Data Exchange takes Business, Dealership and Consumer privacy seriously. As such we are committed to the safeguarding of the consumer’s web browsing and location data as well as the data shared by our clients. Consumer data provided by, or derived from information gathered on behalf of our client’s business(es) is gathered by Data Exchange through; 3rd parties, aggregators, visitors to publisher websites where Data Exchange receives 1st party ad placement requests, client websites via cookies, device fingerprinting, phone call capture, lead forms and the business or dealership CRM. Data Exchange has developed a comprehensive privacy statement for client and consumer to understand the terms and conditions surrounding the collection and use of the information gathered. This statement discloses the types of information we collect, how it is used, and how our client or a consumer can gain access to, opt-out, edit, purge or update any of the data we’ve collected.

General Provisions For Businesses Leveraging Data Exchange Products & Services:

By using Data Exchange Services or any affiliated company inclusive of subcontractor services, herein referred to collectively as “Data Exchange Services”, your company accepts the terms of this privacy policy, data collection and this data usage agreement. This is a legally binding agreement between your Business Entity a.k.a Dealership and Data Exchange, affiliated companies inclusive of subcontractors we leverage; Please read carefully. When using Data Exchange Services, your business may be subject to other posted terms and guidelines applicable to certain services available on www.Data.Exchange in regular updates. All terms, conditions and guidelines outlined by Data Exchange herein, including our privacy policy are part of both our standard Website Visitor Agreement as well as incorporated into the Data Exchange client facing agreements applicable to any use of the Data Exchange products or services. Unless explicitly stated otherwise, any features or services provided by Data Exchange are subject to our privacy policy, data collection and data usage agreement. Accessing Data Exchange Services in any manner, even through automated means, constitutes your company’s use of the Data Exchange Services and your/its agreement to be bound by our privacy policy, data collection and data usage agreement. Data Exchange may change the terms of our privacy policy, data collection and data usage agreements from time to time and will revise the effective date when it revisions are made. Your business(es) or dealership(s) continued use of the Data Exchange products and services after the posted effective date constitutes your agreement to be bound by this agreement as modified, except that modifications do not apply to any dispute arising prior to their effective date. Data Exchange may change, restrict access to, suspend, or discontinue the Data Exchange products or services, or any portion thereof, at anytime – without notice.

Materials, incentives and specials used to create advertisements whether, digital, analog or physical (e.g; direct mail) herein referred to as “creative” which are provided by Data Exchange, their affiliated companies inclusive of 3rd party subcontractors are for general informational purposes only. While we aim to provide products, services and advertisements which are useful, be mindful that creative may, from time to time, contain errors. Data Exchange products and services include materials and information collected from an array of third parties which we may or may not have evaluated and/or reviewed. We make no guarantees regarding the accuracy, completeness, timeliness, or reliability of any of the materials, creative or information encompassed in the Data Exchange products or services, and you should not rely on them without independent verification.

California – Consumer Facing:

Under California law, we will not share information we collect about any consumer with companies outside of Data Exchange, Data Exchange affiliated companies or the original contracting business, unless allowed by law. We treat IP address and location data in the State of California as well as the entire United States as “PII” (Personally Identifiable Information). We will limit sharing among our companies to the extent required by California law and Data Exchange internal practices which strictly adhere to a CCPA | CPRA nationally. You can inquire here for a continually updated list of “data processors” Data Exchange works with.

Guiding Principles

Data Exchange respects the privacy of individuals whose data has been collected through our services, via email, form submission, tracked phone calls, location data or engage with, in any way through advertisements, products or services offered by Data Exchange on our client’s behalf. Accordingly, our policy regarding privacy (both online and off) has been developed using the following guiding principles:

Data Exchange and closely held affiliated companies maintain a strict “no-spam” policy. Subscribers to our client’s email services (coupled with any other feature or service found on the Data Exchange Website leveraged by our clients) will not receive unsolicited emails or related messaging from Data Exchange (acting on behalf of our client) unless the consumers behavior indicates they are in-market for a product or related client service verified through the use of cookies, mobile device data, lead submissions, location data or CRM captured inquiries provided the consumer has been apprised of our clients privacy policy accepting the terms of such by using their website, or any publisher, data aggregator or 3rd party website which clearly defines their data collection and data usage policies that closely align with policies stated here. Data Exchange collects information online, through location data, data aggregators, cookies/pixels and 3rd party data appends primarily to provide our client’s existing and potential local shoppers with a more relevant experience while shopping for related products or services. When doing so, we will make every reasonable effort to avoid excessive or irrelevant collection of data that does not relate to the subject matter the consumers information was originally gathered for. Data Exchange will take reasonable physical, electronic and managerial measures to safeguard and secure any information both of our client and the consumer which has been collected and/or provided to us (e.g. data will be stored in protected cloud data warehouses on secured servers with restricted access). Data Exchange will not share or sell any of the consumers or client’s information provided to us from the CRM/Database, phone call tracking or collected while submitting lead forms from the client’s business or dealership website; with anyone, without the written consent of the client who has contracted with Data Exchange – other than for use in the service originally contracted for. At the time your business(es) or dealership registers for any such service, you will be notified of, and asked to consent to the sharing of your clients information with particular third parties necessary to aide in the provisioning of the requested Data Exchange products and/or services.

Non-Personally Identifiable Data:

Anytime a consumer visits your business(es) website, a website which sells ad placements to our 1st party audiences, and/or a website where we have contractual placed a fully disclosed tracking script either 1st, 2nd or 3rd party, we may gather certain non-personally identifiable information. This information may include the type and version of the browser, service provider, IP address, location data (Now deemed under CCPA | CPRA as PII) and any search queries the consumer may have used to locate the products, services they searched for. We use this information to help diagnose problems with our platform, build holistic profiles of our client’s 1st party and related Data Exchange modeled shoppers, administer our analytics, attribution platform while compiling broad statistical, probabilistic and behavioral data. In addition, we gather certain navigational information about where a consumer goes on our clients website(s) and across any website which sells ad placements against our 1st party audience. This information enables us to determine which websites are most frequently visited and helps us to tailor the creative to be served on these sites to fit the needs and interests of our client’s potential local shoppers. Such information is gathered by us in the aggregate and will not be associated with a specific individual if that individual has opted-out of consent or where limited by law.

Information Voluntarily Provided:

Any information provided to our client (i.e. name, email address, etc.) when a consumer enrolls in an email reminder service, requests for information, or use of any other interactive portions of our clients website, is securely maintained on our web server and internal data warehousing systems. This information may be used to provide consumers with information requested from our client’s business around their products and services, or to provide the consumer with special notices. Consumers may opt-out of receiving future communications at any time (see opt-out procedures on this website). The data collected may also be used to tailor our ad placements by providing content which is deemed relevant to the consumer based on the indicated behavioral interests in a geographic region or regions.

Information Collected from Other Sources:

To help us better understand and respond to consumers needs and interests, we may in the future receive information about consumers from other sources. We will ask any provider of such information to represent and warrant that the information has been gathered and maintained in accordance with all state and federal laws. Any such information will be maintained by us in accordance with the standards set forth in this privacy policy, data usage and collection agreement along with other personal information the consumer has provided.

Disclosure of Personal Information:

Data Exchange understands the importance of consumer privacy. We collect and maintain the personal information of our client’s consumers for our client’s use, our own use and select 3rd parties which help us fulfill our services. We do not sell, rent, or trade consumer information to third parties, other than as described herein, and never without our originating client’s consent, further the consumer’s consent can be withdrawn at any time using the opt-out form found on this website.

Business Partners:

Data Exchange may partner with select data collection, targeting and analytic providers along with other companies at various times to provide expanded services to our client’s website visitors and local geographic shoppers. As part of such a relationship, we may share with these companies the data collected through the use of certain pixels and data collection mechanisms, interactive website functions as well as location data tools. The information captured and provided by these mechanisms about the visitors and local shoppers is available to Data Exchange, our client and select members of their employ and 3rd party partners.

Data Exchange Subprocessors:
Data Exchange and its affiliates engage third-party entities to assist them in connection with Data Exchange Services. View the Data Exchange Subprocessor list here
Agents:

Data Exchange may use other companies and individuals to perform certain functions on our behalf. Such parties only have access to (rarely) the personal information and generally the anonymous information needed to perform these functions and may not use or store the information for any other purpose.

Business Transfers:

In the event that Data Exchange and or an affiliated company sells or transfers a particular portion of its business assets, derived data from consumer information may be one of the business assets transferred as part of the transaction. If substantially all of the assets of Data Exchange are acquired, derived consumer information may be transferred as part of the acquisition.

Compliance with Law/Safety:

Data Exchange may disclose specific personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect the users (our clients) of our services, their websites and/or businesses, or the public.

With Consent:

Other than as set forth in this Privacy Policy, consumers will be notified when any personally-identifiable information about them may be shared with third parties (outside of the data usage and privacy policies disclosed herein), and the consumer has the right to decline the sharing of that information at any time.

Use of Cookies:

Data Exchange may use a browser feature known as a “cookie.” Cookies are small files placed on a consumer’s computer that assist us in providing consumers with tailored ads, and customized browsing experiences. Data Exchange uses cookies to provide consumers with the convenience of tailored ads tied to specific browsing behavior, attribution and related data analytic processes. Cookies are also utilized to help us better provide consumers with information targeted by interests, based upon a consumers prior browsing across websites which have our pixel placed, sell ad placements against our 1st party audience or on our client’s website(s). The “help” section of the toolbar on most browsers will inform consumers on how to prevent a browser from accepting new cookies, how to have the browser notify a consumer upon the receipt of a new cookie, or how to disable the use of cookies completely. As our services have been partially designed to take advantage of the use of cookies. Should a consumer configure their browser to decline the use of cookies, certain features of our client’s websites, analytics and tracking may not function correctly for both our client and the consumer.

Use of Location Data:

Data Exchange may use location data derived from apps on a consumer mobile device. Our services have been designed to take advantage of location data and can opt-out of by limiting apps on a mobile device, coupled with disabling location based web browsing from collecting a consumer’s location data. Should a consumer configure their mobile device to decline the use of location data, certain features of our products or services inclusive of analytics and/or tracking may not function correctly for both our client and the consumer. In the State of California as with all of the United States; Data Exchange considers and treats location data as PII in accordance with CCPA | CPRA whether implicit or implied and as such Data Exchange will act in compliance with all known rules and regulations in the CCPA | CPRA not just in California, but rather as a framework for Data Exchange’s operations in their entirety.

Accessing Our Services from Outside of the United States:

If you are a prospective client looking to leverage Data Exchange services for a business whose location is outside of the U.S., their maybe laws, ordinances and regulations which dramatically affect the performance or even preclude the use of our offerings (e.g. GDPR). Please consult with your Data Exchange representative before contemplating any engagement if your business is located outside the U.S.

External Links, Brand Compliance and Whitelist:

Our advertisements are placed on various publisher websites. Data Exchange is not responsible for the privacy practices or the content of such websites. To help ensure the protection of a consumer’s privacy, we recommend that you the client review the privacy policy and related content to comply with your business’s brand safety requirements of any site we provide in our whitelist where we may serve ads on your behalf.

Passwords:

Client – The personal data record created through your registration with our platform can only be accessed with the unique password associated to that record. To protect the integrity of the information collected on behalf of your account, you should not disclose or otherwise reveal your password to anyone, and your username or password is NOT permitted to be shared with any third parties whether you have contracted with them for a similar service or otherwise.


Data Exchange’s Privacy and Data Integrity Policies provide foundational framework for our business decisions and data solutions.

Our focus is to support the auto buying process for the automotive industry and the consumer by, in most cases blindly aggregating and analyzing billions of anonymous shopping sessions to better understand changes in consumer trends and demands. Thus improving the consumer shopping experience, reducing waste at all levels of the vehicle supply chain, and ultimately providing the right vehicle at the client’s advertised cost to the consumer. Data Exchange provides these benefits while protecting the rights of all consumers and data owners.

Overview of Data Exchange Data Collection

Data Exchange is a comprehensive aggregator of data relating to automotive shopping behavior.

Among other placements defined extensively herein, we collect data from our clients websites using our data collection script. We collect all website session activity, and maintain upon capture a consumers personally identifiable information entered into a form field such as name, phone, email, or when a consumer arrives at a website through a link containing a unique identifier.

A consumer’s personally identifiable information is made available only to Data Exchange and their affiliates, the website owner (our client) where the consumer disclosed the information, and those third parties designated by the website owner (our client). We do from time to time collect Personally Identifiable Information (PIII) from our clients website and CRM through the use of our pixel/tracking scripts as part of a Data Exchange provided products and services or CRM data, BUT not as a 3rd party with no contractual 1st party service being performed.

Shopping activity is aggregated to produce an individual holistic shopping profile, and aggregated with all shopping activity data to power information solutions such as industry trends, consumer demand analysis and platform performance measurements.

Data Collected

Data collected by Data Exchange includes interactions with the website where our data collection scripts are present. Examples of the types of data we collect include:

  • Links clicked
  • Pages viewed
  • Form field selections (NO CREDIT APPS)
  • Videos Played
  • Content Interacted with

We collect all website session activity, and often capture personally identifiable information entered into a form fields such as name, phone, email, and when a consumer arrives at a website through a link containing a unique identifier or through the client’s CRM.

We do NOT collect Social security numbers, credit card numbers and passwords or data outside of the United States, as they’re intentionally excluded from our data collection efforts.

As described briefly above, personally identifiable information may also be introduced into the Data Exchange system through CRM record set imports. These record sets are typically exported from our customer via their lead database (CRM), and include the following consumer information disclosed to a business/dealership/website owner:

  • First and last name and/or unique identifier
  • Phone numbers
  • Email addresses
  • Mailing Address

However, if we have been contracted to simply collect interaction/behavioral data from a 3rd party website for analysis and or ad targeting we do NOT capture any of these four items listed here:

  • First and last name
  • Phone numbers
  • Email addresses
  • Mailing Address
Data Maintained

Data Exchange manages all data collected under a comprehensive information security program. Personally identifiable information is limited to those employees/contractors with a need to access basis, and specific protocols are defined for the access, use and transfer of this data.

Data Usage

If disclosed, a consumers personally identifiable information such as name, phone, email or other unique identifiers is only made available to Data Exchange and closely held affiliates, designated 3rd parties and the contracting business/dealership client who may share this information with other designated third parties.

Behavioral and location data is used to create a profile of a consumer’s shopping, vehicle(s) of interest and related shopping preferences. Coupled with millions of data points, profiles contain how long a consumer has been shopping and what they’re most likely to purchase.

An individual’s behavioral and location data is also aggregated with shopping activity data from all consumers behavior collected, to power information solutions such as industry trends, consumer demand analysis and platform performance measurements.

Personally identifiable information imported into our platform may be appended with shopping preferences based on a consumers aggregated browsing, shopping and location behavior.

Request Your Consumer File

You can request a copy of your consumer file by calling 844.446.4440 ext 3 or filling out this form

Revised 3/1/2021

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