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Privacy Policy

Effective Date: 09/30/2025

CarPot, Inc. (“Company,” “CarPot,” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy describes how CarPot, Inc. collects, uses, and discloses your information when you use our Platform (including our website, software offerings, mobile applications, and related services). This policy explains the types of information we may collect from you or that you may provide when you access or use https://www.carpot.com, our software offerings, mobile applications, and/or platforms that are accessible through or independent of our website (collectively, the “CarPot Platform”), as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. If you're a resident of California or Nevada or visiting us from the European Economic Area ("EEA"), you should read this policy and the applicable sections below for residents of California and Nevada and visitors from the UK and EEA. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. We use your personal data to provide and improve our platform, including our website, mobile applications, and related online services (collectively, the ‘CarPot Platform’). By using any part of the CarPot Platform, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see “Changes to Our Privacy Policy” below). Any changes to this Privacy Policy will be effective immediately on posting the updated Privacy Policy unless otherwise stated or as required by applicable law (for example, notice and opt-in or opt-out consent may be required). Your continued use of this Website after we make changes is deemed to be acceptance of those changes to the fullest extent permitted by applicable law, so please check the policy periodically for updates.

1. SCOPE OF CARPOT PRIVACY POLICY

This Privacy Policy applies to all aspects of our Platform, including our website, mobile applications, and any other online or offline services operated by CarPot. Our Platform may link to or incorporate websites, mobile applications, or content hosted and served by others over which we have no control, such as third-party websites, online properties, platforms, social media, or systems, each governed by the privacy policy and business practices of those third parties. You understand and agree that CarPot is not responsible for the security, privacy, or business practices of any such third party.

This policy applies to information we collect

  • On our Platform, including our website, mobile applications, and all associated CarPot software and web apps.
  • In email, text, and other electronic messages between you and the Platform.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
  • As provided by other users in connection with your use of the Platform and/or services provided thereto.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website or platform operated by the Company or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

2. YOUR INFORMATION

2.1 Information We Collect About You and How We Collect It. We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal/home address, e-mail address, telephone number, payment information, vehicle information, and EINs/SSNs (as applicable), and any other identifier by which you may be contacted online or offline, including IP addresses and cookie identifiers (collectively, “personal information”);
  • That is about you but individually does not identify you, such as -- geo location, operating system, browser preferences, input devices, vehicle access methods (e.g., garage codes); and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.
  • For the avoidance of doubt, CarPot does not collect or store Social Security Numbers (SSNs). Such information is collected and securely maintained solely by Stripe in accordance with its own policies.

2.2 Information you provide. The information we collect on or through our Platform may include:

  • Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use or creating an account on our Platform, purchasing our products, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Platform.
  • Details of transactions you carry out through our Platform and of the fulfillment of your orders, in which event you may be required to provide financial information before placing an order through our Platform.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Any other information, content or documents you upload to the Platform.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we take measures to ensure the security of our Platform and any information we collect, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. By posting User Contributions, you acknowledge and agree that you are solely responsible for the content you post, and that we do not control the actions of other users with whom you may choose to share such information. We cannot and do not guarantee that unauthorized persons will not view your User Contributions.

You are responsible for ensuring that all information you provide to us is accurate, complete, and up to date. We are not responsible for any losses arising from inaccurate, incomplete, or outdated information provided by you.

2.3 Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
  • Information about your computer, device, mobile connection and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on this Platform and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our Platform usage statistics and usage patterns.
  • Store information about your preferences, allowing us to customize our Platform according to your individual interests.
  • Improve the services we provide to our users.
  • Recognize you when you return to our Platform.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
  • Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.
  • Web Beacons. Pages of the Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Platform statistics (for example, recording the popularity of certain content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

2.4 Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Platform are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

3. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Platform and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Platform or any products or services we offer or provide though it.
  • To use data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
  • To contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may 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.
  • To contact you with respect to items, products or services that are germane to the products and services that the Company might provide you.
  • To allow you to participate in interactive features on our Platform.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • We may use de-identified or aggregated data to develop, train, and enhance machine learning models or artificial intelligence systems for improving the accuracy, efficiency, and personalization of our platform. Such data will not include personally identifiable information and will be processed in accordance with this Privacy Policy.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at privacy@carpot.com. For more information, see “Choices About How We Use and Disclose Your Information” below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. We are not selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information and data to any persons or entities. For the avoidance of doubt, we may sell, rent, release, disclose, make available, transfer, or license certain aggregated, non-identifiable, non-personal information to third parties.

By providing personal information to CarPot, you expressly consent to the collection, use, processing, and disclosure of your information in accordance with this Privacy Policy. You may withdraw your consent at any time by contacting us as described in Section 10; however, please note that withdrawal of consent will not affect our right to process your information based on lawful grounds other than consent, and may limit your ability to access certain features of the Platform.

4. RETENTION AND TRANSFER OF INFORMATION

4.1 Retention of Your Personal Information and Data

The Company will retain your personal information and data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal information and data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain your usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our platform, or we are legally obligated to retain this data for longer time periods. We maintain internal data retention schedules specifying the retention periods applicable to different categories of personal information. When personal information is no longer required for the purposes set out in this Privacy Policy, or for compliance with applicable laws, we will securely delete or anonymize it in accordance with our data retention procedures.

4.2 Transfer of your Personal Data

Your personal information and data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that your personal information and data is treated securely and in accordance with this privacy policy and no transfer of your personal information and data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

4.3 International Users

By using the Platform, users understand and agree that the Company will transfer data to the United States and other global jurisdictions. By choosing to visit the Platform, utilize the services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Delaware, United States and the adjudication of any disputes arising in connection with the Company or the Platform will be in accordance with the Terms & Conditions which can be found at https://www.carpot.com/terms. Notwithstanding the foregoing, if you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to processing of your data globally. By providing your personal information, you consent to any transfer and processing in accordance with this Privacy Policy. The General Data Protection Act (GDPR) provides protections and outlines specific requirements for companies with respect to the processing of Personal Data from the European Union. The Company may develop and implement appropriate policies, processes and controls to achieve GDPR compliance. The Company may also offer European Union Model Clauses, sometimes referred to as the Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the European Union. If you are an enterprise customer and would like to request a copy of our standard data processing addendum, incorporating the model clauses, please email us at: privacy@carpot.com. We collect and process personal information where necessary for the performance of a contract with you, to comply with our legal obligations, to protect our legitimate business interests (such as maintaining and improving our Platform, preventing fraud, and securing our systems), or pursuant to your consent where required. We will not process personal information for purposes incompatible with these lawful bases without providing you notice and, where required, obtaining your consent.

5. SECURITY OF YOUR PERSONAL DATA

The security of your personal information and data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information and data, we cannot guarantee its absolute security. Any natural or legal person who processes the data on behalf of the Company may have access to your personal information or data. CarPot uses third-party cloud infrastructure providers with data centers located in the United States. These third-party vendors collect, store, use, process and transfer information about your activity on our platform in accordance with their privacy policies.In the event of a data breach affecting personal information as defined under Massachusetts law, CarPot will comply with all applicable notification requirements under Massachusetts General Laws Chapter 93H. We will promptly notify affected individuals and, where required, the Massachusetts Attorney General’s Office and the Office of Consumer Affairs and Business Regulation.

6. DISCLOSURE OF YOUR INFORMATION

6.1 Information We May Disclose. Some content or applications, including advertisements, on the Platform may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who may be bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Platform users is among the assets transferred.
  • To third parties to market their products or services to you. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • To law enforcement agencies, regulatory authorities, or other governmental bodies when required by applicable law, court order, subpoena, or other legal process, or when we believe in good faith that disclosure is necessary to comply with legal obligations, investigate potential violations, prevent fraud, protect the rights, property, or safety of CarPot, our users, or the public.
  • To insurance providers, brokers, or claims administrators for purposes related to verifying coverage, processing or facilitating insurance claims, assessing liability, preventing fraud, or coordinating services connected to accidents, damage, or other vehicle-related incidents, provided such third parties are bound by confidentiality and data protection obligations consistent with this Privacy Policy.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use which can be found at https://www.carpot.com/terms and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6.2 Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can by sending us an email with your request to privacy@carpot.com.
  • Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@carpot.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website. California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@carpot.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

7. STATE PRIVACY RIGHTS

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indian, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virigina, you may have certain rights in relation to the personal information we collect from you. However, these rights are not absolute, and we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data;
  • Right to access your personal data;
  • Right to correct inaccuracies in your personal data;
  • Right to request the deletion of your personal data;
  • Right to obtain a copy of the personal data you previously shared with us;
  • Right to non-discrimination for exercising your rights; and
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Depending on the state you live in, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota);
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland);
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon);
  • Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota);
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California); and
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida).

To exercise these rights, please contact us at: privacy@carpot.com. If you are a California resident, you have the right to request that the Company discloses the specific personal information and categories we have collected about you. To request this information, please contact us at: privacy@carpot.com. You can also request to have your personal information deleted that has been collected about you. To submit a deletion request, please contact us at: privacy@carpot.com.

8. DATA SECURITY

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

9. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Platform home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Platform home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

10. CHILDREN’S PRIVACY

Our Platform and services are not directed toward children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn that we have inadvertently collected personal information from a child under 13 without verifiable parental consent, we will delete that information from our records as soon as practicable. If you believe we may have collected personal information from a child under 13, please contact us using the information provided in Section 10 of this Privacy Policy.

11. CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@carpot.com.