Privacy Policy

Effective Date: November 15, 2025 Last Updated: November 15, 2025

Supreme Dealer LLC ("Supreme Dealer," "we," "us," or "our"), a New Mexico limited liability company with its registered address at 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, respects your privacy and is committed to protecting your personal information. This Privacy Policy ("Policy") describes how we collect, use, disclose, and safeguard personal information when you, as an authorized representative of a dealership business, register for, access, or use our Platform, websites, and related services (collectively, the "Services").

This Policy is incorporated by reference into the Supreme Dealer Terms of Service. Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms of Service.

PLEASE READ THIS POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE PRACTICES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE, YOU MUST NOT ACCESS OR USE THE SERVICES.

1. Scope of This Policy

1.1 Who This Policy Covers

This Policy applies to personal information we collect from or about dealership users and their authorized representatives in connection with the Services. The Services are offered exclusively to dealership businesses operating in the United States and Canada and are intended solely for business-to-business use. The Services are not directed to, intended for, or designed for use by individual consumers.

1.2 Geographic Scope

Supreme Dealer provides the Services only to dealership businesses located in the United States and Canada. The Services are not intended for, and are not offered to, users located in the European Union, the United Kingdom, the European Economic Area, or any other jurisdiction outside the United States and Canada. If you are located outside the United States or Canada, you must not access or use the Services.

1.3 Children's Privacy

The Services are strictly business-to-business and are not directed to, intended for, or designed for use by anyone under the age of eighteen (18). We do not knowingly collect personal information from individuals under eighteen. If we become aware that we have collected personal information from anyone under eighteen, we will delete it promptly. If you believe we may have collected such information, please contact us at Legal@supremedealer.com.

1.4 Third-Party Practices

This Policy applies only to personal information collected by Supreme Dealer. It does not apply to information collected by any third-party website, application, integration, or service, even where the Services link to or interact with such third parties. Your interactions with third-party services are governed by their own privacy policies, which we encourage you to review.

2. Information We Collect

We collect personal information directly from you, automatically through your use of the Services, and from limited third-party sources, as described below.

2.1 Information You Provide to Us

When you register for, access, or use the Services, we collect personal information you submit to us, including:

• Account and Registration Information: your name, business email address, business phone number, dealership business name, business address, job title or role, and authorized contact persons.
• Billing and Payment Information: billing name, billing address, and payment card information, which is collected and processed directly by our third-party payment processor, Stripe, Inc. Supreme Dealer does not store full payment card numbers on its servers.
• Communications: any information you provide when you contact us by email, support ticket, chat, phone, or other means, including the content of those communications and any attachments.
• Marketing Preferences: your subscription status for newsletters, product updates, and promotional communications.
• Feedback: comments, suggestions, survey responses, testimonials, and other feedback you provide regarding the Services.

2.2 Information Collected Automatically

When you access or use the Services, we automatically collect certain information about your device and usage, including:

• Device and Connection Information: IP address, browser type and version, operating system, device type, device identifiers, time zone, and language settings.
• Usage Information: pages and features accessed, time and duration of access, referring and exit URLs, clicks, navigation paths, and other interactions with the Services.
• Log Data: server logs containing access timestamps, error reports, and similar diagnostic information.
• Cookies and Similar Technologies: as further described in Section 5 of this Policy.

2.3 Information We Generate Through the Services

In the ordinary course of providing the Services, we generate or process certain information associated with your account, including:

• AI Interaction Recordings and Transcripts: audio recordings of inbound telephone calls handled by our AI Voicebot, together with the resulting text transcripts, as well as text transcripts of conversations conducted through our AI Chatbot and similar AI Tools. Recordings and transcripts are made available to the dealership account holder so that the dealership may review interactions with its leads and customers.
• Analytics and Performance Data: aggregated metrics about your use of the Services, including campaign performance, lead activity, and inventory engagement.

2.4 Information from Third Parties

We may receive limited information about you from third-party sources, including:

• Our payment processor, Stripe, regarding the status of payments and transactions;
• Third-party integrations and platforms that you authorize to connect to your account (such as social media networks, advertising platforms, and marketplace services), in accordance with the permissions you grant; and
• Publicly available business directories and verification services we use to confirm your dealership business standing.

2.5 Sensitive Personal Information

We do not knowingly collect Social Security Numbers, government-issued identification numbers, financial account credentials, credit scores, biometric data, precise geolocation, health information, or other sensitive categories of personal information from dealership users. You should not submit such information to the Services.

3. How We Use Information

We use personal information for the following business purposes:

3.1 To Provide and Operate the Services

• Create, maintain, and secure your account;
• Authenticate users and prevent unauthorized access;
• Deliver, operate, configure, and personalize the features and functionality of the Services;
• Process transactions, send billing notices and receipts, and manage subscriptions; and
• Provide customer support, respond to inquiries, and troubleshoot issues.

3.2 To Train and Customize Our AI Tools

Consistent with our Terms of Service, we ingest, process, and use Dealership Data (including inventory data, product information, pricing, and dealership information) to train, fine-tune, configure, and customize the AI Tools for your account, in order to generate accurate and personalized AI Output for your leads and customers. We do not use customer Personal Information that flows through the Services for the purpose of training general-purpose AI models that operate outside your account.

3.3 To Communicate With You

• Send administrative messages, such as account confirmations, security alerts, technical notices, billing notices, and updates to our policies;
• Respond to your requests, comments, and questions;
• Send newsletters, product announcements, promotional offers, and marketing communications regarding Supreme Dealer products and services (you may opt out at any time as described in Section 7); and
• Invite you to participate in surveys, beta programs, and customer research.

3.4 To Improve and Develop the Services

• Monitor and analyze trends, usage patterns, and engagement to improve and optimize the Services;
• Develop new features, products, and services;
• Conduct internal testing, quality assurance, and security testing;
• Generate aggregated, de-identified, or anonymized data for analytics, benchmarking, research, and product development (such aggregated or de-identified data will not identify you and may be retained and used by Supreme Dealer without restriction).

3.5 To Protect Our Rights and Comply With Law

• Detect, investigate, prevent, and respond to fraud, security breaches, abuse, and violations of our Terms of Service or Acceptable Use Policy;
• Enforce our Terms of Service and other agreements;
• Comply with applicable laws, regulations, court orders, subpoenas, and other legal processes;
• Cooperate with law enforcement and regulatory authorities as required by law; and
• Establish, exercise, or defend legal claims and protect the rights, property, or safety of Supreme Dealer, our users, or others.

3.6 Voice Recordings

Audio recordings of inbound calls answered by the AI Voicebot are stored to enable the following purposes:

• Allowing the dealership account holder to review, listen to, and reference its interactions with leads and customers;
• Generating, validating, and improving text transcripts of those calls;
• Providing customer support, resolving disputes, and investigating quality or compliance issues; and
• Improving the accuracy, performance, and security of the AI Voicebot, in accordance with Section 3.2.

Important: The AI Voicebot answers inbound calls placed by leads and customers to telephone numbers operated by the dealership account holder. The dealership is solely responsible for providing all legally required notice of recording and for obtaining all legally required consent from the parties to such calls, in accordance with all applicable federal, state, provincial, and local laws (including, without limitation, all-party-consent and single-party-consent recording laws). Supreme Dealer's provision of the AI Voicebot does not constitute legal advice on, and does not satisfy, the dealership's consent and notice obligations.

4. How We Share Information

We do not sell or rent personal information to third parties, and we do not share personal information with third parties for their independent advertising or marketing purposes. We share personal information only in the following circumstances:

4.1 Service Providers and Subprocessors

We share personal information with trusted third-party service providers who perform functions on our behalf under contractual obligations of confidentiality and data protection. These providers are authorized to use personal information only as necessary to provide their services to us. Categories of service providers include:

• Payment Processing: Stripe, Inc., which processes payment transactions on our behalf.
• Cloud Hosting and Infrastructure: industry-standard cloud service providers that host and store data, provide computing capacity, deliver content, and operate databases and backups.
• Artificial Intelligence Providers: third-party providers of large language models and related artificial intelligence technologies that power certain features of the AI Tools. The identity of these providers may change from time to time without notice.
• Customer Relationship Management and Customer Support: HubSpot, Inc., which we use for customer relationship management, customer support, and related communications.
• Email and Communications: email delivery providers used to send transactional and marketing communications.
• Analytics: analytics providers that help us understand how the Services are used.
• Professional Advisors: auditors, accountants, attorneys, and other professional advisors, in connection with the services they provide to us.

4.2 Third-Party Integrations You Authorize

When you connect or authorize a third-party service (such as a social media network, advertising platform, marketplace, or CRM) to interact with your account, we share personal information with that third-party service in accordance with the permissions you grant. Your use of such third-party services is governed by their own terms and privacy policies, not by this Policy.

4.3 Legal and Safety Disclosures

We may disclose personal information if we believe in good faith that such disclosure is necessary to:

• Comply with applicable laws, regulations, court orders, subpoenas, search warrants, or other legal process;
• Respond to lawful requests from public or governmental authorities, including for national security, law enforcement, or regulatory purposes;
• Enforce our Terms of Service or other agreements;
• Detect, prevent, investigate, or respond to fraud, security incidents, or violations of our policies; or
• Protect the rights, property, or safety of Supreme Dealer, our users, or others.

4.4 Business Transactions

If Supreme Dealer is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of all or substantially all of its assets, or transition of service to another provider, personal information may be transferred or disclosed as part of such transaction. We will provide notice and, where required by law, obtain consent before personal information becomes subject to a different privacy policy.

4.5 Aggregated or De-Identified Data

We may share aggregated, de-identified, or anonymized data that does not identify you or any individual for any purpose, including for analytics, research, benchmarking, marketing, and product development. We are committed to maintaining such data in a de-identified or aggregated form and will not attempt to re-identify it.

4.6 With Your Consent

We may share personal information with other third parties when you have given us your consent to do so.

4.7 No Sale or Sharing for Cross-Context Behavioral Advertising

We do not sell personal information, and we do not share personal information with third parties for cross-context behavioral advertising, as those terms are defined under applicable United States state privacy laws. We have not sold or shared personal information for such purposes in the preceding twelve (12) months.

5. Cookies and Similar Technologies

5.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website or use an online service. They allow the service to recognize your device and remember information about your visit.

5.2 How We Use Cookies

We use cookies and similar technologies, including session cookies and persistent cookies, for the following purposes:

• Strictly Necessary Cookies: required to operate the Services, authenticate users, and maintain security. Without these cookies, the Services cannot function properly.
• Functional Cookies: remember your preferences and settings (such as language or display preferences) to provide a more personalized experience.
• Analytics Cookies: help us understand how the Services are used, identify performance issues, and improve the Services.

5.3 Your Cookie Choices

Most browsers allow you to refuse or accept cookies through their settings. You may also delete cookies that have already been placed on your device. Please note that disabling certain cookies will prevent you from using core features of the Services and may make the Services unusable. We do not currently respond to "Do Not Track" browser signals, as no uniform standard for such signals has been adopted.

6. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, tax, or reporting requirements, and to resolve disputes or enforce our agreements. Our standard retention periods are as follows:

• Account and Dealership Data: retained for the duration of your active account, plus ninety (90) days following cancellation or termination of your account, during which time you may request export of your Dealership Data. After such ninety (90)-day period, we will delete or anonymize your Dealership Data, except as otherwise required by law or as retained in aggregated or de-identified form.
• AI Voicebot Recordings and Transcripts: retained for the duration of your active account so that you may access and review your interactions with leads and customers. Following cancellation or termination of your account, recordings and transcripts will be deleted in accordance with the same ninety (90)-day post-termination schedule applicable to Dealership Data, except as otherwise required by law.
• Billing and Tax Records: retained for seven (7) years, as required by applicable tax, accounting, and financial recordkeeping laws.
• Marketing Communications and Newsletter Subscriptions: retained until you unsubscribe or request deletion.
• Customer Support Communications and Tickets: retained for three (3) years from the date of the communication.
• Website Analytics Data: retained for up to twenty-six (26) months in accordance with industry standards.
• Logs and Security Data: retained for a reasonable period necessary for security, audit, and incident response purposes, typically not exceeding two (2) years.

We may retain personal information for longer where required by law, where necessary to defend or assert legal claims, or where retention is reasonably necessary for legitimate business purposes such as fraud prevention.

7. Your Choices and Communication Preferences

7.1 Account Information

You may access, review, and update most of your account information at any time by logging into your account dashboard. If you cannot make a change through your account, you may contact us at Help@supremedealer.com.

7.2 Marketing Communications

You may opt out of receiving marketing emails from Supreme Dealer at any time by clicking the "unsubscribe" link contained in the footer of any marketing email, or by sending a request to Legal@supremedealer.com. Please note that even after opting out, you will continue to receive transactional and service-related communications (such as billing notices, security alerts, and important updates to the Services), which are not subject to opt-out.

7.3 Cookies

You may control cookies through your browser settings as described in Section 5.3.

7.4 Closing Your Account

You may close your account at any time as described in the Terms of Service. Closing your account will result in the deletion of your Dealership Data in accordance with the retention periods described in Section 6.

8. Your Privacy Rights

Depending on your jurisdiction and applicable law, you may have certain rights with respect to your personal information. Supreme Dealer voluntarily extends a unified set of privacy rights to all dealership users in the United States and Canada, regardless of the state or province in which you are located. These rights include:

8.1 Right to Know and Access

You have the right to request that we provide you with information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purposes for which we collected it, the categories of third parties with whom we shared it, and any specific recipients.

8.2 Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you.

8.3 Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (such as where we are required to retain information to comply with legal obligations, complete a transaction, detect security incidents, exercise legal claims, or for other purposes permitted by law).

8.4 Right to Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format, and to request that we transmit such information to another controller where technically feasible.

8.5 Right to Opt Out of Sale or Sharing

Although we do not sell or share personal information for cross-context behavioral advertising, you have the right to direct us not to do so. To the extent applicable, you may exercise this right by contacting us at Legal@supremedealer.com.

8.6 Right to Limit Use of Sensitive Personal Information

To the extent any sensitive personal information is inadvertently collected, you have the right to limit our use and disclosure of such information to those purposes necessary to provide the Services.

8.7 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not deny you the Services, charge different prices, or provide a different level or quality of Services because you exercised your rights.

8.8 Right to Withdraw Consent

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

8.9 Right to Appeal

If we deny your request to exercise any of the rights described above, you have the right to appeal our decision. To appeal, contact us at Legal@supremedealer.com and clearly state that you are appealing our decision. We will respond to appeals within a reasonable period and in accordance with applicable law.

8.10 How to Exercise Your Rights

To exercise any of the rights described above, please submit a verifiable request to us by emailing Legal@supremedealer.com. Your request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will respond to verifiable requests within forty-five (45) days, or such other period as required by applicable law. We may extend this period by an additional forty-five (45) days where reasonably necessary, in which case we will notify you of the extension within the initial response period. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded, in which case we may charge a reasonable fee or decline to act on the request.

8.11 Authorized Agents

You may designate an authorized agent to make a request on your behalf. We may require the authorized agent to provide proof of authorization and may require you to verify your identity directly with us before responding to the request.

8.12 State-Specific Rights

To the extent applicable, the rights described above are intended to satisfy the requirements of the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act, the Montana Consumer Data Privacy Act, and similar state privacy laws now or hereafter in effect. Residents of these states may have additional rights as specified by applicable law.

8.13 Canadian Privacy Rights

If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act ("PIPEDA") and substantially similar provincial privacy legislation, including the right to access your personal information, request correction of inaccuracies, and withdraw consent to the collection, use, or disclosure of your personal information. To exercise these rights, contact us at Legal@supremedealer.com. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or the privacy commissioner of your province.

9. International Data Transfers

Supreme Dealer is established in the United States, and the Services are hosted and operated primarily on servers located in the United States. If you access the Services from Canada or from any other location, personal information that we collect will be transferred to, stored in, and processed in the United States.

By accessing or using the Services, you acknowledge and consent to the transfer of your personal information to the United States. The data protection laws of the United States may differ from those of the country in which you are located, and U.S. governmental authorities may have access to personal information under U.S. law. Supreme Dealer takes reasonable steps to ensure that personal information transferred internationally is protected by appropriate safeguards consistent with this Policy and applicable law.

10. Data Security

10.1 Security Measures

Supreme Dealer implements and maintains commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. These safeguards include:

• Encryption of personal information in transit using industry-standard protocols (such as HTTPS and TLS);
• Encryption of personal information at rest;
• Access controls and authentication mechanisms, including unique credentials and, where supported, multi-factor authentication;
• Logical separation of customer environments;
• Monitoring, logging, and intrusion detection systems;
• Regular security reviews and updates; and
• Contractual obligations of confidentiality and data protection with our service providers.

10.2 No Absolute Security

No method of transmission over the Internet or method of electronic storage is one hundred percent (100%) secure. While we strive to use commercially reasonable means to protect personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying us of any suspected unauthorized access or security breach affecting your account.

10.3 Breach Notification

In the event of a confirmed data breach affecting your personal information, we will notify you at the earliest reasonable opportunity in accordance with applicable law and will cooperate reasonably in investigating and remediating the breach.

11. SMS, Voice, and Electronic Communications

11.1 Service-Related Communications

By registering for the Services, you consent to receive service-related communications from Supreme Dealer by email, SMS, in-platform notification, or other electronic means, including communications related to account security, authentication, billing, technical issues, and material changes to the Services or our policies. These communications are not subject to opt-out, as they are necessary to provide the Services.

11.2 Marketing Communications

You may receive marketing communications (such as newsletters, product announcements, and promotional offers) by email if you have opted in or have not opted out. You may opt out of marketing communications at any time as described in Section 7.2.

11.3 Phone Number and SMS Consent

Phone numbers and SMS consent will not be shared with third parties, vendors, affiliates, or any other outside entity for marketing or promotional purposes under any circumstances. Text messaging originator opt-in data and consent will not be shared with any third parties.

11.4 SMS Program Disclosures

When you opt in to receive SMS messages from Supreme Dealer, the following disclosures apply: message frequency may vary, message and data rates may apply, you may reply STOP to opt out at any time, and you may reply HELP for help. Full SMS terms, including the program description, supported carriers, consent basis, and contact information, are set forth in Section 21 of our Terms of Service.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. For material changes, we will provide at least thirty (30) days' prior written notice via email to the address associated with your account and/or by posting a notice within the Platform. For non-material changes, we may update the "Last Updated" date at the top of this Policy without further notice.

Your continued use of the Services after the effective date of any modification constitutes your acceptance of the modified Policy. If you do not agree with the modified Policy, you must stop using the Services and may cancel your subscription in accordance with the Terms of Service.

13. Relationship to the Terms of Service

This Policy is incorporated by reference into the Supreme Dealer Terms of Service and forms an integral part of the agreement between you and Supreme Dealer. In the event of any conflict between this Policy and the Terms of Service, the Terms of Service shall control, except with respect to matters specifically governed by this Policy.

14. Contact Information

If you have any questions, concerns, comments, or requests regarding this Policy or our privacy practices, or if you wish to exercise any of your privacy rights, please contact us:

Supreme Dealer LLC 1209 Mountain Road Pl NE, Ste R Albuquerque, NM 87110 United States Email: Legal@supremedealer.com