information Use

Personally Identifiable Information Personally identifiable information collected by The-Autos through your use of the Site (including without limitation through your submission of an email address to receive promotional or other communications via email, or through you providing a mobile number to submit a lead or to receive coupon(s) or other communications via call, text or SMS) may be stored on servers or in a cookie on your computer and may be used by The-Autos for the purposes listed below. Please note that in most cases the primary purposes for use of personal information are the submission and transmittal of lead data and powering targeted advertising and user experiences; however, although The-Autos does not track exact numbers, personal information of most users is also used for the purposes listed below as secondary purposes:

• To submit and transmit lead data to The-Autos advertisers.
• To power individualized or targeted user experiences across the Site and to improve those experiences.
• To engage in attribution and analytics modeling such as lead scoring and performance reporting to advertisers.
• To confirm or fulfill a request that you make (e.g., in order to send you a price quote or other information you have requested, The-Autos may share your contact information and content interests with a participating The-Autos dealer and/or manufacturer).
• To deliver coupons and other marketing communications via text or SMS, which, by providing your mobile number to The-Autos, you have expressly consented to receive.
• To follow up on any request that you have previously made (e.g., The-Autos may contact you to determine whether the dealer and/or manufacturer responded to your original request).
• To communicate with you regarding the The-Autos service (e.g., The-Autos may send you emails or call you to confirm a price quote request or to notify you that you have received a lead regarding a vehicle you have advertised or to request that you participate in a survey).
• To send promotional materials, newsletters or other content via email, text message, or otherwise. If you no longer wish to receive a particular email newsletter or other promotion from The-Autos, you must follow the opt-out instructions included in such email newsletters, text messages, and promotions.
• To permit third-parties (to whom The-Autos may disclose personally identifiable information specifically for direct marketing purposes) to send you promotional or informational messages, but if contact is via phone or SMS only if you have first affirmatively agreed to receive such messages. You agree that the seller or other third-party may use an auto dialer to text or call, and that a portion of any call may be prerecorded.
• To manage The-Autos's business and its relationships with affiliates, customers, and other third-parties to which The-Autos may disclose personally identifiable information pursuant to this Policy.
• To assist in Site administration, analysis, research, development, optimization and other internal purposes, including, without limitation, to compile Usage Data.

Usage Data: Usage Data is used by The-Autos for administrative, analytical, research, optimization and other purposes. For example, The-Autos may use statistical analyses of Usage Data in order to measure interest in the various areas of the Site, for development purposes and to inform advertisers and partners about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.

Your use of The-Autos products or services will not be limited if you opt out of receiving telemarketing calls or texts. However, you agree that The-Autos may send to you, and you cannot opt out of, communications of a transactional or relationship nature, including, but not limited to, communications regarding fraudulent or illegal activity, the status of your Sell It Yourself Account, changes to this Policy or the The-Autos Terms of Service, as well as communications to confirm, fulfill and follow up on your Sell It Yourself Account registration or a request submitted through the Site.

Information we may collect

The-Autos collects mobile information such as your device and hardware IDs and device type, the request type, your carrier, your carrier user ID, and the content of your request, which does not by itself identify you, though it may be unique or consist of or contain information that you may consider personal. The-Autos may collect geo-location information (this may include when you use location-based products and services on the Site, and/or turn on location-based services on your mobile device). This information may reveal your actual location, such as GPS data, or it may not, such as when you submit a partial address to look at a map of the area. All requests may be sent through your mobile carrier's network and your carrier may have access to it. For information regarding your carrier's treatment of your information, please consult your carrier's privacy policies.

You may disable the collection and use of your location data through browser, operating system or device-level settings. Consent concerning use of location data may be withdrawn at any time by contacting our customer support team at: Email: privacy@the-autos.com

Information that we may share

The-Autos share the personally identifiable information that you provide with third-parties in the following cases:

1. Affiliates. The-Autos may share your personally identifiable information with affiliates in a manner consistent with this Policy.
2. Leads and Requests. If you submit a lead or request information or services through the Site, you agree that The-Autos may share personally identifiable information with third-parties as may be necessary to provide such information to or perform such services for you. For example, if you use the Site's "Email the Dealer "form in a vehicle listing to request a price quote from a dealership, The-Autos will share the information you entered with that dealership (or its designee). If that vehicle listing was provided by an automobile manufacturer on behalf of a dealer, The-Autos may also share the personally identifiable information you submit as part of the request with the automobile manufacturer and/or its affiliates. Similarly, if through the Site you request additional information from a financial institution, The-Autos will share your information with that institution. Personally identifiable information also may be included in reports to these third-parties, but only when you have intended to submit the information to the third-party as described above. After the information is provided to such third-parties, the subsequent use or disclosure of such information is subject to those third-parties' privacy policies and practices and The-Autos does not control their subsequent use or disclosure of information.
3. Sweepstakes/Promotions. In the event that you participate in a sweepstakes, contest or other promotion on the Site that is sponsored by The-Autos and a third-party, The-Autos reserves the right to share personally identifiable information collected in conjunction with the sweepstakes, contest or promotion with the third-party. After the information is provided to such third-parties, the subsequent use or disclosure of such information is subject to those third-parties' privacy policies and practices.
4. Direct Marketing. Except as provided herein, it is The-Autos's general practice not to disclose personally identifiable information of our customers to third-parties specifically for the third-parties' direct marketing purposes. If you are 18 years of age or older and have affirmatively agreed to receive third-party direct marketing materials, The-Autos may share personally identifiable information with third-parties for direct marketing purposes. Although The-Autos will notify all third-party direct marketers that the information provided to them is confidential, the subsequent use or disclosure of such information is subject to those third-parties' privacy policies and practices.
5. Service Providers. The-Autos may work with third-parties that provide services on its behalf, including, among others, providers of analytical, attribution, development, promotional, research, credit card processing, technical and other services. For example, The-Autos may ask that a third-party conduct an online survey or sweepstakes or send newsletters on its behalf. Similarly, if you make a payment to The-Autos by credit card, The-Autos may share your personally identifiable information and credit card information with a third-party in order to process credit card transactions, or such information may be collected directly by the credit card processing service provider on The-Autos's behalf. In such cases, The-Autos asks that the third-party maintain your personally identifiable information as confidential and use the information only to perform the services specified by The-Autos.
6. Email List Opt-Outs. In the event The-Autos sends promotional emails to you on behalf of third-party advertisers and you inform The-Autos you wish to opt out of future promotional emails from a particular third-party, The-Autos may share your email address with that third-party so the third-party may add you to its opt-out lists.
7. Other. The-Autos expressly reserves the right to release any personally identifiable information or other information you provide to third-parties under the following circumstances: (a) when required by law or legal process, (b) to investigate and/or take action against illegal activity, suspected abuse or unauthorized use of the Site, (c) to protect the property or safety of our users or others, (d) to enforce our Terms of Service and (e) in connection with any sale or other transfer of ownership of all or a part of The-Autos. Further, if you make any personally identifiable information publicly available on the Site, The-Autos reserves the right to disclose such information to third-parties, including, without limitation, insurance companies and The-Autos's affiliates and third-party distribution partners.

Please note that the messages that The-Autos sends to you to confirm, fulfill or follow up on a request may incidentally include promotional material or other content from The-Autos or its partners. The-Autos reserves the right to share aggregated non-personal data elements of Usage Data such as clicks, web impressions, etc. with any third party for any reason.

Sell It Yourself Ads

When purchasing an Sell It Yourself Ad, it is important to note that any information you choose to include in an Sell It Yourself Ad maybe made publicly available via the Site and other media in which The-Autos vehicle listings are published, including third-party Web sites and print publications. You are required to include at least your phone number and, optionally, an email address to allow users to contact you regarding your Sell It Yourself Ad. As such, you may receive unsolicited phone calls and emails from third-parties. Except for required information, you should not include any contact or other information in an Sell It Yourself Ad that you do not want other parties to see or use. If you require assistance to access, verify the accuracy of, or change the personally identifiable information in your Sell It Yourself Ad account, or to remove your Sell It Yourself ads, please contact our customer support team at: Email: privacy@the-autos.com

Changes to this Policy

We reserve the right to update and periodically amend this Policy at our discretion and at any time. If we make changes to this Policy, amendments will be posted online and the date of update will be included. Your continued use of The-Autos and its affiliated sites after any such update indicates your agreement to the same.

Security and Protection

Your personally identifiable information is one of our most valuable assets. We take steps to keep it physically secure in our data centers and it is accessible only to authorized personnel as needed to perform operations governed by this policy. As such, we have external independent audits conducted at least every two years to ensure data security and assess, identify and address data security risks including use of industry standard cyber security protections. For example, when The-Autos collects credit card information from you, The-Autos uses Secure Socket Layer (SSL) encryption, the industry standard for protecting privacy in web transactions. Additionally, all current and new-hire The-Autos employees receive regular security and privacy training. Please keep in mind that despite these measures, The-Autos cannot guarantee or warrant 100 percent security of its servers and databases nor that personally identifiable information that you submit through the Site will not be intercepted or otherwise disclosed. However, in the event of a data breach or material policy change, The-Autos will notify affected customers in a timely manner.

In the past year, we have not incurred any monetary losses related to data breaches or legal proceedings associated with user privacy, nor have we had any data breaches impacting consumer personal information. The number of law enforcement requests for personal information received by The-Autos in any given year as well as the number of users whose information was requested is confidential; however, over the past ten years the number of such law enforcement requests has averaged fewer than ten per year. The-Autos provide requested information in all cases where it is in receipt of a duly-issued subpoena or other court order. As of the date of this Policy, The-Autos has not received any governmental requests to remove or block content on its site.

Children Policy

The-Autos believe that it is especially important to protect children's privacy online. The-Autos does not knowingly collect or use any personally identifiable information from children under the age of 18 and The-Autos does not knowingly provide any personally identifiable information, regardless of its source, to any third-party for any purpose whatsoever from visitors younger than 18 years old. No information should be submitted to or posted at The-Autos by visitors younger than 18 years old.

Links

This Site contains links to other sites. While The-Autos encourages our business partners to adopt privacy policies that build users' trust and confidence in the internet, The-Autos is not responsible for the privacy practices or the content of websites linked to the Site or any third-party products or services offered through the Site.

Privacy and Consumer Data Dispute Resolution

Access to information that we collect and maintain about you may be available to you. For example, if you created a password-protected account within the The-Autos Sites, you can access that account to update the information you previously provided. Additionally, if you believe that information we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the information by contacting us

Disputes

If you choose to visit the The-Autos site, your visit and any dispute regarding privacy is subject to this Privacy Statement and our Visitor Agreement, including limitations on damages, resolution of disputes, and application of the law of any state in Nigeria.

Third Party Information

As noted above, affiliates, third-parties who place advertisements on this website, and other third-party service providers may collect and use information about your visits to and use of this website through the use of cookies, pixels, web beacons and other similar technologies. For example, we work with companies that collect statistical information regarding Site usage and provide related analytical services. We may work with third-party advertising companies that use cookies and web beacons to serve advertisements when you come to the Site and to generate statistics and metrics related to the delivery of such advertisements. We also may work with third-party advertising platforms and networks that use cookies, web beacons and other technologies to collect non-personally identifiable information about your visits to and interactions with this Site and other websites in order to provide targeted emails and other advertisements about goods and services of interest to you across networks of websites (which may or may not include this Site). These third-parties may also use this information for determining or predicting the characteristics and preferences of their respective advertising audiences, for measuring the effectiveness of their advertising and for other purposes.

Third-party service providers may also collect information from your devices and may combine personal and non-personal information about you with information from other sources including your visits to this and other websites, mobile websites and/or mobile applications across your various devices. These activities may enable them to identify you in order to provide content and advertisements about goods and services of interest to you across those various devices.

Consumer Requests

The-Autos respect your control over your information and, upon request, we will confirm whether we hold or are processing information that we have collected from you. Additionally, all consumers may request that we edit, correct or delete personal information we have collected about them.

Please note that under certain circumstances we may not be able to fulfill a request, such as if the request interferes with regulatory obligations, impacts legal matters, we cannot verify your identity, or the request involves disproportionate cost or effort; but in any event we will respond to your request within a reasonable time frame and provide you an explanation.

Regarding personal information about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity which determined the means and purposes of processing all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal information.

If you wish to exercise your rights to view, correct, or delete information we may have collected about you, please do not hesitate to contact us at: Email: privacy@the-autos.com