1stMILE Privacy Policy

This Privacy Policy governs your direct relationship with 1STMILE, LLC and 1STMILE BUY, LLC (collectively, “1stMILE,” “we,” “our,” or “us”). 1STMILE provides this Privacy Policy to describe how we collect, use, and share information of individuals who use our services, including in connection with our website located at https://www.1stMILE.com and websites operated by our affiliates; participate in programs offered by us (including but not limited to the 1stMILE Loyalty Program and the 1stMILE Buy Program); use our mobile app (the “app”); and provide information through in-store terminals or kiosks that display this Privacy Policy (collectively, the “Platforms”).

When you provide information to an automotive repair shop through 1stMILE's services in order to obtain services from that automotive repair shop, that data is controlled by the automotive repair shop, not this Privacy Policy. Please refer to that repair shop's privacy statement to understand how it treats your information.

1. Information Collection

When using any of the Platforms, you may provide information about yourself. We collect this information when you create an account, provide information via email or the 1stMILE Online Chat, complete surveys and forms through the 1stMILE Platforms, submit information through a terminal, enroll in our programs, or interact with us for any other purpose. We may also automatically collect information relating to your interactions with us and our Platforms.

For example, we may collect or access the following information:

• Personal and online identifiers (such as name, email address, IP address, or other unique online identifiers)
• Certain customer record information (such as address, telephone number, financial account numbers, or any other financial information)
• Characteristics of protected classifications under California or federal law (such as gender)
• Commercial or transactions information (such as records of transactions with 1stMILE)
• Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
• Biometric information (such as call recordings, after obtaining any consent required under applicable law)
• Geolocation information
• Inferences drawn from the above information about your predicted characteristics and preferences
• Other information about you that is linked to the personal information above (such as Vehicle Identification Number (“VIN”), make and model of your vehicle, and any other information you associate with your 1stMILE account; or an email address that we have matched with any other information collected about you).

Please see the “Analytics” section of this Privacy Policy to learn more about the use of this information and the choices available to you.

2. Information Use

We may use your information for any lawful purpose, including the following:

• To respond to your inquiries;
• To operate and improve our services, including to provide better services, products, and opportunities to our customers and visitors to our Platforms;
• To enroll you in and administer our programs, including the 1stMILE Loyalty Program and the 1stMILE Buy Program, including to deliver services related to the programs;
• To operate, personalize, and improve the Platforms, including for advertising and analytics purposes;
• To send surveys, promotions, and marketing materials (including via email, SMS text messaging, and on the 1stMILE Dashboard) that may be of interest to you, and for other marketing activities (such as displaying advertisements on terminals or kiosks and analyzing and evaluating advertising and marketing campaigns);
• To prevent and detect fraud;
• To comply with the law and to maintain the security of our Platforms; or
• With your consent, or as otherwise disclosed at the time information is collected.

We may use information that has been de-identified or aggregated without limitation.

3. Information Sharing

We may share the information we collect with other parties, including the following:

• To Fulfill Your Requests. We may share information with third-party service providers or vendors who process data on our behalf to help our business operations, such as payment processors and email service providers, or with our legal or business advisors.
• Corporate Changes. We may share information as part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding.
• As Required by Law and Similar Disclosures. We may share information pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity.
• Affiliates. We may share information with corporate affiliates, including those not under the 1stMILE brand.
• Other Third Parties. We may share information with third-party companies, business partners, and other organizations whose products or services we think may interest you.
• Vendors. We share information with vendors who provide services to us.
• Consent. We may share information with your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information that has been de-identified or aggregated without limitation.

4. Security

To prevent unauthorized access, use, or disclosure of information we collect, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information.

5. Digital Advertising & Analytics

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

1stMile adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity. You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. You can also exercise choices regarding interest-based advertising on your mobile device by downloading the appropriate version of the DAA's AppChoices tool at https://youradchoices.com/appchoices.

If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

We may work with third parties that collect data about your use of the Platforms and other sites or apps over time for non-advertising purposes. We use Google Analytics and other third-party services to improve the performance of the Platforms and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Platforms, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

6. Third-Party Links and Tools

We may provide links on the Platforms to third-party websites or apps, including plug-ins that link to social media sites such as Facebook, Twitter, YouTube, LinkedIn, and Instagram. These websites and apps are independent from 1stMILE and have their own separate privacy policies. 1stMILE is not responsible for the privacy practices or content of such third-party websites or apps. We recommend that you review the third parties' privacy polices before you visit these websites or apps to learn about their data practices.

The Platforms may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Platforms, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.

7. Opting Out of Promotional Emails and Text Messages

If you decide for any reason that you no longer wish to receive promotional emails from us, you can unsubscribe from our email distribution list by clicking the “unsubscribe” link located at the bottom of each promotional email. You can also opt out of receiving emails by sending a request to Privacy@1stMILE.com. Please note that if you opt out of receiving promotional emails from us, we may still contact you by email for transactional purposes related to your account or business relationship with us.

To opt out of promotional text messages, please reply STOP to any message you receive.

8. California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.

Personal Information We Collect. For the categories of personal information we collected about California consumers in the preceding 12 months, please see Section 1 of this Privacy Policy.

1stMILE engages in targeted advertising activities using personal information such as loyalty program data, Vehicle Identification Numbers (VINs), and vehicle service history. Under the CCPA, these activities may constitute a "sale" or "sharing" of personal information, even when no monetary consideration is exchanged. California residents have the right to opt out of these activities as described in the "Your Rights Regarding Personal Information" section below.

Categories of Sources. We collect this personal information from the following categories of sources:

• You;
• Advertising networks;
• Affiliates and joint venture partners;
• Data analytics providers;
• Data brokers and third-party data providers;
• Government entities;
• Social networks; and
• Service providers.

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation:

• Our commercial purposes, which can include:
  • To market our products and services, such as by sending you updates, promotions, advertisements, and marketing materials that may be of interest to you; and
  • To enable commercial transactions.
• Our business purposes as identified in the CCPA, which can include:
  • Auditing related to our interactions with you;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and
  • Other one-time uses.

Recipients of California Personal Information. We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:

• Service providers;
• Advertising networks;
• Internet service providers;
• Data analytics providers;
• Affiliates;
• Operating systems and platforms; and
• Social networks.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, and disclose about you; the categories of sources from which we collected personal information about you; our purposes for collecting personal information about you; the categories of personal information about you that we have disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• The right to correct inaccuracies in the personal information we have collected about you.
• The right to request that we delete the personal information we have collected from you.
• The right to opt out of (i) the sharing or processing of personal information for targeted advertising; (ii) the sale of personal information; or (iii) profiling for decisions that have legal or other significant effects upon you. Please note that if you opt out of certain practices, we may be unable to provide you with some services.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the rights described above, please contact us using the following information and submit the required verifying information, as further described below:

• By phone at (855) 554-6179
• By email at Privacy@1stMILE.com
• Online through https://1stMILE.com/california-consumer-request-form

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request. You will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your full name, email address, or other contact information, and information about your relationship with 1stMILE.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf. You will need to provide your identification, the identification of the agent, and your written consent for them to act on your behalf.

Opt-out Preference Signals. Certain mechanisms or technologies may be used to signal your opt-out preferences to entities that process personal information. To the extent that we are able to recognize these signals and they are legally sufficient, we process these signals as requests to opt out of processing for (i) sales of personal information and/or (ii) sharing or processing of personal information for targeted advertising. Depending on the signal you select, the opt-out may apply to only certain interactions, such as on a specific a browser or device. You may select and install a mechanism or technology to send opt-out preference signals of your choice per the provider's instructions.

Minors' Right to Opt In. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

9. Notice of Financial Incentive for California Residents

1stMILE offers you the opportunity to participate in multiple programs offered by us, including the 1stMILE Loyalty Program and the 1stMILE Buy Program (“Programs”). Our collection of certain personal information about you as described in this Privacy Policy, including the categories of information described in “Information Collection” section above, allows us to operate the Programs and provide participant benefits such as discounts on future visits to automotive repair shops.

These benefits and the terms of participation in the Programs are available here: https://1stmile.com/faq/. The amount and nature of these benefits will be determined by the extent of your participation in the Programs. We may adjust the terms of participation from time to time.

If you wish to stop participating in the Programs, email your communications preferences to Privacy@1stMILE.com. Please be advised that we may continue to process information about you in connection with your transactions with 1stMILE.

The price and service differences, such as discounts and credits, that are available to you through the Programs are based upon our reasonable determination of the value that we receive from collecting and retaining personal information about you in connection with operating our business. This estimated value takes into account a variety of factors as permitted by law, including (but not limited to) our expenses incurred in collecting and processing the information, our expenses incurred in providing rewards to you, and the estimated marginal revenue that we may derive from information related to a specific Programs participant.

Please note that this notice of financial incentive applies only to Programs run by us. For policies relating to loyalty programs run by automotive repair shops that we service, please see the relevant notices provided by those automotive repair shops.

10. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time. You should check this page periodically to learn of any updates. If we make changes to this Privacy Policy, we will post the amended version on our Platforms and the effective date will be updated. Your continued use of the Platforms indicates you agree to those updates.

11. How to Contact Us

If you have any questions, requests, or concerns related to this Privacy Policy, please email us at Privacy@1stMILE.com or call (855) 554-6179.