Effective Date: October 12, 2023

At Sprout Assure, we, along with our affiliates, agents, and vendors (referred to collectively as “Sprout Assure,” “we,” “us,” or “our”), prioritize the protection of your privacy and the security of the personal data you share with us. This Privacy Policy (“Policy”) is designed to inform you about the types of information we collect from you through our interactions, including your use of our digital platforms, which are accessible at www.sproutassure.com, along with any related websites and mobile applications we may offer, and any other online submissions you make to us (collectively referred to as the “Website”). This policy outlines how we may use the information we collect, and the choices available to you regarding how your information is used. By visiting and using our Website, you agree to the terms of this Privacy Policy.

A. UPDATES TO THIS PRIVACY POLICY

Sprout Assure reserves the right, at its sole discretion, to alter this Privacy Policy at any time without prior notice to any user of the Website, including to comply with privacy laws, regulations and/or our own or industry standards, or to reflect changes in our business practices. If we revise the Privacy Policy, we will notify you by posting the updated Privacy Policy on the Website. Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy on the Website. Your continued use of our Website after any change has become effective will constitute your acceptance of any change. We encourage you to review this Privacy Policy each time you access or use the Website.

B. INFORMATION WE COLLECT

We typically collect the following kinds of information when you use our Website or otherwise interact with us through phone calls, payment channels, or other contact:

(1) Personal Data: Our definition of “Personal Data” includes any information that may be used to specifically identify or contact you, such as your name, address, phone number, financial information such as a debit or credit card number, or vehicle information such as year, make, model, and VIN. Personal Data also includes information that may be used to identify you indirectly, including by reference to an online identifier, geolocation data, or a device identification number.

In certain circumstances, we may request, allow, or otherwise provide you an opportunity to submit Personal Data in connection with a feature, program, promotion, or some other aspect of our services. For instance, you may: (a) provide your name, mail address, email address, financial information, and phone number when registering with our Website’s online payment portal; or (b) provide certain demographic information about yourself (e.g., age, gender, purchase preference, usage frequency) when using our Website. Certain information may not be Personal Data when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether you provide this information is your choice; in many instances, however, this type of information is required to realize a benefit we may offer or gain access to certain content or features available through our Website.

(2) Usage Data: Our definition of “Usage Data” is any information that does not personally identify you that is automatically collected anytime you visit the Website, including information such as browser type and referring websites. Usage Data can include certain Personal Data that has been de-identified; that is, information that has been rendered anonymous. We may collect Usage Data from you when you access our Website with your device. Usage Data may include, but is not limited to, information regarding your computer, your IP address, the type of Internet browser you are using (e.g., Internet Explorer, Firefox, Safari, Opera), the location from which you are visiting the Website, the type of computer operating system you are using to access the Website (e.g., Vista, Windows XP, Mac OS, Android, iPhone), the domain name of the third party website from which your visit originated, the search terms you use on our Website, or the areas of the Website you visited and the actions you performed on the Website.

C. HOW WE COLLECT INFORMATION

We may collect information about you from a variety of sources:

(1) Directly From You: We collect Personal Data when it is voluntarily provided by, for example, completing our Website form to contact us, set up a customer account, call customer service, or make a payment.

(2) Through Your Use of our Website: Our systems may record Usage Data as you use and navigate the Website. For example, our servers automatically record Usage Data that your browser transmits when you visit our Website. We also may automatically collect Usage Data about how you access and interact with the Website through the use of automated tracking technology.

(a) Cookies and Web Beacons: Cookies and web beacons allow us to automatically receive and store certain types of Usage Data whenever you interact with the Website. We may use cookies, which are small data files that are transferred to a web browser, which enables our Website to remember and customize your subsequent visit. We may also use third-party applications, which may use cookies, to gather and analyze information about your browsing activities on the Website.

Cookies and other user tracking mechanisms (e.g., local shared objects), by themselves, do not tell us your email address or other Personal Data unless you choose to provide this information to us by, for example, registering at the Website. However, once you choose to furnish us with Personal Data, this information may be linked to the data stored in the cookie or other tracking mechanisms. We may use cookies and other user tracking mechanisms, including “persistent cookies,” which will remain on your computer even after you close your browser, to understand Website usage and to improve the content and offerings on the Website. We may use cookies to personalize your experience at the Website and to save your password in password-protected areas. We also may use cookies to offer you products, programs, or services. While most browsers are set to accept cookies and other tracking devices by default, you can set yours to refuse tracking devices or to alert you before accepting them. However, by disabling tracking devices, you may not have access to the entire set of features on the Website. Please refer to your Internet browser’s instructions to learn more about these functions.

Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Website that allow us to gather information about your browsing activities on the Website. We may use web beacons to improve your experience with the Website, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that the Website can deliver relevant content. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

(b) Do Not Track Features: Certain web browsers and other devices you may use to access the Website may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Website does not respond to “Do Not Track” signals.

D. HOW WE USE AND DISCLOSE THE INFORMATION COLLECTED

As our business grows, we may seek to make available additional offerings and services including those that may not be related to vehicle payment plans, vehicle maintenance and repair programs, or home service contracts. In doing so, we will strive to give our users choices about whether or not you would like to continue to receive future promotional or marketing communications from us either directly or on behalf of others whose offerings we think may be of interest to you. In identifying which offerings we think may be of interest to you, we may use and analyze information you have provided to us, to an affiliate or information we have otherwise collected from unaffiliated companies and sources. If you choose not to receive such marketing communications, we reserve the right to send you certain non-promotional communications to fulfill pending or ongoing services requested by you (such as service announcements), email, and other communications related to the purchases you have made or information you have submitted, or similar administrative or transactional messages.

(1) Personal Data: The Personal Data you voluntarily submit to us is generally used to carry out your requests, respond to your inquiries, process payments, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of our affiliated and unaffiliated companies (subject to your communication preferences and opt-out rights), or to communicate with you about content or other information you have posted or shared with us via use of our Website. We share and/or sell your Personal Data with contracted other companies in order for them to offer our customers service contracts and maintenance and repair programs.

In certain instances, we may also share and/or sell your Personal Data with third parties performing functions on our behalf (or on behalf of our affiliated companies), accessing our Website (e.g., vendors that process credit card payments, provide us marketing or promotional assistance, analyze our data, or assist us with customer service).

(2) Usage Data: We use Usage Data in a variety of ways. For example, we may use Usage Data to evaluate use of our Website and all related sites and mobile applications we may provide, analyze site traffic, track purchases, understand customer needs and trends, carry out targeted promotional activities, and to improve our services. We may use Usage Data by itself or aggregate it with information we have obtained from others. We may, among other things, share Usage Data with our affiliated companies, allow third parties to collect such information directly from you, and/or sell the Usage Data to third parties to achieve these and any other business objectives (e.g., generate revenue, form alliances).

(3) General Uses and Disclosures: We use and share the information, including Personal Data, we collect from users for the purposes described below.

(a) Provision of Services to Website Users. If you use the Website, we will use your information to process and respond to your requests, comments, inquiries, and other forms you submit through the Website. For example, when you begin to provide Personal Data to us, you do so for the purpose of our sharing this information with third-party providers to provide you with the quotes you requested.

(b) Processing Payments. We use Personal Data, such as financial information to process any payments, including disclosure of Personal Data to third-party payment processors.

(c) Improving our Services. We use Personal Data and Usage Data to enhance our understanding of our users’ preferences and optimize the performance of the Website.

(d) Disclosures to Service Providers. We share Personal Data and Usage Data with third-party service providers that assist us with hosting, maintaining, and analyzing online activity on the Website, processing payment card information, marketing our services, and managing our daily business operations. We share only the minimum amount of Personal Data with these service providers that they need to perform their tasks. We also enter into contracts with these service providers that require them to protect Personal Data.

(e) Marketing. When you submit information to us, you agree to receive email, direct mail, and other forms of communications from us and those to whom you have authorized