Privacy Policy

1. Scope

This Privacy Policy ("Privacy Policy") applies to the tools, features, and services (collectively,

the "Services") offered by DriveSimple, Inc., or its subsidiaries, including Legend Auto Sales, LLC

(together, "DriveSimple", "we", "us", or "our"), through any DriveSimple website,

including idrivesimple.com and legendsalesauto.com (together, "Sites") or DriveSimple mobile

applications ("Apps"), as well as offline interactions with you related to your sale, trade,

purchase or financing of a vehicle through DriveSimple.

By using or accessing the Services in any manner, you acknowledge that you accept the

practices and policies outlined below, and you hereby consent to our collection, use and

sharing of your information as described in this Privacy Policy. Also, your use of DriveSimple

Services is subject at all times to our Terms of Use, which incorporates the Privacy Policy. Unless

otherwise stated, any terms we use in this Policy without defining them have the definitions

given to them in the Terms of Use.

2. Types of Information Collected or Received

When you use the Services, DriveSimple and our third-party service providers may collect

information about you and the device(s) you use to access the Services. We collect a variety of

information, such as:

Account Information and Other Information You Provide Voluntarily. You may

create an account through the Services and, if you do so, we will collect your

name, email address, login information and telephone number. We also may

collect your address for vehicle registration, pickup or delivery, as well as certain

documents required for financing or to complete registration, where applicable.

Further, we collect any additional information that you voluntarily provide to us

directly or through the Services, such as when you communicate with us in

person or by email, text message, telephone or chat, ask us a question, respond

to our surveys, post comments, or provide reviews or testimonials.

Vehicle Information. If you are interested in selling or trading in your vehicle to

DriveSimple, you may obtain a vehicle appraisal from us through the Services. In

order to provide an appraisal, we request and collect your Vehicle Identification

Number ("VIN"), vehicle history, and information about the condition of your

vehicle. We also will request your name and contact information to contact you

about the appraisal.

Financial Application Information. When you submit an application to third-

party lenders through the Services to finance a vehicle purchase from

DriveSimple, or for a pre-qualification for financing, we collect information such

as your name, email address, telephone number, date of birth, address,

employment and income information, veteran or military status, and social

security number. Depending on the lender's requirements, we may need to

collect additional information from you.

Credit Report Information. When you submit an application for pre-

qualification or financing, we use a third-party service provider to request credit

report information from consumer reporting agencies to determine your

eligibility for financing. This information may include your credit or FICO score

and other information in your credit file.

Payment or Other Financial Information. When you make a purchase or sell us

a vehicle through the Services, we may collect your credit card information or

bank account information, such as the name and contact information of your

financial institution, account type, account number, and routing number. Your

credit card information is processed and stored by a third-party service

provider.

Commercial Information. When you use the Services, we collect information

about the transactions you conduct with us, such as vehicle purchases and

appraisals, and about the vehicles that you have searched for or otherwise

expressed or indicated an interest in.

Location Information. With your consent, our Apps may collect geo-location

information from your device in order to tailor our Services to you, for example,

showing you vehicles closer to your location. You may opt out of location

sharing by accessing the location settings on your device and setting your device

not to share its location with us.

Information Provided by Third Parties. When you view and make inquiries

about DriveSimple vehicle listings posted on sites other than the DriveSimple

Sites, we will receive the information you submit in connection with your

inquiry, such as your name, email address or phone number. We also may

receive information about you from other third parties, including, without

limitation, social media platforms, marketing vendors, data analytics companies

or data brokers, vehicle history services, government agencies, including

Departments of Motor Vehicles, reputation and identity verification services,

and insurance companies.

Information Collected Automatically. When you use the Services, we or our

third-party service providers may automatically receive and record certain

information from your device or through the Services. For example, this may

include your device's IP address, user-agent, web pages you visit or features you

use within the Services, the date and time of your activities on the Services,

time since your last visit, links you click, searches conducted, the website visited

before navigating to the Services, your software and hardware attributes

(including browser and operating system type and version, app version, device

type, and device identifiers), demographic and interest data based on browsing

activity, and your general location inferred from your IP address. To obtain such

information, we or our third-party service providers may use the following

technologies to recognize your device and collect information about your device

and Services usage:

o Server Logs: When you use the Services, we automatically receive and

record certain information from your computer or other device and

your browser. To obtain such information, we may use the server logs

or applications that recognize your device and gather information about

its online activity.

o Cookies: Cookies are small files that are stored on your device by your

web browser. The cookies we may use include session cookies (which

expire once you close the browser) and/or persistent cookies (which

stay on your browser and may be used by the browser on subsequent

visits to the Services, unless deleted by you). Cookies allow us to

recognize whether you have visited before and may store user

preferences and other information. If you are concerned about having

cookies on your device, you can set your browser to refuse all cookies or

to indicate when a cookie is being set, allowing you to decide whether

to accept it. You can also delete cookies from your device. However, if

you choose to block or delete cookies, certain features of the Services

may not operate correctly.

o Web beacons, tags, and similar technologies: The Services or the

emails that you receive from us may use an application known as a

"web beacon" (also known as a "tag" or "pixel") and similar

technologies. Web beacons are small strings of code that provide a

method for delivering a graphic image on a web page or in an email

message for the purpose of transferring data. For example, it may allow

an email sender to determine whether a user has opened a particular

email.

o Unique Identifiers: We may use unique identifiers to collect information

about your use of the Services on an individual basis, such as length of

time spent on a particular page and pages viewed during a particular

log-in period. We use this information to evaluate and improve the

Services. These may include, for instance, a unique identifier associated

with a cookie stored on your browser. It may also include a mobile

advertising identifier associated with your mobile device, such as

Apple's Identifier for Advertisers ("IDFA") and Google's Advertising ID.

We may use mobile advertising identifiers to collect information for

interest-based advertising and analytics purposes, as described in the

section below titled "Analytics and Interest-Based Advertising."

o Local Storage: We use Local Storage Objects ("LSOs") such as HTML5 to

store content information and preferences. Your browser may offer its

own management tool to manage LSOs.

Feedback and Surveys. From time to time we may ask you to complete surveys

or provide feedback to help us improve our Services. If you choose to

participate in one of our surveys or provide feedback, we collect the information

you provide as part of that survey. Participation is completely voluntary, and

you therefore have a choice whether to disclose your information.

Resume or Job Application Information. If you submit an application for

employment with DriveSimple, we will collect your resume and any other

information you provide to be considered for a position. In order to submit an

application, we may direct you to a third-party service provider through which

you will submit your materials.

The specific information actually collected by DriveSimple and its third-party service providers

will depend on the portion of the Services you access.

3. DriveSimple's Use of Information

We and our third-party service providers use the information collected for a variety of purposes.

For example, to:

Provide the Services. To provide our Services to you, carry out the

transaction(s) you request, conduct credit checks to determine whether you

qualify for financing, fulfill and enforce the terms of any agreement you have

with us, process payments, respond to your requests or inquiries, conduct

internal recordkeeping, and secure your information and our Services to you.

Communicate with you. To communicate with you regarding the Services, your

purchase or sale of a vehicle, your application for financing, your purchase of

warranties or other ancillary products, and to respond to your questions or

requests concering the Sites, Apps or the Services offered by us.

Consider you for employment with us. To consider your application for

employment with us.

Send marketing materials or other promotional messages. To send you

marketing materials or other promotional messages via mail, email, text, push

notifications or other methods regarding our Services or other products or

services offered by our Business Partners that may be of interest to you.

Tailor our content and advertisements. To Tailor content on the Sites and Apps

and target our advertising, including as described in the section below titled

"Analytics and Interest-Based Advertising."

Conduct analytics and improve our Services. To count and recognize users of

the Services, analyze how the Services are used, improve the Services, create

new products and services, and conduct analytics, including as described in the

section below titled "Analytics and Interest-Based Advertising."

Compile aggregated and de-identified information. To compile aggregated and

de-identified statistics or reports that we may share with our Business Partners

or other third parties.

Protect DriveSimple, You, or Others. To protect, investigate, and deter against

fraudulent, harmful, unauthorized or illegal activity, or otherwise as we believe

to be necessary to protect the rights, property, or safety of DriveSimple, our

employees and contractors, you or the general public.

Legal purposes. For legal or other necessary purposes, including as decribed

below in the section titled "DriveSimple's Sharing of Information with Third

Parties."

Lawful business purposes. Where permitted by law, for other purposes related

to managing our business.

4. DriveSimple's Sharing of Information with Third Parties

We may share the information we collect or receive about you with third parties for a variety of

reasons, including as follows:

Affiliates. We may share your information with our corporate affiliates for the

purposes described in this Policy.

Service Providers. DriveSimple may share your information with third-party

service providers who perform services on our behalf, such as:

o Vehicle inspectors

o Vehicle history providers

o Vehicle listing and advertising platforms

o Reconditioning service providers

o Suppliers

o Sales management database providers

o Customer contact center and phone support providers

o Payment processors

o Credit check providers

o Lenders

o Financing services companies

o Shipping providers

o Email and other marketing and promotion vendors

o Customer data aggregator platforms

o Media and marketing agencies

o Web hosting services

o Operating systems and platforms

o Data analytics and advertising providers

o Survey providers

Government Agencies. We may share your information with government

agencies, including Departments of Motor Vehicles, in order to complete your

transaction(s).

Business Partners. We may share information about you with vendors, lenders,

financial services companies, vehicle listing and advertising platforms, and other

third parties with which we have a commercial relationship ("Business

Partners") to fulfill your request for Services; to meet the terms of any

agreement that you may have with us or our Business Partners; to share

promotions with you; for Business Partners to contact you directly about their

products and services; for benchmarking and data analytics by DriveSimple or

our Business Partners; or to manage our business. In particular, we share your

credit application details with certain Business Partners in connection with your

request for financing.

Third-Party Plugins. The Services integrate certain third-party plugins. Even if

you do not click on these plugins, they may collect information about you, such

as your IP address and the pages that you view. They also may set and/or access

a cookie. These plugins are governed by the privacy policy of the company

providing them.

Other Users or the Public. Your reviews and testimonials may be publicly

viewable or viewable by anyone who uses the Services. Therefore, if you upload

or share any information as part of a review or testimonial, unless otherwise

expressly stated by DriveSimple, such information may become publicly

available. This means that the information may be collected, used, or

redistributed by others, so please proceed with caution before providing any

sensitive or confidential information as part of a review or testimonial.

Customized Audiences and Similar Programs. We may partner with Facebook,

Google and other social media and social marketing partners to deliver

advertisements to our users via the Facebook Custom Audiences program,

Google Customer Match or similar third-party programs. In order to identify and

reach our users on Facebook, Google or another third-party service, we may

share your information with Facebook, Google or another third-party service.

For more information about custom audience targeting and how to adjust your

social media advertising preferences, please review the privacy policy of your

social media or social marketing providers.

Legal Purposes. We also may use or share your information with third parties

when we believe, in our sole discretion, that doing so is necessary:

o To comply with applicable law or a court order, subpoena, or other legal

process;

o To investigate, prevent, or take action regarding illegal activities,

suspected fraud, violations of our terms and conditions, or situation

involving threats to our property or the property or physical safety of

any person or third party; or

o To establish, protect, or exercise our legal rights or defend against legal

claims.

Organizational Transfers. In the event of a merger, sale of assets, sale of equity,

investment, reorganization, bankruptcy, consolidation, or similar transaction,

we may share information we possess to facilitate the transaction, including

during due diligence, or as a corporate asset transferred to the acquiring entity.

You acknowledge that such sharing and transfers may occur, and that any

acquirer of us or our assets may continue to use your information as set forth in

this Policy.

Aggregated and De-Identified Information. From time to time, DriveSimple may

also share aggregated or de-identified information about users, such as by

publishing reports on trends in the usage of the Services.

5. Analytics and Interest-Based Advertising

We partner with certain third parties to collect information to engage in analytics, auditing,

research and reporting. These third parties may use server logs, web beacons, tags, pixels,

mobile advertising IDs (such as Apple's IDFA or Google's Advertising ID), and similar

technologies, and they may set and access cookies on your computer or other device. In

particular, our Services use Google Analytics to help collect and analyze certain information for

the purposes discussed above. You may learn more about Google Analytics' data practices by

clicking here and opt out of the use of cookies in web browsers by Google Analytics by

clicking here.

We may also use analytics providers that engage in heat mapping and that record mouse

movements, clicks, scrolls, and keystrokes during your use of the Services. These analytics help

us identify and address technical issues and understand usage of our Services, which we use to

improve the Services for you.

We also partner with third parties to provide targeted advertising services that are customized

based on your online activities over time and across unaffiliated websites, mobile apps and

devices (commonly referred to as "interest-based advertising"). Our advertising partners may

collect information about your activities on our Services on your current device and combine it

with information about your activities on other websites, mobile apps, and devices. They may

collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising

IDs (such as Apple's IDFA or Google's Advertising ID), cross-device linking, and similar

technologies. For example, our advertising partners may use the fact that you visited our Sites to

target advertising to you on non-DriveSimple websites and mobile apps on your current device

or on other devices you use. For information about interest-based advertising practices,

including privacy and confidentiality, visit the Network Advertising Initiative website or

the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties' own

privacy policies, and not this Policy. You can opt out of interest-based advertising in web

browsers and mobile apps on your current browser or device by following the instructions

below.

Web Browser Opt-Out. To opt out in web browsers, please visit

optout.aboutads.info and optout.networkadvertising.org. To help preserve your

choices, you can install the "Protect My Choices" extension that is available at

http://www.aboutads.info/PMC.

Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the

advertising preferences on your mobile device. For example:

o In iOS 7+, visit Settings > Privacy > Advertising > Limit Ad Tracking.

o In Android, visit Settings > Google > Ads > Opt out of interest-based ads

or Opt out of Personalized Advertising.

You can also opt out for participating companies by downloading the Digital Advertising

Alliance's AppChoices tool.

Please note that the opt-outs described above will apply only to the specific browser or device

from which you opt out, and therefore you will need to opt out separately on all of your

browsers and devices. If you delete or reset your cookies or mobile advertising identifiers,

change browsers (including upgrading certain browsers), or use a different device, any opt-out

cookie or tool may no longer work and you will need to opt out again. If you choose to opt out,

you will still see advertisements while browsing online, however the advertisements may be less

relevant to you and your interests. Although our Services currently do not respond to "do not

track" browser headers, you can limit tracking by these third parties and by taking the steps

discussed above.

6. Ways to Limit our Information Collection and/or Use

If you want to limit our collection and/or use of your information, you have several choices,

including:

Limiting Information provided to DriveSimple:

You can always opt not to disclose certain information to us; however, if you choose not to

provide us with certain information, you may not be able to access certain features or services.

Terminating your Account(s):

You may be able to limit our collection and use of some of your information by terminating your

Account(s) on the Services.

Your choices for Advertising:

You can opt-out of the collection of information by certain third parties as described in the

section above titled "Analytics and Interest-Based Advertising." Most browsers will allow you to

erase cookies from your computer's hard drive or from your device, block acceptance of cookies

or receive a warning before a cookie is stored. You may also be able to erase or disable other

tracking technologies using the settings of your browser or mobile device. However, please note

that if you block or erase tracking technologies then our Services (and your experience) may be

limited.

You may opt-out of receiving emails from us by clicking "unsubscribe" at the bottom of the

message. Please note that if you unsubscribe from our marketing communications, you will still

receive administrative messages.

7. Accessing or Modifying Your Information

If you are registered for an Account, you can access and modify certain information associated

with your Account by logging into the Sites. If you want to learn more about the information

that DriveSimple has about you, you may do so by contacting us at privacy@idrivesimple.com.

If for any reason you wish to close your Account or delete your information, you can

email privacy@idrivesimple.com and we will make reasonable efforts to submit to your request,

subject to applicable laws, rules, regulation or court order. Please note that unless you instruct

us otherwise, or as set forth in this Privacy Policy, we may retain and use information collected

from you after termination of your Account, for as long as reasonably required, for the purposes

of which such information was collected, including, without limitation, in order to comply with

our legal or business requirements or obligations, to resolve disputes, to enforce our Terms or

Privacy Policy, all as permitted under any applicable privacy laws. Aggregate and/or anonymous

information derived from your Account and/or use of the Services may remain on our servers

indefinitely.

8. Third-Party Links

The Services may contain links to third-party websites. If you follow a link to any of these

websites, please note that these websites, and any services that may be accessible through

them, have their own privacy policies. We are not responsible for the privacy practices of other

websites. We encourage our users to be aware when they leave the Services and to read the

privacy policies applicable to such third-party websites. This Privacy Policy applies solely to

information collected in connection with the Services.

9. Data Security

We take reasonable physical, managerial and technical measures to maintain the security and

integrity of your information and the Services and prevent unauthorized access, use,

modification, or deletion. However, no security program is 100% secure, and thus, we cannot

guarantee the absolute security of your information.

10. California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") provides you with

the right to request that DriveSimple disclose certain information to you about its collection,

use, disclosure and sale of your personal information over the past 12 months, and the right to

request that DriveSimple delete any of your personal information that DriveSimple has collected

from you, subject to certain exceptions. To exercise these access and deletion requests, please

submit a verifiable consumer request by emailing us at privacy@idrivesimple.com or sending

your request to DriveSimple, P.O. Box 903, Olive Branch, MS 38654. Requests must: (a) include

your name, email address, street address, city, state and zip code in order for DriveSimple to

verify your request; and (b) describe your request in sufficient detail to allow us to understand,

evaluate and respond to it. DriveSimple is only required to respond to two such requests per

customer each year.

In the past 12 months, we may have shared the following categories of personal information,

which are further described in section 2 of this Privacy Policy, of California residents for business

and operational purposes, including to process transactions and for the other purposes set forth

in sections 3 and 4:

Identifiers;

Commercial information;

Online activities;

Telephone number;

Date of birth;

Demographics;

Geo-location data;

Records of your interactions with us;

Credit report information; and

Financial information.

Section 4 of this Policy further describes the ways in which we may share your information with

third parties, including our Business Partners, such as identifiers, commercial information, and

information about your use of the Services. Some of this sharing may be considered a "sale"

under the CCPA. California residents have the right to opt out of the sale of their personal

information. To do so, please email us at privacy@idrivesimple.com or send your request to

DriveSimple P.O. Box 903 Olive Branch, MS 38654. DriveSimple does not sell the personal

information of minors less than 17 years of age without affirmative authorization.

You may designate an authorized agent to make a request under this section on your behalf. To

do so, please submit a written form signed by you and your authorized agent that authorizes

your agent to act on your behalf, such as a power of attorney.

DriveSimple will not discriminate against you for exercising your rights under the CCPA.

11. Information for Individuals Outside the United States

The Services are directed to users in the United States. We currently only buy and sell vehicles in

the United States. The information that we collect through or in connection with the Services is

transferred to and processed in the United States for the purposes described above.

DriveSimple also may subcontract the processing of your data to, or otherwise share your data

with, affiliates or third parties in the United States or countries other than your country of

residence. The data-protection laws in these countries may be different from, and less stringent

than, those in your country of residence. By using the Services or by providing any information

to us, you expressly consent to such transfer and processing.

12. Children's Policy

The services are not intended or directed to individuals under the age of 17. We request that

such individuals do not provide information to us through any of the Services. Please email us

at privacy@idrivesimple.com if you have reason to suspect that we collected personal

information from a child under the age of 17.

13. Changes to the Privacy Policy

DriveSimple reserves the right to make changes to its Privacy Policy at any time and for any

reason, so please revisit this page frequently. If DriveSimple makes a material change to its

Privacy Policy, then DriveSimple will notify you either by email or by posting a notice on the

Sites. If DriveSimple, in its reasonable discretion, believes that any part of this Privacy Policy

must be amended in order to comply with any legal requirements, the amendments may take

effect immediately or as required by law and without any prior notice. All changes are effective

as of the date indicated at the top of this page, and your continued use of the Services after the

indicated date will constitute acceptance to be bound by those changes.