1) Scope

This Privacy Policy explains how FRS Dealer Solutions, LLC ("FRS," "we," "us," or "our") collects, uses, discloses, and protects personal information when you visit or use our website, request a demo, contact us, submit a privacy request, create or use an account, or use our dealership workflow services. Those services may include title and registration support, temporary tag workflows, document collection and management, billing and invoicing, remote online notarization, identity verification, insurance verification, transportation coordination, and related support.

This Policy applies to information we process as a business or service provider under applicable privacy laws. Depending on the transaction, the information may relate to dealership personnel, customers, buyers, co-buyers, vehicle owners, signing participants, or other transaction participants. If another company or dealership gives you its own privacy notice for a particular transaction, that notice may also apply.

Children. The Services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13.

2) Notice at Collection

The table below summarizes the main categories of personal information we collect, why we collect it, how it is typically disclosed, how long we generally keep it, and whether we sell or share it for targeted advertising. We do not sell personal information or share it for cross-context behavioral advertising.

3) Sources of Personal Information

• Directly from you. For example, when you create an account, submit forms, upload documents, contact us, request support, request a demo, or submit a privacy request.
• From dealerships, employers, or transaction participants. For example, when a dealership or related business submits information needed to complete a workflow involving you.
• From service providers and integration partners. For example, identity verification, notarization, shipping, mapping, messaging, and analytics providers that support the Services.
• Automatically from your browser, device, and use of the Services. For example, through logs, cookies, scripts, and similar technologies.

4) How We Use Personal Information

• Provide, operate, and maintain the website, accounts, workflows, and related dealership services.
• Authenticate users, secure the platform, prevent fraud and abuse, and investigate incidents.
• Process title, registration, temporary tag, document, billing, identity verification, notarization, insurance, and shipping-related workflows.
• Communicate with you about transactions, support requests, privacy requests, demos, expo inquiries, account security, and service notices.
• Measure site usage, troubleshoot issues, improve performance, and enhance the user experience.
• Comply with laws, contracts, audits, lawful requests, recordkeeping obligations, and enforcement of our agreements.

We do not sell personal information, do not use personal information for cross-context behavioral advertising, and do not use or disclose sensitive personal information for purposes other than providing services, maintaining security, satisfying compliance obligations, or other purposes permitted by law.

5) Cookies, Analytics, and Similar Technologies

We use cookies, scripts, local storage, and similar technologies to operate the site and understand how it is used.

• Essential technologies. We use these for authentication, session management, security, and core site functionality.
• Analytics and experience tools. We currently use Google Analytics and Microsoft Clarity to understand site usage, performance, and user interaction patterns.
• Integrated third-party features. Certain workflows may also use technologies provided by mapping, verification, or other service vendors when you use those features.
• Your choices. You can manage cookies through your browser settings. Blocking cookies may affect sign-in and other site functions.

Our Services are not built for targeted advertising, and we do not currently change site behavior in response to browser "Do Not Track" signals.

6) When We Disclose Personal Information

We disclose personal information only as needed to operate the Services, complete requested workflows, comply with the law, or protect the platform and its users. Typical recipients include:

• Cloud, infrastructure, messaging, and security providers, including Microsoft Azure services, Microsoft Graph email services, Azure Communication Services, storage providers, and related technical support providers.
• Analytics and experience providers, including Google Analytics and Microsoft Clarity.
• Identity verification and notarization providers, including fraud-prevention or compliance providers.
• Mapping, logistics, and transaction partners, including Azure Maps, mapping and address-lookup providers, ACERTUS, and other shipping or transaction-service providers involved in the workflow you request.
• Dealerships, lenders, notaries, insurers, and other transaction parties when the transaction or business customer directs or requires that sharing.
• Government authorities, courts, regulators, auditors, and law enforcement when required by law or when reasonably necessary to protect rights, safety, and the integrity of the Services.
• Parties to a corporate transaction such as a merger, financing, sale, or acquisition, subject to appropriate confidentiality and legal safeguards.

We do not sell personal information, and we do not share it for cross-context behavioral advertising or targeted advertising.

7) Identity Verification, ID Documents, and Face Data

Some workflows require or support identity verification or notary-related checks. When these workflows are used, we may collect or receive government ID images and fields, selfie or face images, verification outcomes, anti-fraud signals, location data associated with the verification event, and related transaction or audit records.

We use this information only to complete the verification workflow, prevent fraud, protect users and the platform, document the transaction, and meet legal or contractual obligations. We do not sell, rent, lease, or use face or biometric-related information for advertising. When this information is handled by a verification vendor, that vendor's privacy terms and notices may also apply to its portion of the processing.

8) Retention

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, including to maintain the relevant account or transaction, comply with law, enforce agreements, resolve disputes, and protect the platform. Retention varies by data type, use case, and legal requirements. In general:

• Account and dealership-user data is typically kept for the life of the relationship and a reasonable security, audit, and business record period afterward.
• Demo, contact, expo lead, support, and privacy request records are typically kept for the inquiry lifecycle, follow-up period, and any related recordkeeping obligations.
• Transaction, invoicing, document, and compliance records are kept for the period needed to complete the transaction and satisfy accounting, legal, contractual, audit, and dispute-resolution obligations.
• Logs, security records, and analytics data are kept for the period reasonably needed to operate, secure, and improve the Services, or longer when needed to investigate incidents or resolve disputes.
• Identity verification and face or ID-related data is kept only for the verification, transaction, audit, security, legal, and compliance purposes associated with the workflow, after which it is deleted, de-identified, or otherwise handled according to applicable law and contractual obligations.
• We may de-identify or aggregate information and keep de-identified data where permitted by law.

9) Security

We use reasonable administrative, technical, and physical safeguards designed for the nature of the information we process. These measures include access controls, encrypted connections, logging, monitoring, and role-based restrictions where appropriate. No system is completely secure, and we cannot guarantee absolute security.

10) Your Privacy Rights and Choices

Depending on where you live and subject to verification and legal exceptions, you may have rights such as the following. We will not unlawfully discriminate against you for exercising applicable privacy rights.

• Access / know / confirm. Ask us to confirm whether we process your personal information and request access to the personal information or categories of information we hold about you.
• Correction. Ask us to correct inaccurate personal information.
• Deletion. Ask us to delete personal information, subject to legal and operational exceptions.
• Portability. Request a copy of certain personal information in a portable format where applicable.
• Appeal. If we deny your request, you may appeal that decision where required by applicable law.
• Marketing choices. You can opt out of non-transactional marketing communications by following the instructions in the message or contacting us.

If you have an account with us, you may also be able to access, download, or delete certain account-related information through in-product account management tools.

How to exercise your rights. For access, correction, and deletion requests, use our privacy request form. For other privacy requests, questions, or appeals, email privacy@frsdealersolutions.com. We may need to verify your identity and, when applicable, confirm an authorized agent's authority before fulfilling a request. We will respond within the time required by applicable law.

Because we do not sell personal information or use it for targeted advertising, we do not currently provide a separate sale/share or targeted advertising opt-out mechanism.

11) International Users

The Services are designed primarily for U.S.-based dealerships, transactions, and users. If you access the Services from outside the United States, you understand that your information may be transferred to, stored in, and processed in the United States and other countries where our service providers operate, which may have privacy laws different from those in your home jurisdiction.

12) Third-Party Links and Services

The Services may link to third-party websites or use third-party tools and integrations. Those third parties operate under their own terms and privacy policies, and this Policy does not govern their independent practices. We encourage you to review their privacy disclosures when using those services.

13) Changes to This Policy

We may update this Policy from time to time to reflect changes in our Services, vendors, legal requirements, or business practices. When we make material changes, we will post the updated version on this page and update the "Last updated" date. When required, we will provide additional notice.

14) Contact Us

Questions or requests about privacy can be sent to privacy@frsdealersolutions.com or submitted through our privacy request form.

FRS Dealer Solutions, LLC
Attn: Privacy
2785 Pacific Coast HWY STE E 717
Torrance, CA 90505