LOTWING PRIVACY POLICY (last updated December 10, 2019)

This website www.lotwing.com (referred to as “Website” in this policy) is owned by LotWing, LLC, a California limited liability company (referred to as “LotWing”, “we”, “our” or “us” in this policy). LotWing provides software services and products to vehicle dealerships to electronically manage and locate the vehicle inventory at their dealership facility and to update vehicle inventory location ("Services"). This privacy policy (“Privacy Policy”) explains how we, store, process and use your data when you visit this Website and/or use our mobile application ("App") or use our Services.

By using our Services, you (“you”, “your”, “user”) agree to the collection, storage and use of data in accordance with this Privacy Policy. We recommend that you read this Privacy Policy carefully when using our Website and App or Services or transacting with us. By accessing and using our Services through the Website and/or the App, you are accepting the practices described in this Privacy Policy. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

WHY WE NEED TO COLLECT AND PROCESS DATA

Our philosophy is to collect the minimum amount of data needed to provide our Services and restrict sharing that data with third parties unless necessary. We need to collect and process data, so that:

Users are able to register and create subscription accounts by paying the registration fee ("Subscription Account") to view and use our Services. To enhance existing features or develop new features, products and services. To send you e-mail notifications about our new or existing products and services, special offers, or to otherwise contact you. To allow us to personalize the content that you and others see based on personal characteristics or preferences. To detect, prevent and address technical issues. To provide user support. To enforce our Terms of Use (for example, when necessary to protect our intellectual property rights) and when the law requires us to do so.

WHAT DATA IS COLLECTED

Data Collected From You – Communication Data

We collect information you provide directly to us for the purpose of using our Services, when you contact us, or otherwise communicate with us.

Data Collected From You – Account Data

When a dealership creates an account with us, we require and collect the dealership name, address, phone number, email address and credit card number, expiration date and security code. For the dealership employee to use our Services we require and collect only such individual's user name, password and email address (“Information”). You provide this directly to us in the account creation process. We also collect when you contact our user support, email us, or otherwise communicate with us. We do not share, sell or transfer your information to third party users or partners except as mentioned in this Privacy Policy.

Log Data

Like many websites, data that your browser or computer automatically sends (“Log Data”) whenever you visit the Website or use the App is collected. This Log Data may include information such as.

Your computer's or devise Internet Protocol ("IP") address. Your browser type and version. The type of device you are using, its operating system version, and in some cases its unique identifier. The pages of Website that you visit, the time and date visited, and time spent on those pages. The external website that referred you to this Website, if any.

This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize Services to improve your overall experience. We may aggregate information from the user of the Website and/or App, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors and average time Website and/or App is used.

HOW IS DATA USED?

No data collected by the Website and/or App is sold to third parties.

Data is only shared with third parties in the following manner: With our payment partners to process payments (credit card information) when you register and subscribe to the Services through our Website. As required by law or ordered by a court, regulatory, or administrative agency. As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another's rights or property, including, without limitation, our rights or property. If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency. To enforce our Terms of Service, this Privacy Policy, and any other applicable agreements and policies. To enforce or protect our rights. As mentioned in this Privacy Policy.

Anonymized, aggregated statistics of users may be shared publicly for the purpose of marketing this website.

Communication Data

Any information or data you submit to us when you communicate with us is used to complete our communication, execute a requested action, and may be used to improve or update the Services.

Account Data

This data is used for account management, such as resetting your password.

Account Usage Data

Sign-up and login times are used for understanding the number of active users on the Website and/or App, to help optimize performance and content.

Log Data

Log Data is used by us for Website and App management and optimization. For example, fixing problems with the Website or App, ensuring the Website and App are compatible with different browsers, and understanding traffic patterns to optimize our Service delivery.

Service Providers

We may use third party service providers to help provide our Services, for example companies that provide the servers where we host this Website. Some of these service providers can access some of the Log Data, but only to perform specific tasks for the purpose of providing the Services.

HOW IS DATA STORED?

Data is stored in servers in the United States of America. LotWing uses HTTPS communication protocol via Transport Layer Security (TLS) encryption.

Any communication you have with us will be stored in the medium and technology that it is sent. For example, if you send an email to us, then that email will be stored in our email system.

Account Data

Passwords you enter are never stored directly. Instead, they are converted to a unique set of characters (called a "hash") that can be used in the future to verify the same password is entered, but cannot be used to determine the original password. The hash is additionally secured through encryption and other security processes such as using per entry salts and iteration counts.

Usernames and Email Addresses are stored encrypted and as encrypted hashes.

Account Usage Data

Login times and signup times are stored in plain text.

Log Data

Log data is stored as plain text logs.

Data Security

We strive to implement and maintain reasonable, industry-standard secure storage technologies and commercially acceptable security procedures and practices appropriate to the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. However, we cannot ensure or warrant 100% security of any information you provide to us or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed by unauthorized persons or hardware or software failure. Further, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the information we have collected from you.

Therefore, if you create an account and therefore provide information such as your username, password and email address, it is recommended you choose a username that is not linked to your identity, a password that is randomly generated and managed by a password management system, and an email address that is not linked to your identity and is secured with a robust password and two-factor authentication.

We will never send you an email asking for your password, or any personal information, and if you see any such thing then you should contact us at dietmar@lotwing.com.

Should you notice any flaws or concerns in our security, please contact us at dietmar@lotwing.com.

Marketing

LotWing will not send you marketing emails.

Cookies

Cookies are text files placed on your computer by most websites that are generally used to provide additional functionality to a website as well as collect standard Internet log information and visitor behavior information.

For further information about cookies generally, visit https://www.allaboutcookies.org

How do we Use Cookies?

This Website uses cookies to improve your experience on this Website. Cookies are used to:

Keep you logged in (if you have an account and are logged in). Show your username when logged in. Make navigation of the Website more convenient by remembering what content you have viewed recently.

How to Manage Cookies

You can set your browser not to accept cookies, and the website https://www.allaboutcookies.org tells you how to remove cookies from your browser. However, this Website’s features mentioned above will not be available if you do this.

Do Not Track

Some web browsers may give you the ability to enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. We currently do not respond to “do not track” signals.

How Long we Retain Your Information

All data is kept as long as needed to provide you Services or to comply with applicable law. This will normally be indefinitely, though sometimes older data will be deleted. If you delete your account, your account information (username, password and email address) will be deleted.

Business Transfers and Corporate Changes

We may share your Information with our subsequent owner, co-owner, or operator of one or more of the Services; or in connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets; financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

YOUR RIGHTS IN RELATION TO THE INFORMATION WE COLLECT

You have the right to access, correct, delete, restrict processing, and object to processing of your information. If you wish to (i) update, alter, delete or obtain a copy of your information that we hold; (ii) restrict or stop us from using any of the information which we hold on you, including by withdrawing any consent you have previously given to the processing of such information; or (iii) where any information has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such information in a suitable format, you can request this by emailing us at the address set out at the end of this Privacy Policy. We endeavor to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests.

Please note that, if you request that we restrict or stop using information we hold on you, or withdraw a consent you have previously given to the processing of such information, this may affect our ability to provide Services to you or negatively impact the services we can provide to you. We reserve the right to deny you access for any reason permitted under applicable laws. Such exemptions may include national security, corporate finance and confidential references.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy will remain in effect, except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website. This Privacy Policy was last updated on December 10, 2019.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, please do not hesitate to contact us at dietmar@lotwing.com.