Effective Date: July 1, 2026

MOBILITY GLOBAL PRIVACY POLICY

Last Updated: July 1, 2026

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Introduction

This Corporate Privacy Policy (“Policy”) explains the personal information processing practices of Mobility Global, Inc. and its affiliates’ (“Mobility Global” or “us”) and how you can exercise your privacy rights.

This Policy applies when:

This Policy does not apply:

Table of Contents

Personal Information We Collect and Why

We collect data about you in different ways. For example, we collect data:

  • Directly from you. This includes when you make an account, sign up to get our emails, or contact us.
  • Automatically. This includes through cookies, server logs, and other tools on our website or apps.
  • From other sources. These can include our affiliates, vendors, publicly available sources, and other companies.

The table below describes the personal information we collect, where we collect it from and why it is collected and used.

Personal Information Collected

Where We Get it From (Source of Personal Information)

Why it is Collected

Billing information

For example:

  • Payment card information
You.
  • To maintain your account with us and to provide you with requested Services or Events.
  • For order processing and to provide transaction documents.

Contact Details

For example:

  • Name
  • Telephone/ cell phone/ mobile number
  • Email address
  • Postal address
  • Details of your communications with us

You or your employer.

From other sources.

  • To maintain your account with us and to provide you with requested Services or Events.
  • To respond to your communications and inquiries.
  • To provide updates, information, and alerts about our Services.
  • For information verification.
  • For customer support, maintenance, and training for our Services.
  • To obtain your feedback about our Services (including through surveys).
  • To receive services from you or your employer.
  • To manage your registration to our Events.
  • To provide marketing insights and information.

User Credentials

For example:

  • Name
  • Email Address
  • Signature
  • Log-in details
You or your employer.
  • To set up and maintain your user account.
  • To monitor and enforce compliance with our contract terms.
  • To enable clients to use our Services.

Your User Profile

For example:

  • Name
  • Email Address
You or your employer.
  • To set up and maintain your user account.
  • To monitor and enforce compliance with our contract terms or applicable law.
  • To enable clients to use our Services.

Employer and employment information

For example:

  • Job title
  • Company affiliation
  • Function
  • Seniority
  • Department
  • Office Location
  • CV/ Resume
You or your employer.
  • To manage your individual user account when it is covered by an account of an Mobility Global corporate customer, such as the corporate account of your employer.
  • To manage your registration to our Events.
Client Information
You or your employer.
  • To contact our clients and communicate with them about business activities such as projects, services, and billing.

Your Preferences and Interests

For example:

  • Emails and newsletters you would like to receive or have opted out from receiving.
  • The markets, industries and conferences that interest you.
You.
  • To send you tailored information on our Services across our divisions that may interest you.
  • To allow you to participate voluntarily in mailings and other events.
  • To promote our Events and Services.
  • To provide marketing insights and information.

Recordings and Images

For example:

  • Video, voice, or audio recordings
  • Images
  • Automated transcriptions
You (with your consent when required by law).
  • To provide Event content or recordings to individuals who were not able to attend the live event, to promote our Events in live recordings, or to otherwise provide Event content.
  • To provide product demos and trainings.
  • To generate meeting summaries or notes and action items.
  • To collect your feedback for product improvement.
  • To promote our Events and Services.

Customer Support Information

For example:

  • Issues, questions, or problems you have using our Services.
  • User preferences.
  • How you use or want to use our Services.
  • Information you access or analyze within our Services.
  • Other information you communicate you our support, maintenance, or training staff.
  • Recordings or automated transcriptions of service calls.
You (with your consent when required by law).
  • To maintain your account with us.
  • Provide technical support.
  • Remedy issues or problems.
  • Train you in the use of our Services.
  • To keep an auditable record of all communications and actions which is accessible to our support, maintenance, and training staff globally.

Device Information

For example:

  • Log-in events (when, how and for how long you log into and use certain Services).
  • IP or MAC address.
  • Device make, model and operating system.
  • Mobile network information.
  • Internet service provider.
  • Unique device identification number.
  • Advertising ID.
  • Browser type and language
  • Geographic location (e.g., country or city level location or time zone).
  • Other technical information.
  • "Click stream" data (including the pages, screens, functions, applications, and products accessed, and links clicked).
Collected automatically from your device, by cookies, weblogs, web beacons and similar tracking technology. (See “Cookies and Similar Tracking Technology” for more information).
  • For website analytics.
  • To understand how you use our Services, including the pages you visited, and what content and functions interest you.
  • To develop, update and improve our Services.
  • To tailor content based on your preferences and usage habits.
  • To deliver tailored information on our Services that may be of interest or value to you and to send you marketing and promotional emails with your consent if required by applicable law.
  • To develop research or editorial content.
  • To provide customer support and training on our Services.
  • To evaluate your training needs for our Services.
  • To provide corporate customers with usage data of individuals using our Services under their account.
  • To identify and resolve technical issues.
  • To identify unauthorized use or unauthorized distribution of our Services.
  • To review or update pricing agreed with our customers.
  • For our or our content providers’ billing purposes.

Marketing Data

For example:

  • Name.
  • Job Title.
  • Contact Details.
  • Demographic insights based on inferences.
Other third parties (including marketing vendors, survey services, social media, event partners).
  • To market our Services to you.
  • To maintain and correct our records.
  • To add data fields.
  • To enhance the marketing, delivery, and support of our Services to you.
  • To sell or share with customers

Motor Vehicle Information

For example:

  • Registration and Title information pursuant to 18 U.S.C A. §2721 and similar state laws governing the use of such information.
Motor vehicle records.
  • Consumer information from motor vehicle records is used for permitted purposes only in compliance with 18 U.S.C A. §2721 and similar state laws governing the use of such information and is not used or provided to other entities for direct marketing purposes.

Customer Financial Data

For example:

  • Net worth
  • Individual portfolio information
You.
  • For conducting due diligence activities for financial institutions and other regulated companies as part of our Know Your Customer procedures.

Government Identification

For example:

  • National ID
  • National ID number
You.
  • For conducting due diligence activities for financial institutions and other regulated companies as part of our Know Your Customer procedures.

Personal information collected through our mobile apps

For example:

  • Your calendar.
  • Your contacts and call information.
  • The accounts and other apps on your mobile device.
  • Photos (including date, time, location, and contents).
  • Media files, metadata.
  • Other stored information.
  • Precise geo-location
You (with your consent when required by law).
  • To provide the app to you.
  • To share your information with other app users (for example, to enable meeting booking functionality).

App logs and usage statistics

For example:

  • When you open an app.
  • If the app stops working, "crash data,” such as whether you have mobile reception.

To learn more, please check your device settings or review the platform from which you downloaded it. To stop collection of all information through one of our apps, please uninstall the app.

You.
  • To monitor which app you use, when and how.
  • To identify and fix an issue.

Sensitive Information.

For example:

  • Social security, driver’s license, state identification card, or passport number;
  • precise geolocation;
  • Racial or ethnic origin,
  • religious, or philosophical beliefs, or union membership;
  • health information;
  • sex life or sexual orientation;
  • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
  • the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
You.
  • To process transactions.
  • To set up your user accounts.
  • Comply with laws.
  • Manage our business.
  • Monitor and enforce compliance with our contractual terms.
  • Provide you with services.
  • Demographic insights based on inferences may be sold or shared with customers.

We also may use your personal information:

  • For purposes that we explain to you when we collect your personal information.
  • For other compatible purposes permitted by law, such as archiving, research, or statistical purposes.

Except to test the effectiveness of our processes to anonymize or deidentify information, we will not attempt to reidentify deidentified or anonymized personal information.

Who We Disclose Personal Information To and Why

We may disclose your personal information (described above in “Personal Information We Collect and Why”). The table below describes who we disclose personal information to and the reason why we disclose it.

Recipient (who we disclose personal information to)

The reason or purpose of disclosure

Our group companies and our joint venture companies. For a list of our current group companies and related companies, please see our latest filings here.
For the purposes noted above in “Personal Information We Collect and Why.”
Service providers, Content Providers and Business Partners. A list of our categories of service providers, content providers and business partners is available here.
  • To operate our business.
  • To honor a request that you have made through the Services.
  • To deliver, improve or customize our Services.
  • To send marketing communications and communications related to our business.
  • For payment processing.
  • With business partners in the ad tech sector for their own commercial marketing purposes when your personal information has been collected for marketing purposes and such disclosure is permitted by applicable law.
  • For other legitimate purposes permitted by applicable law or otherwise with your consent.
The organization that arranges your access to our Services (if that is not you).
  • To fulfill contractual obligations.
  • To provide our Services, support, and training to the organization.
Our customers and partners.
  • To provide marketing insights and information.
  • For permitted purposes pursuant to 18 U.S.C. § 2721, such as for federal, state, or local agency (including courts and law enforcement) in carrying out its functions; use in connection with motor vehicle or driver safety, theft, emissions, product recalls, advisories, or performance monitoring; use by an insurer or agent for claims investigation, rating, or underwriting; business/identity verification; litigation/legal proceedings; production of statistical reports or research activities, provided personal information is not disclosed or used to contact individuals; employer verification; use by licensed investigative or security services; or subject to written, express consent.
Our webinar and conference partners. We may share the contact information you provide when registering for an event and share event attendee lists between our Mobility Global affiliates and with our webinar and conference partners.
  • To ensure that your contact information is up to date.
  • To administer, secure, and seek feedback on and promote our events.
  • To send you marketing and promotional emails with your consent, if required by applicable law.
Your employer.
  • To fulfill and enforce our contract with them.
  • To inform them of potential group training needs.
  • To inform them of Service use and for pricing purposes.
Competent law enforcement bodies, regulatory, government agency, court or other third parties. For more information, please see our SEC filings here.
  • To comply with law or regulation.
  • To prevent illegal activity.
  • To protect against fraud or for risk management purposes.
  • To cooperate with relevant agencies for the investigation and prevention of crimes such as insider trading.
  • To exercise, establish or defend our legal rights.
  • To protect your vital interests or those of any other person.
  • To protect the interests, rights, safety or property of us or others.
  • To comply with a court order, government request or other legal or regulatory process.
A potential buyer or target (and that third party’s or our agents and advisers), in the event of a proposed sale, purchase, merger, transfer, acquisition or liquidation or similar event.
  • If such a change happens to our business, the buyer or target will use your personal information in the same way as set out in this Policy or will inform you about how it will use your personal information as required by applicable law.
Other third parties.
  • Personal information that you disclose on message boards, chat areas or social media pages or in direct messages to other users of these platforms may be collected and used by third parties to contact you, to send you unsolicited messages or for other purposes without our knowledge or control.
  • Social media forums and chat rooms not operated by us may have additional rules and conditions. We are not responsible for the personal information or any other information you choose to submit on these forums that are not controlled by us. The Services may offer you the ability to share personal information through a social networking site (e.g., Facebook, X [formerly known as Twitter]) using integrated tools (e.g., Facebook “Like” button, or X 'Post' button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking sites or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites. We encourage you to use caution when publicly disclosing your personal information.
Other disclosures with your consent.
  • We may ask for your consent to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.

Places We Transfer Personal Information To

Mobility Global is a multi-national group with headquarters in the United States of America. When we collect your personal information, we may transfer it to or from any of the countries in which we do business where we are permitted to do so.

Examples of locations where personal information is processed by or on behalf of Mobility Global include:

Principal jurisdictions where personal information is processed or hosted
Back-office support personnel locations
Other
- United States of America
- Canada
- United Kingdom
- India
- France
- Italy
- Germany
- Mexico
- Australia
- Japan
- China
- India
- Canada
- United States of America
- United Kingdom
- Poland
- Australia
- Mexico
- Italy
- China
- Malaysia
- Thailand
- France
- Brazil
- Japan
- Rep. of Korea
- Spain
- Netherlands
- Hong Kong
- Ireland
- Sweden
- Singapore
- Germany
- Locations of our group companies and related companies
- Location of the organization that arranges your access to our products and services
- Locations of our service providers, product content providers and business partners

We implement safeguards to protect transferred personal information.

These safeguards include Standard Contractual Clauses. We may rely on these safeguards for transfers to and from our affiliates, vendors and business partners, where applicable. Please contact us for more information about our safeguards.

You may request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA (if applicable), which includes the categories of information transferred, by contacting us using the contact information below.

Information Security

We protect your personal information with technical and organizational measures designed to provide a level of security appropriate to the risk of processing. We require that our vendors and third parties also have technical and organizational measures in place to protect your personal information.

No method of internet transmission or electronic storage is fully secure. While we use reasonable efforts to protect personal information, we cannot guarantee its security. If we are required to inform you about a security incident, we will do so electronically, in writing, or by phone, as the law permits.

How Long We Retain Your Personal Information

We will retain your personal information for as long as we have an ongoing legitimate business need to do so. Examples of a legitimate business need include providing a Service to you or to complying with legal, tax or accounting requirements.

Once we no longer need to retain your personal information, we will destroy, delete or anonymize your personal information in compliance with our Company policies. If destruction, deletion or anonymization is not possible, we will pseudonymize and/or securely store your personal information and isolate it from any further processing until destruction, deletion, or anonymization is possible.

Please contact privacy@mobilityglobal.com if you have any questions about our information governance policies, procedures and standards.

Cookies And Similar Tracking Technology

We use cookies and similar tracking technology in our Services and websites. Third parties might also collect data over time and across other websites. Among other things, they may use this data to serve ads tailored to your interests, which may include ads about our products or Services. Please see our Cookie Notice to learn more about:

  • how and why we use cookies and similar technologies;
  • how we use Google Analytics on our Websites; and
  • how you can exercise your rights to control our use of them.

We recognize Global Privacy Control (GPC) signals and other user-enabled opt-out preference signals as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. To learn more about the GPC, you can visit its website here.

"Do Not Track" Signal

Some browsers allow you to send a “Do Not Track” signal that lets you tell websites you do not want to have your online activities tracked. Because there is no consistent industry understanding of how to respond to such signals, we do not respond to browser-initiated “Do No Track” signals.

Global Privacy Control (GPC)

We will treat any opt-out preference signal as valid opt-out request where required under applicable law, including the Global Privacy Control (GPC) signals. Please note that your opt-out preference signal will be applied only to your current browser and device. To learn more about the GPC, you can visit its website here.

Your Privacy Rights

Depending on the laws that apply to your personal information, you may have the right to:
Access your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408. To access your motor vehicle registration and/or title information, contact your state's department of motor vehicles or other state agency that processes motor vehicle titles and registration. The American Association of Motor Vehicle Administrators maintains links to state motor vehicle agency websites, organized by AAMVA regions.
Appeal a decision by Mobility Global regarding a prior request or file a complaint
Request by contacting us at privacy@mobilityglobal.com with the subject line “Appeal”. If you are not satisfied with our response, you may have the right to lodge a complaint with your local supervisory authority. Contact details for data protection authorities in the EEA, Canada, Switzerland and the UK are available here.
Block or restrict the processing of your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.
Confirm if Mobility Global is processing your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.
Correct or update your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408. To correct your motor vehicle registration and/or title information, contact your state's department of motor vehicles or other state agency that processes motor vehicle titles and registration. The American Association of Motor Vehicle Administrators maintains links to state motor vehicle agency websites, organized by AAMVA regions.
Delete or anonymize your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.
Limit the processing of your personal information and/or use and disclosure of your sensitive personal information
Request by submitting this Limit Sensitive Data Use Form or by calling 1-888-433-8408.
Object to the processing of your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.
Obtain:
  • a copy of your personal information (portability)
  • information about 3rd parties to which your personal information was disclosed, which may include a list of categories of 3rd parties or specific 3rd parties to which your personal information was disclosed
  • information about the possibility of denying consent and the consequences of such denial

Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.

Opt-out of sale or sharing of your personal information
Action by submitting this Do Not Sell or Share My Personal Information Form or by calling 1-888-433-8408.
Review your personal information
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.
Withdraw consent
Request by submitting this Personal Information Request Form or by calling 1-888-433-8408.
Not all of the rights listed above are absolute and they do not apply in all circumstances. We may limit or deny your request when permitted by law. For more information, see the applicable jurisdiction specific addendum which forms part of this Policy.

Exercising Your Privacy Rights

Exercise your privacy rights by:

  • Submitting this Personal Information Request Form
  • Calling 1-888-433-8408
  • Opt-out of the sale of your personal information by submitting this Do Not Sell or Share My Personal Information Form
  • Opt-out of sharing or targeted advertising requests through this Do Not Sell or Share My Personal Information Form. Please note that if you change browsers or devices, or if you clear your browser’s cache, you may need to click the link again to apply your preference.
  • Unsubscribe or “opt-out” of receiving promotional emails by following instructions in emails that you receive or by visiting our preference center here. If you decide not to receive promotional emails, we may still send you service-related communications.

We will respond to your request in the timeframe required under applicable law. We will not retaliate against you for exercising your rights. We may charge a fee, when permitted by law.

Depending on the type of request and applicable law, we may need to verify your identity before we can respond to your request. When permitted by law, we may request that you provide photographic or other forms of identification to us. If we are unable to verify your identity, we may not be able to respond to your request.

If you are an authorized agent submitting a request on behalf of a data subject,

If you disagree with how we handled a request, you may appeal our decision by contacting us at privacy@mobilityglobal.com with the subject line “Appeal”. If you are not satisfied with our response, you may have the right to lodge a complaint with your local supervisory authority. Contact details for data protection authorities in the EEA, Canada, Switzerland and the UK are available here.

Updates To This Policy

Subscribe to Updates

We may change our Policy and privacy practices. New Policies will be published on our website. If changes are material, we will notify you using your contact information that you provide in the subscription tool above. Also, if changes are material, the Policy that was in place when you submitted personal information to us will generally govern that data unless you consent to the new Policy. Our Policy shows “effective” and “last updated” dates. The effective date is the date the current version took effect. The last updated date is the date the current version was last substantively changed.

How To Contact Us

If you have any questions or concerns about this policy or if you have a disability and need assistance in accessing anything in this Policy, please use the contact details below:

privacy@mobilityglobal.com

1-888-433-8408

5860 Trinity Parkway, Suite 600, Centreville, Virginia 20120

You may also use this Personal Information Request Form to contact us or exercise any of your rights.

Jurisdiction
Local Contact Information
Brazil
Data Protection Officer
R.L. Polk & Co.
privacy@mobilityglobal.com
Brazil
Data Protection Officer
R.L. Polk & Co.
privacy@mobilityglobal.com
European Union

France
Data Protection Officer
Flex-O Hausmann, 69 Bd Haussman, Suite 218, 75008, Paris
privacy@mobilityglobal.com

Germany
Data Protection Officer
Opernturm Office, Bockenheimer Landstrasse 2-8, Frankfurt am Main
privacy@mobilityglobal.com

Data Protection Officer
Bredeney Office Park, Buropark Bredeney, Building Section A, Hatzper Strasse 30-36/Theodor-Althof-Strasse 39-47, Essen, 45133
privacy@mobilityglobal.com

Data Protection Officer
Barthstrasse 2-10, Munich, 80339
privacy@mobilityglobal.com

Italy
Data Protection Officer
Can Piccolo No 2, Trieste
privacy@mobilityglobal.com

Data Protection Officer
Wellio Duomo, Via dell’Unione, 1, 20123 Milan
privacy@mobilityglobal.com

Netherlands
Data Protection Officer
Herengracht 124-128
privacy@mobilityglobal.com

Poland
Data Protection Officer
Ul. Marynarki Polskiej 163, C-200 Office, Gdansk
privacy@mobilityglobal.com

Data Protection Officer
budynek Equator IV AI. Jerozolimskie 100, 00-807 Warszawa
privacy@mobilityglobal.com

Spain
Data Protection Officer
Avenida Diagonal 534, Barcelona
privacy@mobilityglobal.com

Japan
Data Protection Officer
Yaesu Tower, EXEVIA Tokyo Yaesu 1-6-1 Yaesu, Chuo-ku
+81-(0)3-4550-8000
privacy@mobilityglobal.com
UK
Data Protection Officer
30 Crown Place, Industrious, Office No. 10.09, London, EC24 4EB
privacy@mobilityglobal.com
People’s Republic of China

Data Protection Officer
Unit 2826, Level 28, China World Office 1, 1 Jianguomenwai Avenue, Chaoyang District, Beijing 100004
privacy@mobilityglobal.com

Data Protection Officer
Room 308-10, 3rd floor, No. 1010 Middle Huaihai Road, Xuhui District, Shanghai (上海市徐汇区淮海中路 1010 号 3 楼 308-10 室)
privacy@mobilityglobal.com

Singapore
Data Protection Officer
R.L. Polk & Co.
privacy@mobilityglobal.com
Mexico
Data Protection Officer
Mexico Avenida Constitucion 2050, Monterrey, MX 64060
privacy@mobilityglobal.com

Additional Information for Certain Jurisdictions

Brazil

This Brazil Addendum ("Brazil Addendum") supplements this Policy to the extent that the General Data Protection Law of Brazil ("LGPD") applies in relation to the processing of personal information by Mobility Global.

In case of any inconsistencies between this Brazil Addendum and the rest of this Policy related to personal information governed by LGPD, this Brazil Addendum prevails.

Under the LGPD, you have the right to:

  • confirm the existence of processing of your personal data;
  • access your personal data;
  • correct incomplete, inaccurate, or out of date personal data;
  • anonymize, block, or delete unnecessary or excessive personal data or personal data that is not being processed in compliance with the LGPD;
  • port your personal data to another service or product provider, by means of an express request;
  • delete personal data processed with your consent;
  • information about public and private entities with which we have shared your personal data;
  • information about the possibility of denying consent and the consequences of such denial;
  • revoke consent;
  • request review of decisions taken solely on the basis of automated processing of personal data that affects your interests.

You or an authorized agent may exercise your rights through the Personal Information Request Form. The LGPD also provides that you may file a complaint regarding your data directly with the Brazilian data protection regulator.

Data Protection Officer contact information can be found in the “How to Contact Us” section of this Policy.

International Transfers

Where the Brazilian Standard Contractual Clauses apply to an international transfer and where Mobility Global is the “designated party”, the following shall apply in accordance with Clause 14 of the Brazilian Standard Contractual Clauses:

(a) The form, duration, and specific purpose of the international transfer:
Customers may transfer personal information to Mobility Global for the purpose of receiving Mobility Global’s products and services, for the term of their relationship with Mobility Global, which Mobility Global may retain in accordance with the “How Long We Retain Your Personal Information” section of this Policy. Mobility Global may disclose personal information to the recipients and for the purposes described in the “Who We Disclose Personal Information To and Why” section of this Policy. Such disclosures may result in an international transfer, in accordance with the “Places We Transfer Personal Information to” section of this Policy,

(b) The destination country of the transferred data:
Mobility Global may transfer personal data to the jurisdiction of any of Mobility Global’s office locations and as described in this Policy.
For transfers to third parties, the destination jurisdiction will depend on the location of the third-party recipient.

(c) The identification and contact details of the Designated Party: Please see the “How to Contact Us” section of this Policy.

(d) The data sharing practices of the Parties and the purpose of such sharing. Please see the “Who We Disclose Personal Information To and Why” section of this Policy.

(e) The responsibilities of the agents conducting the processing. Mobility Global will process personal information in accordance with the obligations set forth in this Policy. Mobility Global contractually requires third-party recipients of personal information to process personal information in accordance with applicable law.

(f) The rights of the Data Subject and the means for exercising them, including a readily accessible channel for handling their requests and the right to petition against the Controller to the ANPD. Please see the first part of this Brazil Addendum and the “Your Privacy Rights” section of this Policy.

(g) Any further transfers, including the recipients and the purpose of the transfer. Please see the “Who We Disclose Personal Information to and Why” section of this Policy.

Japan

This Japan Addendum ("Japan Addendum") supplements this Policy to the extent that the Act on the Protection of Personal Information (Japan) (Act No. 57 of 2003, as amended) (“Act”) applies in relation to the processing of personal information in Japan by Mobility Global Japan GK ("Mobility Global Japan") (details of these entities are as follows) and/or Mobility Global entities located outside Japan. If there are any inconsistencies between this Japan Addendum and the rest of this Policy in relation to Mobility Global's process of personal information subject to the APPI, this Japan Addendum prevails. Mobility Global will comply with applicable Japanese data protection laws and regulations and not use personal information for purposes which are not set forth in this Policy or otherwise communicated to the data subject. The process for submitting a claim or request is set out in this Privacy Policy and Addendum.

Business operators handling your personal information:

Entity Name: Mobility Global Japan GK

Entity Address: Yaesu Tower, EXEVIA Tokyo Yaesu 1-6-1 Yaesu, Chuo-ku

Telephone Number: +81-(0)3-4550-8000

Joint-use of personal information inside of Mobility Global Group

Mobility Global Japan jointly uses personal information with other entities in the Mobility Global group who may use personal information to provide information about our Services to our clients and related support and training, conduct certain market research, contact clients, or engage in other activities detailed in this policy. Mobility Global Japan may also have certain products that collect business information about individuals in Japan. Such information includes: address, name, company name, department name, job title, phone number, fax number, e-mail address, billing information, history of personnel changes and professional employment history, records of job interviews with Mobility Global Japan, your areas of interest, etc.

A list of our group companies is available here.

Names and addresses of the entities responsible for the management of said jointly used personal data and the name of each entity’s representative is listed in the section above.

Contact information regarding handling of personal information

If you have any questions, concerns or complaints about our disclosure, correction, deletion, utilization, or other processing of your personal information (including how we secure your personal information), please contact privacy@mobilityglobal.com or via mail, at: Yaesu Tower, EXEVIA Tokyo Yaesu 1-6-1 Yaesu, Chuo-ku.

People’s Republic of China

This China Addendum (“China Addendum”) applies to the processing of your personal information only if you are located in the People’s Republic of China (“China”) and supplements this Policy. In case of any inconsistencies between this China Addendum and the rest of this Policy, this China Addendum prevails.

1. Sensitive Personal Information. Your personal information whose leakage or unlawful use may easily infringe the dignity of a natural person, or cause harm to the personal safety or property security, including biometric characteristics, religious beliefs, specially designated status, medical health, financial accounts, personal whereabouts and personal information of minors under the age of 14 may be considered as sensitive personal information in accordance with applicable Chinese law and regulations ("Sensitive Personal Information"). To the extent we collect this Sensitive Personal Information, we will only process it to the extent necessary for fulfilling the purposes as stated in this Policy and will take measures for its security. Where required by applicable Chinese law and regulations, we will obtain your separate consent before we process your sensitive personal information and comply with requisite requirements under Personal Information Protection Law (PIPL).

2. Sale of business. We may provide personal information to a potential buyer or target (and that third party’s or our agents and advisers) in connection with any proposed purchase, merger, transfer, acquisition or liquidation or similar event of all or any part of our business. If such a change happens to our business, the buyer or target will use your personal information in the same way as set out in this Policy including this China Addendum or will inform you about how it will use your personal information as required by applicable law, or (where applicable) require such third party to obtain your consent again.

3. Notifications. We cannot absolutely guarantee the security of any information or data you provide online. In the event of a security incident, we will take mitigation measures in accordance with our incident response plan and report to competent regulators in China as required by applicable law. In the event of a security incident affecting your personal information, we will notify you as required by applicable law through email, correspondence, telephone, push notification or other means. If you think your data is the subject of a security incident and we have not notified you, or if you are concerned about the security of your data, please contact our dedicated security team at security@mobilityglobal.com.

4. Contact Information of our China DPO. You may contact our China Data Protection Office at privacy@mobilityglobal.com or, at: Unit 2826, Level 28, China World Office 1, 1 Jianguomenwai Avenue, Chaoyang District, Beijing 100004 or Room 308-10, 3rd floor, No. 1010 Middle Huaihai Road, Xuhui District, Shangha. You may also exercise your rights in relation to personal information transferred overseas or request closure of an account which is registered with Mobility Global through the method specified under the section of this Policy titled, “Your Privacy Rights.”

United States

This United States of America Addendum ("US Addendum") supplements this Policy and applies in relation to the processing of personal information of residents of the United States of America by Mobility Global. In case of any inconsistencies between this US Addendum and the rest of this Policy, this US Addendum prevails where applicable.

For information about how to exercise your privacy rights, please see Exercising Your Privacy Right. For information about the requests we receive under California law, including the number of requests and the average number of days we’ve taken to respond to requests, please click here.

Information Collection and Disclosures

  • For information about the categories of personal information that we collect, the sources of the information and the business purposes for which we process the personal information, please see Personal Information We Collect and Why.
  • For more information about disclosures of personal information for a business purpose, please see Who We Disclose Personal Information To and Why.
  • California Shine the Light. If you would like more information on the categories of personal data (if any) we share with third parties or affiliates for those parties to use for direct marketing, submit a written request using the information in the Contact Information section.

Mobility Global "shares" or "sells" personal information to third parties in very limited circumstances including to create tailored marketing audiences and deliver personalized advertisements. We sell or share personal information with third parties for certain Polk Automotive Solutions: https://ihsmarkit.com/products/polk-automotive-solutions.html

Category of Personal Information
Disclosure for a Business purpose
Sharing for Cross-Context Behavioral or Targeted Advertising
Sale
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.
  • Affiliates or subsidiaries.
  • Business partners.
  • Data analytics providers.
  • Data brokers.
  • Internet service providers.
  • Joint marketing partners.
  • Operating systems and platforms.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
  • Social networks.
Advertising networks for the purpose of delivering tailored information about goods and services that may be of interest or value to you and to send you marketing and promotional emails with your consent, if required by applicable law.
  • Business partners
  • Data analytics providers
  • Data brokers
  • Advertising networks
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.
  • Affiliates or subsidiaries.
  • Business partners.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.
N/A
  • Business partners
  • Data analytics providers
  • Data brokers
  • Advertising networks
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Affiliates or subsidiaries.
  • Business partners.
  • Data analytics providers.
  • Data brokers.
  • Internet service providers.
  • Joint marketing partners.
  • Operating systems and platforms.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
Advertising networks for the purpose of delivering tailored information about services that may be of interest or value to you and to send you marketing and promotional emails with your consent, if required by applicable law.
  • Business partners
  • Data analytics providers
  • Data brokers
  • Advertising networks
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Affiliates or subsidiaries.
  • Data brokers.
  • Internet service providers.
  • Joint marketing partners.
  • Operating systems and platforms.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
N/A
  • Business partners
  • Data analytics providers
  • Data brokers
  • Advertising networks
Professional or employment related information.
  • Business partners.
  • Advertising networks.
N/A
  • Business partners
  • Advertising networks
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number.
  • Affiliates or subsidiaries.
  • Business partners.
  • Data analytics providers.
  • Data brokers.
  • Internet service providers.
  • Joint marketing partners.
  • Operating systems and platforms.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
  • Social networks.
N/A
N/A
Government Issued Identification.
  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.
N/A
N/A
Audio, electronic, visual, thermal, olfactory, or similar information
N/A
N/A
N/A
Non-public education information (as defined in the Family Educational Rights and Privacy Act).
N/A
N/A
N/A
Government Issued Identification
  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
N/A
N/A
Financial information.
  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
N/A
N/A
Geolocation Data
  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Payment processors and financial institutions.
  • Professional services organizations, this may include auditors and law firms.
  • Other application users (if feature configured).
N/A
N/A
Inferences drawn from any of the information listed above.
  • Affiliates or subsidiaries.
  • Business partners.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.
N/A
  • Business partners
  • Data analytics providers
  • Data brokers
  • Advertising networks
Not sold or shared for Cross-Context Behavioral or Targeted Advertising:
Mobility Global has no actual knowledge that it sells or shares the personal information of consumers under 16 years of age.
For R.L. Polk & Co. only: The entity maintaining this website is a data broker under Texas law and in other U.S. states. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

Supplemental Terms for Certain Services

This section provides supplemental information for certain Services. For each listed Service, the applicable terms in this section take precedence over the rest of this Policy.

Polk Automotive Business

For over 100 years, Polk has been the premier supplier of automotive intelligence. We work to maintain the public's trust by offering products and services consistent with our commitment to Polk's Privacy Principles.

Polk strives to maintain high ethical standards in the development and management of its databases.

  • We endeavor to provide information services to business customers through practices informed by ethical and responsible standards.
  • We seek to source data from providers that represent themselves as compliant with applicable laws and industry standards.
  • We utilize quality review processes intended to support data integrity throughout the data lifecycle.

Polk implements protocols designed to limit information sharing to those companies with a legal, appropriate, and allowable use for the information.

  • The consumer information we collect and provide to our business customers is limited to information necessary for the legitimate business purposes of Polk and its business customers.
  • We maintain control over the use of our consumer information through contractual agreements and guidelines established with our customers and vendors.

Polk implements safeguards to protect information against unauthorized access.

  • We maintain physical and electronic security of our facilities and systems to protect data from unauthorized access, use, or dissemination.
  • We aim to work only with reputable industry service companies to support our business and require that these companies adhere to our practices concerning the handling and use of consumer data.
  • We maintain internal practices to protect the security of information by limiting access to data, systems, and facilities.

Polk works within regulatory requirements to maintain the best information value for our customers.

  • We maintain an executive-level committee that reviews Polk's collection, use and distribution of consumer information.
  • We maintain an awareness of legislative and administrative actions that affect our ability to provide high-quality information to our clients. We work to influence those actions, where appropriate, to deliver value to our clients.
  • We advise our customers about data compliance and permissible uses.

Polk includes privacy principles and practices in its standards for employee ethics.

  • We expect all Polk employees to share in upholding the public's confidence and trust, and to apply Polk's privacy principles and practices in every aspect of our business.
  • We include privacy principles and practices as part of the orientation program for all new employees.
  • We conduct regular information sharing meetings and maintain electronic bulletin boards to educate employees on compliance issues.

Polk respects a consumer's expressed desire to be removed from marketing lists.

  • Polk has controls in place to action a consumer's choice not to be contacted for marketing purposes. Consumers may opt out of mailing using the DMA choice ANA Email Preference Service or contact Polk by phone, mail or email to be removed from our marketing lists.
  • We expend effort and expense in maintaining our name suppression system to comply with consumer requests.
  • We subscribe to the DMA choice ANA Email Preference Service and to suppression services supplied by state governments.

Access to and Correction of State-Sourced Information

Polk collects and compiles motor vehicle registration and title information to provide products and services to authorized entities pursuant to 18 U.S.C A. §2721 and similar state laws governing the use of such information. Consumer information from motor vehicle records is used in compliance with the governing laws and regulations and thus not used by Polk or provided to other entities by Polk for direct marketing purposes. To access or correct your motor vehicle registration and/or title information, contact your state's department of motor vehicles or other state agency that processes motor vehicle titles and registration. The American Association of Motor Vehicle Administrators maintains links to state motor vehicle agency websites, organized by AAMVA regions.

automotiveMastermind

automotiveMastermind is a software as a service digital marketing company that provides, among other things, an online platform for predicting consumer purchasing behavior for marketing and advertising purposes. For more information about its processing activities, please visit: Privacy Policy - automotiveMastermind

CARFAX US

CARFAX is an American technology company specializing in vehicle data products for consumers and businesses. CARFAX products include new and used car listings, maintenance tracking, and the CARFAX Vehicle History Report. For more information about its processing activities, please visit:  Privacy Hub | CARFAX

CARFAX Canada

CARFAX Canada is Canada's definitive source of automotive information, delivering vehicle history, appraisal and valuation. For more information about its processing activities, please visit:  Privacy Hub | CARFAX

CARFAX EU

CARFAX provides trusted automotive information that helps people buy and sell used cars with more confidence. For more information about its processing activities, please visit: Privacy Hub | CARFAX