This Privacy Notice for AUGUPA LLC DBA ION DMS ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://www.iondms.com or any website of ours that links to this Privacy Notice
• Use ION DMS – Dealer Management System — a cloud-based platform that streamlines automotive business operations including sales, inventory, finance, service, and communication
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. Contact us at support@iondms.com.

1 What Information Do We Collect?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You may include:

• Names
• Email addresses
• Job titles
• Phone numbers

Sensitive Information: We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Information Automatically Collected

This information does not reveal your specific identity but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, and other technical information. This information is primarily needed to maintain the security and operation of our Services.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data — service-related diagnostic information our servers automatically collect, including IP address, device info, browser type, and activity timestamps
• Device Data — information about your computer, phone, tablet, or other device used to access the Services
• Location Data — device location data, which can be precise or imprecise. You may opt out by disabling Location settings on your device

2 How Do We Process Your Information?

We process your personal information for a variety of reasons, including:

• To deliver and facilitate delivery of services — to provide you with the requested service
• To respond to user inquiries/offer support — to respond to your inquiries and solve any potential issues
• To fulfill and manage your orders — to fulfill and manage your orders, payments, returns, and exchanges
• To request feedback — to contact you about your use of our Services
• To send marketing and promotional communications — in accordance with your marketing preferences (you may opt out at any time)
• To post testimonials — which may contain personal information
• To comply with our legal obligations — to respond to legal requests and exercise our legal rights

3 What Legal Bases Do We Rely On?

If You Are Located in Canada

We may process your information if you have given us specific permission (express consent) or in situations where your permission can be inferred (implied consent). You may withdraw your consent at any time.

In some exceptional cases, we may process your information without consent, including:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been a victim of financial abuse
• If disclosure is required to comply with a subpoena, warrant, or court order
• If the information is publicly available and specified by the regulations

4 When and With Whom Do We Share Your Personal Information?

We may need to share your personal information in the following situations:

• Business Transfers — in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business
• Affiliates — with our parent company and any subsidiaries, joint venture partners, or other companies under common control with us
• Business Partners — to offer you certain products, services, or promotions

5 Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements tailored to your interests.

To the extent these technologies are deemed a "sale"/"sharing" under applicable US state laws, you can opt out by submitting a request described in the section Do United States Residents Have Specific Privacy Rights?

Google Analytics

We may share your information with Google Analytics to track and analyze use of the Services. To opt out, visit https://tools.google.com/dlpage/gaoptout. For more information, visit the Google Privacy & Terms page.

6 How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law. No purpose in this notice will require us to keep your personal information for longer than 90 days.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or securely store it and isolate it from any further processing until deletion is possible.

7 How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. You should only access the Services within a secure environment.

8 Do We Collect Information from Minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or are the parent or guardian consenting to your minor dependent's use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any such data, please contact us at support@iondms.com .

9 What Are Your Privacy Rights?

In some regions (like Canada), you have certain rights under applicable data protection laws, including the right to:

• Request access and obtain a copy of your personal information
• Request rectification or erasure
• Restrict the processing of your personal information
• Data portability (if applicable)
• Not be subject to automated decision-making

Withdrawing Your Consent

You have the right to withdraw your consent at any time by contacting us using the details in the How Can You Contact Us? section. Please note this will not affect the lawfulness of the processing before its withdrawal.

Opting Out of Marketing Communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in emails, replying "STOP" or "UNSUBSCRIBE" to SMS messages, or by contacting us. You will be removed from the marketing lists; however, we may still send service-related messages necessary for administration of your account.

Cookies and Similar Technologies

Most web browsers are set to accept cookies by default. You can usually choose to remove or reject cookies in your browser settings. Note this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, email us at support@iondms.com.

10 Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control

We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat this as a valid opt-out request under applicable state privacy laws including the CCPA. For more information, visit globalprivacycontrol.org.

11 Do United States Residents Have Specific Privacy Rights?

Categories of Personal Information We Collect

Your Rights

• 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
• Right to opt out of the processing of your personal data for targeted advertising, sale, or profiling

How to Exercise Your Rights

To exercise these rights, contact us by visiting support@iondms.com or by referring to the contact details at the bottom of this document. We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal.

Request Verification

Upon receiving your request, we will need to verify your identity. We will only use personal information provided in your request to verify your identity. If we cannot verify your identity from information already maintained by us, we may request additional information.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us. If your appeal is denied, you may submit a complaint to your state attorney general.

12 Do We Make Updates to This Notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.

13 How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at support@iondms.com or contact us by post at:

14 How Can You Review, Update, or Delete the Data We Collect from

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request by contacting us at support@iondms.com.

15 Data Deletion Instructions

If you wish to delete your data associated with ION DMS, please follow the steps below:

• Send an email to support@iondms.com
• Use the subject line: "Data Deletion Request"
• Include your registered phone number or email address

Once we receive your request:

• We will verify your identity
• Your data will be deleted from our system within 7 business days
• You will receive confirmation once the deletion is completed

If you have any questions, you can contact us at support@iondms.com.