Privacy Policy

Interpretation

The following definitions apply equally to singular and plural forms.

Definitions

For the purposes of this Privacy Policy: You mean the individual who accesses or uses the Service, DriveClub, or any other legal entity on whose behalf such individual accesses or uses the Service, as applicable. Company (referred to as “DriveClub,” "the Company," "We," "Us," or "Our" in this Agreement) means DriveClub, located at 1301 N Broadway, STE 32353, Los Angeles, CA 90012. Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means owning 50% or more of the shares, equity interests, or other voting securities for election of directors or other managing authority. Account means a unique account created for you to access our service or parts of our Service. Website refers to DriveClub.io, accessible at www.driveclub.io. Service refers to the Website and the provision of vehicle ownership savings products and services. The term "country" refers to the United States. Service Provider means any individual or company that processes data for DriveClub. It includes third-party companies, such as Service Providers that underwrite and service vehicle service contracts, or people employed by DriveClub to assist with the Service, deliver the service on behalf of DriveClub, perform tasks related to the service, or help DriveClub analyze how the Service is used. A third-party social media service is any website or social network where a user can log in or create an account to access the Service. Personal Data means any information that pertains to an identified or identifiable person. For the purposes of the CCPA, Personal Data includes any details that identify, relate to, describe, or can be linked to, or can reasonably be connected directly or indirectly to You. Cookies — you may manage your cookie preferences at any time using our Cookie Preferences tool, if available, or through your browser settings. Certain cookies are necessary for the operation of the Service and cannot be disabled. Usage Data refers to data collected automatically, either generated by using the Service or from the Service infrastructure itself (for example, the length of a page visit). Do Not Track (DNT) is a concept promoted by U.S. regulatory authorities, especially the Federal Trade Commission (FTC), to encourage the internet industry to develop and implement a way for users to control how their online activities are tracked across different websites. Under the CCPA (California Consumer Privacy Act), "business" refers to DriveClub as the legal entity that collects consumers' personal information and determines how it is processed, or that acts on behalf of such an entity. It is the entity that, alone or with others, makes decisions about processing consumers' personal data and conducts business in California. Consumer, for the purposes of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined by law, includes (1) every individual who is in the USA for a purpose other than a temporary or transitory one, and (2) every individual who is domiciled in the USA but is outside the USA for a temporary or transitory purpose. Sale, for the purposes of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer's Personal Information to another business or a third party, whether orally, in writing, electronically, or through other means, for monetary or other valuable consideration.

Types of Data Collected — Personal Data

While using Our Service, we may ask you to provide certain personally identifiable information that can be used to contact you, identify you, or complete forms related to purchasing vehicle ownership products and services. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal Code, City
• Vehicle information (year, make, model, mileage, VIN)
• Usage Data

Usage Data

Usage data is collected automatically when you use the Service. Usage Data may include information such as your device's Internet Protocol address (e.g., IP address), browser type and version, the pages of our Service that you visit, the date and time of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. When you access the service on a mobile device, we may automatically collect certain information, including, but not limited to, the type of device, your device's unique ID, its IP address, your mobile operating system, the type of mobile browser you use, unique device identifiers, and other diagnostic data. We may also collect information that your browser transmits whenever you visit our service or access it on a mobile device.

Use of Artificial Intelligence and Automated Processing

DriveClub uses artificial intelligence ("AI"), including our conversational assistant Milo, to help answer questions, personalize your experience, recommend products and services, detect fraud, improve customer support, and enhance our offerings. When you interact with Milo, your prompts, responses, account information, vehicle information, and related usage data may be processed by DriveClub and trusted third-party AI service providers acting on our behalf. These providers are contractually required to protect your information and may only process it for authorized business purposes. We may retain AI conversations to improve our services, monitor quality, investigate fraud or abuse, maintain security, comply with legal obligations, and train or improve our AI systems where permitted by law. Please do not include highly sensitive personal information—such as Social Security numbers, driver's license numbers, passport numbers, financial account credentials, or health information—unless specifically requested as part of a transaction or required to provide a service. DriveClub uses AI to assist with recommendations and customer support. We do not use AI alone to make decisions that produce legal or similarly significant effects without appropriate human review. AI-generated responses may be reviewed by authorized DriveClub personnel for quality assurance, customer support, safety, security, and legal compliance. We use artificial intelligence (“AI”) and automated systems in our products and services to enhance customer experience and business functions. These technologies assist us in analyzing usage patterns, customizing content and recommendations, handling customer inquiries, boosting fraud prevention, and refining our offerings. Our AI systems may handle personal information such as account details, messages, interactions, and usage data to provide relevant experiences. Sometimes, we work with third-party AI providers who process data on our behalf under strict contractual and confidentiality agreements. We do not rely on AI to make decisions that have legal or similarly significant consequences without human oversight. All automated outputs are reviewed or supervised by human team members as appropriate. When you use our AI-powered tools, like chat assistants or support bots, your messages and related data may be processed by AI systems to generate responses or enhance service quality. Please avoid sharing sensitive personal information during these interactions. You can contact us at support@driveclub.io for more information on how we use AI or to exercise your data privacy rights.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to monitor activity on Our Service and store certain information. These tracking technologies include beacons, tags, and scripts, which help us collect data and improve Our Service. You can instruct your browser to block all cookies or to notify you when a cookie is sent. However, if you do not accept cookies, you might not be able to use certain parts of our service, such as identifying yourself as a returning customer. Cookies can be either "Persistent" or "Session" Cookies. Persistent Cookies remain on your computer or mobile device even after you go offline, while Session Cookies are deleted as soon as you close your web browser. We utilize both session and persistent Cookies for the purposes outlined below: Necessary / Essential Cookies (Type: Session Cookies; Administered by: Us) — These cookies are essential for providing you with services available through the website and enabling you to use some of its features. They help authenticate users and prevent fraudulent account use. Without these cookies, the services you request cannot be delivered, and we only use these cookies to give you those services. Cookies Policy / Notice Acceptance Cookies (Type: Persistent Cookies; Administered by: Us) — These cookies determine if users have accepted the use of cookies on the website. Functionality Cookies (Type: Persistent Cookies; Administered by: Us) — These Cookies help us remember your choices when you use the Website, such as your login details and language preference. The goal of these Cookies is to provide you with a more personalized experience and to prevent you from having to re-enter your preferences each time you visit the Website. Tracking and Performance Cookies (Type: Persistent Cookies; Administered by: Third-Parties) — These Cookies collect information about Website traffic and how users interact with it. The data gathered may directly or indirectly identify you as an individual visitor because it is usually linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features, or functionalities of the Website to observe how users respond. For more details about the cookies we use and your options regarding cookies, please visit our Cookies Policy.

Use of Your Personal Data

DriveClub may collect and use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring how it is used.
• To manage Your Account: to oversee your registration as a user of the Service. The Personal Data You provide may grant You access to various functionalities of the Service available to You as a registered user.
• For the performance of a contract: the development, compliance, and execution of the purchase contract for the products, items, or services you have bought or of any other contract with Us through the Service.
• To contact You: To reach You by email, phone calls, SMS, or other similar electronic communication methods, such as push notifications from a mobile app about updates or informational messages related to the functionalities, products, or contracted services, including security updates when necessary or reasonable for their implementation.
• To provide you with news, special offers, and general information about other goods, services, and events that we offer, which are similar to those you have already purchased or inquired about, unless you have opted out of receiving such information.
• To manage your requests: attend to and handle them for you.

Sharing Your Personal Information

We might share your personal information in these situations:

• With Service Providers: We may share your personal information with Service Providers to activate and service your vehicle service contract(s), monitor and analyze the use of our Service, show advertisements to you to help support and maintain our Service, contact you, advertise on third-party websites to you after you have visited our Service, or for payment processing.
• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business to another company.
• With Affiliates: We may share your information with our affiliates, and in such cases, we will require those affiliates to follow this Privacy Policy. Affiliates include our parent company, subsidiaries, joint venture partners, or other companies that we control or are under common control with us.
• With Business partners: We may share your information with our business partners to provide you with certain products, services, or promotions.

Public Sharing and Third-Party Social Media Services

When you share personal information or interact with other users in public areas, this information may be seen by all users and could be publicly shared outside the platform. If you connect with other users or sign in through a Third-Party Social Media Service, your contacts on that service may see your name, profile, pictures, and details about your activity. Likewise, other users will be able to view descriptions of your activity, communicate with you, and see your profile.

Service Providers, AI Partners, and Additional Data

We may share information with service providers that help us deliver requested services, including AI providers, payment processors, roadside assistance providers, insurance partners, vehicle protection providers, repair networks, analytics providers, communication platforms, identity verification providers, fraud prevention providers, and cloud infrastructure providers. These companies may process information only as necessary to provide services to DriveClub. In addition to the information described above, we may collect AI conversation history, customer support interactions, vehicle ownership information, membership activity, benefit usage, service history, personalization preferences, and interactions with our business partners when you choose to use those services.

Retention of Your Personal Data

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, prevent fraud, enforce our agreements, and maintain appropriate business records. AI conversation history may also be retained for quality assurance, product improvement, and security purposes consistent with applicable law.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at DriveClub's operating offices and at other locations where the parties involved are based. This means that the information may be transferred to — and stored on — computers outside your state, province, country, or jurisdiction, where data protection laws might differ from those in your region. Your consent to this Privacy Policy, along with your submission of such information, signifies your agreement to that transfer. DriveClub will take all reasonably necessary steps to ensure that your data is handled securely and in accordance with this Privacy Policy. No transfer of Your Personal Data will occur to an organization or country unless adequate safeguards, including data security and privacy protections, are in place.

Disclosure of Your Personal Data — Business Transactions

If DriveClub is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and subject to a different Privacy Policy.

Disclosure of Your Personal Data — Law Enforcement

Under certain circumstances, DriveClub may need to disclose Your Personal Data if required by law or in response to valid requests from public authorities (e.g., a court or government agency).

Disclosure of Your Personal Data — Other Legal Requirements

DriveClub may disclose Your Personal Data in good faith if it believes that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of DriveClub
• Prevent or investigate potential misconduct related to the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

DriveClub maintains administrative, technical, and physical safeguards designed to protect personal information. These measures include, where appropriate, encryption of data in transit, access controls, authentication, logging, monitoring, vendor security reviews, and least-privilege access practices. Although we take commercially reasonable measures to protect your information, no security system is completely secure.

Analytics

We might work with third-party service providers to track and analyze how our Service is used. Google Analytics — Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data it collects to track and monitor use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt out of having your activity on the Service made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use Your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You can opt out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting Us at support@driveclub.io. We might use Email Marketing Service Providers to handle and send emails to you.

Behavioral Remarketing

DriveClub may use remarketing services to advertise on third-party websites to you after you visit our Service. Our third-party vendors, and we use cookies to inform, optimize, and serve ads based on your past visits to our Service.

Payments

We may offer paid products and/or services through the Service. In such cases, we might use third-party services for payment processing (e.g., payment processors). We do not store or collect your payment card details. That information is given directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy. These payment processors follow the standards set by PCI DSS, managed by the PCI Security Standards Council, a collaboration of brands such as Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information. FluidPay — their Privacy Policy can be viewed at: https://www.fluidpay.com/privacy-policy

Your Rights under the CCPA

Under this Privacy Policy and by law, if you are a resident of California, you have the following rights.

• The right to notice. You must be properly informed about which categories of Personal Data are being collected and the purposes for which the Personal Data is used.
• The right to access or request. The CCPA allows you to request and receive information from DriveClub regarding the disclosure of your Personal Data that has been collected in the past 12 months by DriveClub or its subsidiaries to a third party for the third party’s direct marketing purposes.
• The right to refuse the sale of your Personal Data. You also have the right to request that DriveClub not sell your Personal Data to third parties. You can do this by visiting our "Do Not Sell My Personal Information" section or webpage.
• The right to know about your personal data. You have the right to request and receive information from DriveClub regarding the disclosure of the categories of Personal Data collected, the sources from which the Personal Data was collected, the business or commercial reason for collecting or selling the Personal Data, the categories of third parties with whom we share personal data, and the particular pieces of Personal Data we gathered about you.
• The right to delete Personal Data. You also have the right to request the deletion of your Personal Data collected in the past 12 months.
• The right not to be discriminated against. You have the right not to face discrimination for exercising any of Your Consumer rights, including by denying goods or services to you; charging different prices or rates for goods or services, including offering discounts, other benefits, or imposing penalties; providing a different level or quality of goods or services to you; or suggesting that you will get a different price, rate, or level of goods or services.

Exercising Your CCPA Data Protection Rights

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights may include the right to know, access, correct, delete, and obtain information about your personal information; the right to opt out of the sale or sharing of personal information where applicable; the right to limit the use and disclosure of sensitive personal information where applicable; and the right not to receive discriminatory treatment for exercising your privacy rights.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we work with (such as our advertising partners) may use technology on the Service that "sells" personal information as defined under the CCPA. If you want to opt out of using your personal information for interest-based advertising and potential sales as defined by the CCPA law, follow the instructions below. Please note that opting out is specific to each browser you use. You may need to opt out on every browser individually.

Opt-Out — Website

You can opt out of receiving personalized ads provided by our Service Providers by following the instructions given on the Service:

• From our "Cookie Consent" notice banner
• From our "CCPA Opt-out" notice banner
• From our "Do Not Sell My Personal Information" notice banner
• From our "Do Not Sell My Personal Information" link

Opt-Out — Mobile Devices

The opt-out will set a cookie on your computer that is unique to the browser you use to opt out. If you switch browsers or delete the cookies stored by your browser, you'll need to opt out again. Your mobile device may allow you to opt out of using information about the apps you use so you can avoid targeted ads based on your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices
• You can also prevent your mobile device from collecting location data by adjusting its settings.

Do Not Track Signals

Our service does not respond to Do Not Track signals. However, some third-party websites do track your browsing activity. If you visit such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children's Privacy

Our Service does not serve anyone under 18. We do not knowingly collect personally identifiable information from anyone under 18. If you are a parent or guardian and are aware that your child has provided us with personal data, please contact us. If we find that we have collected personal data from anyone under 18 without verifying parental consent, we will remove that information from our servers. If we need to rely on consent as the legal basis for processing your information and your country requires parental consent, we may need to obtain your parents' permission before collecting and using it.

California Business and Professions Code § 22581

California Business and Professions Code section 22581 allows California residents under 18 years old who are registered users of online sites, services, or applications to request and obtain the removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account. Be aware that your request does not guarantee the complete or comprehensive removal of content or information posted online, and the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may include links to other websites not operated by Us. If you click on a third-party link, you will be taken to that third party's site. We strongly recommend that you review the Privacy Policy of every site you visit. We do not control and are not responsible for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We might update our Privacy Policy occasionally. We will inform you of any updates by posting the latest version of the Privacy Policy on this page. We will notify you by email and/or a prominent notice on our Service before the change takes effect, and we will update the "Last updated" date at the top of this Privacy Policy. You should review this Privacy Policy regularly for updates. Changes take effect when they are posted on this page. As DriveClub introduces new AI capabilities, connected vehicle features, or additional partner services, we may update this Privacy Policy to describe those practices. Material changes will be communicated as required by applicable law before they become effective.

Contact Us

If you have any questions about this Privacy Policy, you can contact us: By email: support@driveclub.io