LightspeedDMS LLC Mobile Application PRIVACY STATEMENT

Introduction

This privacy statement describes the types of information we may collect or that you may provide when you download, install, access, or use this App, and our practices for collecting, using, maintaining, protecting, and
disclosing that information.

This privacy statement applies only to information we collect in this App, but DOES NOT apply to information that we collect offline or on any other Company apps or websites, including websites you may access through this App, or information that you provide to or is collected by any third party. Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this privacy statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy statement. This privacy statement may change from time to time. Your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the privacy statement periodically for updates. Please note that your use of this App and the Lightspeed DMS product or service that this App enables you to use through your mobile device (“Product”) is subject to the Master Services Agreement (and all applicable addenda, schedules and amendments thereof) (the “Agreement”) by and between LightspeedDMS and the LightspeedDMS dealership client (“Client”) that governs the use of the Product. You confirm that you are an employee or a contractor of the Client and Client has granted you the permission to use the Product and assigned you the logon user name and password giving you access to the Product.

Information We Collect

When you download, access and use this App, we may collect and use personally identifiable information and other information about you. “Personally identifiable information” includes your name, address, email address, telephone number, and other similar information that can be used to individually identify you and that is not otherwise publicly available. For example, we may collect the following information:

• Information that you provide directly to us by filling in forms in this App, including your name, business address, email address, telephone number, job title, name of your employer, or other information;
• Information provided to us when you communicate with us through this App for any reason, including information in emails you send us, or submissions you may make on our App; and
• Details of your usage of this App and the resources that you access, including, but not limited to, traffic data and other communication data, including your device information, the date and time you accessed or
  left the App, and the usage of the app.
• Information about your mobile device and internet connection, including the device’s unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number.
• The App may also access metadata and other information associated with other files stored on your device, including, for example, photographs, audio and video clips, personal contacts, and address book information.
• This App may collect real-time information about the location of your device.

Use of Tracking Technologies

We use server logs and other technologies to collect information about you and your use of this App. These technologies do not provide us with your personal information, but they do allow us to track and record your activities in this App so we can see which features are being used.

Use and Disclosure of Your Information

• General. We use the information we collect from you in this App primarily to enable us to effectively provide our products and services, including:
• To enable you to access and use the Product from your mobile device;
• For our internal purposes such as to monitor and analyze App traffic and usage patterns to help improve this App, better understand our customers’ needs, or to develop new offerings in which you
  may be interested;
• To compile statistics and reports regarding the users of this App, products and/or services
• To share with our related companies or trusted third parties so that they may assist us with our use of the information as described above.
• Other Circumstances. We may disclose information about you, including personal identifiable information, if we have a good faith belief that disclosure is necessary to: (i) comply with applicable laws, regulations, legal process (such as a subpoena), or enforceable government requests; (ii) enforce the MSA or the Terms of Use or End User License Agreement for this App (if any), including investigation of potential violations of such MSA, Terms of Use or End User License Agreement, or to detect, prevent, or otherwise address fraud, security, or technical issues; or (iii) protect against harm to the rights, property, or safety of INS, our customers, users, or the public as required or permitted by law. In addition, we may disclose your personal information to third parties if we are involved in a merger, acquisition, or sale of any or all of our business and/or our assets to a third party, provided that they agree to abide by the terms and conditions of this Privacy Statement.

Security

We use commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect in this App. These procedures may include, but are not limited to, facility access control, firewalls, encryption, intrusion detection, and App monitoring. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your personally identifiable information, we cannot guarantee that it will be 100% secure. Your transmission of your data to this App is done at your own risk.

Third Party Websites and Social Media Features

This App may contain links to third party websites. While we seek to link only to sites that share our high standards and respect for privacy, we do not accept responsibility for the privacy practices of third parties. By
accessing other third party websites or applications through our App, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect personally identifiable information
about your online activities over time and across different web sites when you use INS’s App.

Our App includes social media features, such as the Facebook “Like” button. These features may collect your IP address and the website pages you are visiting, and may set a cookie to enable the feature to function properly.

Social media features are either hosted on a third party website or hosted directly in this App. Your interactions with these features are governed by the privacy policy of the entity providing them.

International Visitors

This App is hosted and operated in the United States (“US”). By using the App, you are consenting to the transfer of any information related to your use of this App (including your personal information) to the US or to
another jurisdiction other than your own. If you are accessing this App from outside the US, please be advised that US law (or the law of the jurisdiction ultimately hosting this App or the related content) may not offer the same privacy protections as the law of your jurisdiction.

Your California Privacy Rights

If you are a California resident, you have the right under California law to request companies with whom you have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes during the past year. If you are a California resident and wish to request further information about our compliance with this law or have questions or concerns about our privacy practices, you may contact us using the contact information set forth below.

Children’s Privacy

Our App is solely for use by businesses and by people who are at least 18 years old. By using this App, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a
user’s misrepresentation of age. Under no circumstances may anyone under age 13 use this App, or submit any information, including personally identifying information, in this App. Parents or legal guardians of children under the age of 13 cannot agree to these terms on their behalf in order to overwrite this paragraph.

Privacy Statement Updates

We will update this Privacy Statement from time to time, and any changes will take effect immediately after they are posted in this App. Collection and use of your information from that point on will be subject to the
updated Privacy Statement. Your continued use of the App will be deemed your agreement to the updated Privacy Statement. If you do not agree with the changes, you should delete or stop using the App and notify us that you do not want your information used in accordance with the changes. We will specify the date of the most recent update in the “Last Date for Updates” section of this Privacy Statement. If you need a copy of any previous version(s) of this Privacy Statement, you may contact us at the address below.

Contacting Us

If you have any questions, comments, or complaints regarding LightspeedDMS’s privacy practices or this Privacy Statement please do not hesitate to contact us by email at privacy@cdk.com or by writing to:

CDK Global Holdings, Inc.
Legal Department 1950
Hassell Rd.
Hoffman Estates, IL 60169