DATA PRIVACY POLICY

DCD Automotive Holdings, Inc. (“DCD”) and its affiliates* are committed to respecting and protecting the privacy rights of our customers and all visitors to our websites and our dealerships. We take this matter very seriously, and have instituted policies and procedures to ensure that your privacy rights are safeguarded. The following explains what information we collect, what we use it for and what we share with our affiliates.

INFORMATION DCD COLLECTS

The types of personal information we collect depends on the nature of your interaction with DCD, and the product or service you purchase with us. This information includes: Your name, address, e-mail address, phone number, Social Security number and income, account balances and payment history, credit history, and credit scores. We collect this information from you when you inquire about a vehicle or service through our website, purchase or lease a vehicle and/or finance a vehicle through one of our dealerships. We also collect personal information from third parties such as credit bureaus, affiliates or other companies. This information will only be used in compliance with state and federal law. * Our “affiliates” include Boch Toyota, Boch Honda, Boch Toyota South, Boch Honda West, Boch Nissan, Boch Nissan South, Boch Chevrolet, Boch Hyundai, Boch Collision Center, Nucar Tarbox Toyota, Nucar Tarbox Hyundai, Nucar New Castle, Nucar Automall Tilton, Nucar Lannan Chevrolet of Lowell, Nucar Lannan Chevrolet of Woburn, Nucar Ford of Plymouth, Nucar Preowned Gorham, Don Noyes Chevrolet, Nucar VW Norwood, Nucar Ford St Albans, Nucar CDJR St Albans.

USES

Some of this information, like your name, address, phone number and email may be entered into DCD’s Client Relationship Management (“CRM”) software, a secure application that can only be accessed by certain employees, who must enter a valid user name and password. DCD may use the information to contact you in response to an inquiry you made about a certain vehicle or product we sell. Customers always have the right to opt out of being contacted by DCD by informing us by phone or email. If that happens, we will update our system to reflect your wishes not to be contacted. We may also use the information for marketing purposes. Information provided to us by you, such as your social security number and other financial information about your creditworthiness, may also be used, with your permission, to help secure financing for purchase or lease of a vehicle. We also use some of this information when submitting credit applications on your behalf and with your permission. This process involves submitting a credit application, completed by you, and sent securely to banking institutions and credit bureaus. We safeguard this information by using heightened encrypted protections. We do not share any of this information with any other entity or affiliate. Only select and qualified personnel at our dealerships will have access to your information and credit application. Once this this process is completed the paperwork is stored at a locked, secure location with limited access.

SHARING OF INFORMATION

As outlined above, DCD needs to share some of your personal information in order to run its business. Below is a list of reasons we may share your information and, if so, who we share it with: For our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus. We share this information with credit bureaus and banking institutions when assisting our customers obtain financing for a vehicle. We would also share this information if required to do so by a court of law. For our marketing purposes, to offer our products and services to you. We share this information internally and with our wholly-owned affiliates (other car dealerships that we own). For joint marketing with other financial companies. We do not share this information. For our affiliates' everyday business purposes. We share information about your transactions and experiences with our wholly-owned affiliates. We do not share information about your creditworthiness with our wholly-owned affiliates. We do not share your information with unaffiliated marketing organizations.

COOKIES

DCD uses a technology called “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 your global privacy controls, like the GCP signal. We deploy cookies and similar tracking technologies to build profiles, serve ads and personal your experience across our websites. By pressing accept, you consent to the use of such cookies.

PROTECTION OF YOUR INFORMATION

Protecting and safeguarding your personal information is of the utmost importance to DCD. We take steps to ensure that your information is protected by, among other things, maintaining firewalls and operating system security patches, maintaining malware protection and up-to-date patches and virus definitions, securing all our internal and outgoing email communications with encryption protection and providing heightened encryption protection when transmitting documents containing your personal information. All personal information stored on laptops and other portable devises is also encrypted. Our computer security system, including our wireless systems, utilizes secure authentication protocols to restrict access to active users and blocks access to users who provide incorrect login information. We also have physical surveillance systems in place at all our dealerships, and we limit access to personal information to only those employees and/or agents necessary to complete your transaction. Your personal information is stored in locked storage areas and facilities with restricted access. We have policies in place to ensure that our employees follow our protocols, and require our employees to undergo training sessions on the proper use of our computer system and the importance of protecting personal information. Employees are subject to disciplinary action, including termination, if they fail to follow our policies and protocols. We also require that third-party vendors who have access to our data for business purposes follow our rules and protocols.

FOR QUESTIONS CALL: 781-255-6216 EMAIL: privacy@dcd.auto

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