Privacy Policy

Introduction

At Volve Media™, d/b/a Consulting ("us", "we", "our" or the "Company") we value your privacy and the importance of safeguarding your data. This Privacy Policy (the "Policy") describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Policy, personal data ("Personal Data") refers to any information that on its own, or in combination with other available information, can identify an individual.

We are committed to protecting your privacy in accordance with highest level of privacy regulation. As such, we follow the obligations under the below regulations:

• The EU's General Data Protection Regulation (GDPR)
• Brazil's Data Protection Legislation (LGPD)
• California's Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and California Online Privacy Protection Act (CalOPPA)
• Colorado Privacy Act (CPA)
• Utah Consumer Privacy Act (UCPA)
• Connecticut Data Privacy Act (CTDPA)
• Virginia Consumer Data Protection Act (VCDPA)
• South Africa's Protection of Personal Information Act (POPIA)

Scope

This policy applies to the Volve Media™ websites, domains, applications, services, and products.

This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through (non-Volve Media) links that we may provide to you. These sites are owned and operated independently from us, and they have their own separate privacy policy and data collection practices. Any Personal Data that you provide to these websites will be governed by the third-party's own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Processing Activities

This Policy applies when you interact with us by doing any of the following:

• Make use of our applications and services as an authorized user;
• Visit any of our websites that link to this Privacy Statement.

Personal Data We Collect

What Personal Data We Collect

When you make a purchase, or attempt to make a purchase, we collect the following types of Personal Data:

• Account Information: such as your name, email address, and password.
• Payment Information: such as your billing address, phone number, credit card, debit card or other payment method.

When you use our products and/or features, we collect the following types of Personal Data:

• Account Information: such as your name, email address, and password.
• Payment Information: such as your billing address, phone numbers, credit card, debit card and other payment method.

How We Collect Your Personal Data

We collect Personal Data from the following sources:

• From You: You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback, Product Information, by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
  • Create an account or purchase products on our websites;
  • Use our products or services;
  • Create content through our products or services;
  • Express interest in our products or services;
  • Download software and/or our mobile application;
  • Subscribe to our newsletter;
  • Complete a voluntary market research survey;
  • Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
  • When you log in to our website via social media.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Device Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where carried out via our websites remain uncompleted, such as incomplete orders or abandoned sessions. We collect this data by using cookies, server logs and other similar technologies.
• Third parties: We may receive Personal Data about you from various third parties, including:
  • Account Information and Payment Information from another individual when they purchase a service for you on our website;
  • Device and Usage Data from third parties, including analytics providers such as Google;
  • Account Information and Payment Data from social media platforms when you log in using such platforms;
  • Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;
  • Account Information and Payment Data from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for fraud prevention, detection, and credit risk reduction; and
  • Account Information, Payment Data, and Financial Data from providers of technical, payment and delivery services.

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe that your Personal Data has been provided to us improperly, please contact us using the information set out below.

Device and Usage Data

When you visit a Volve Media™ website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service.

Data We Collect from Third Parties

We may receive your Personal Data from third parties such as companies subscribing to Volve Media™ services, automotive dealerships, partners and other sources. This Personal Data is not collected directly by us but by a third party and is subject to the relevant third party's own separate privacy and data collection policies. We do not have control over how your Personal Data is initially handled by third parties. As always, you have the right to review and rectify this information. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at Volve Media™.

Purpose and Legal Basis for Processing

We collect and use your Personal Data with your consent to provide, maintain, and develop our products and services and understand how to improve them.

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business (for example, against fraud). Consent will be required to initiate services with you. New consent will be required if any changes are made to the type of data collected.

International Data Transfer and Storage

Where possible, we store and process data on servers within the general geographical region where you reside (note: this may not be within the country in which you reside). Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those of your jurisdiction. We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy as well as applicable data protection law. Standard contractual clauses and legal transfer frameworks can be reviewed at EUR-Lex Commission Decision (EU) 2021/914.

Sharing and Disclosure

We will share your Personal Data with third parties only in the ways set out in this Policy or set out at the point when the Personal Data is collected.

Legal Requirement

We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

Service Providers and Other Third Parties

We may use third-party service providers, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, and email service providers, but only to maintain and improve our products and services.

Cookies

A cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site in addition to potential partners and third parties to that business. To give you the best experience possible, we use:

• Strictly Necessary Cookies: Required to run our web services and maintain authenticated sessions.
• Preference Cookies: Used to help us remember your settings and tailored preferences (such as localized service offerings).

Retention & Deletion

We will only retain your Personal Data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need Personal Data, we will remove it from our systems and/or take steps to anonymize it.

Merger or Acquisition

If we are involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

How We Keep Your Data Safe

We have appropriate organizational safeguards and security measures in place to protect your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

• The communication between your browser and our website uses a secure encrypted connection (SSL/TLS) wherever your Personal Data is involved.
• We require any third party who is contracted to process your Personal Data on our behalf to have security measures in place to protect your data.
• In the unfortunate event of a Personal Data breach, we will notify you and any applicable regulator when we are legally required to do so.

Children's Privacy

We do not knowingly collect Personal Data from children under the age of 16 years.

Your Rights for Your Personal Data

Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights include:

Filing an Appeal or Formal Complaint

If you disagree with our resolution of any privacy request, you have the right to appeal or contact relevant regulators:

• Colorado: Colorado Attorney General Portal
• Virginia: Virginia OAG Consumer Protection
• Connecticut: Connecticut OAG Complaint Form
• South Africa: The Information Regulator of South Africa (POPIA) at inforegulator.org.za
• European Economic Area (EEA): Directory of EU Data Protection Authorities

How to Exercise Your Rights

You can make a request to exercise any of these rights in relation to your Personal Data by contacting our dedicated data privacy team. For your own privacy and security, at our discretion, we may require you to verify your identity before providing requested information.

Policy Changes

We may modify this Policy at any time. When updates occur, we will post an updated version on this page and revise the effective date. When using our services, you may also be prompted to review and acknowledge updated terms.