TireTutor, Inc.

Privacy Policy

Last Updated: August 24, 2023

1. Introduction

We, TireTutor, Inc. (“TireTutor”, “we”, “us” or “our”) know our customers (“you” or “your”) care about how their personally identifiable information is used, stored, and shared, and we take privacy seriously. This privacy policy (“Policy”) is intended to help you understand what information we gather about you, how we use and share that information and what measures are taken to protect it. By using or accessing the TireTutor website (the “Website”) and any other related services offered by us (collectively, the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby acknowledge that and consent to how we will collect, store, use, and share your information in the following ways. Please note that any capitalized terms not defined in the Policy are defined within our Terms of Use which you can find on our Website.

1. What Personally Identifiable Information Do We Collect?

1. Voluntarily Disclosed Personally Identifiable Information

When you use our Services, you may to provide us with the following types of personally identifiable information:

• Name, email address, telephone number (including business, mobile and home phone numbers), user name, home, business, and billing addresses and zip code.
• Information about your vehicle such as vehicle identification number, license plate number, year, make, model, trim (i.e., specific version of a model, which can be a 2-door or 4-door version).
• Your preferences and requests such as specific brand of tire, performance, miles you drive per year, how many tires you need to purchase and additional service requests as available.
• Contact information and communications with us when you complete a contact form for our Services, including “Shop Tires”, “Research Tires”, “Personalized Quotes”, “Get a Quote”, “Schedule Appointment”, or “Get a Quote via Phone” other Services we may provide from time to time.
• Reservation details such as your preferred Dealer, date, and time of your appointment.
• Proof of purchase from a Dealer listed on our Website.
• Your searches, transactions, and our interactions with you for Services.

1. Cookies

“Cookies” are identifiers that are transferred to your browser or device that allow your browser or device to be recognized and inform how and when pages and features on a website are visited and by how many people. Our Website uses Cookies, in combination with pixels and similar technology (collectively, “cookies”) to make the Website work properly, provide you with relevant content and personalized services, and distinguish you from other users of the Website. By using our Website, you also consent to the use of cookies. You do not need to allow cookies to visit most of our Website. However, enabling cookies may allow for a more tailored browsing experience.

1. What are different types of cookies?

• First-party cookies are those set by the host domain that is being visited by the user at the time.
• Third-party cookies are installed by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.
• Persistent cookies, also known as “permanent cookies” remains in your device after the web browser is closed. They are activated each time you visit the website that created that cookie and remain for the period specified in the cookie.
• Session cookies, also known as “temporary cookies” allows the web browser to link your actions during a browser session. A browser session starts when you open the browser window and finishes when you close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

1. Why do we use cookies?

Through the cookies in our Website, we may collect the following personally identifiable information:

• IP address
• Geolocation data
• Device identification and information
• Type of browser and/or device you are using to access our Services
• Page or feature you requested
• Your preferred language
• Behavioral data (e.g., content viewed/clicked)
• Demographic data (e.g., gender, age, interests)

We use analytics platforms provided by Google LLC (Google Analytics), Hotjar Ltd. and Fullstory, Inc. on our Website. These analytics platforms may place third-party cookies and utilize other technologies to collect data on your behavior and devices to help us analyze your use of our Website and diagnose technical issues.

When you click on ads that appear on the Services, our advertising partners may also transmit cookies to your browser or device. If you click on a link to a third-party website or service, a third party may also transmit cookies to you.

This Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests (or other similarly labeled requests not to use cookies on such third-party websites) you have set using your browser or device.

We encourage you to review the privacy policies of the analytics platforms we use, to learn more about how they process personally identifiable information for each of these purposes, how your information is used in the context of advertising, how long they store this information and how you can opt out.

You may access the privacy policies of such analytics platforms that we use by viewing the following links:

• Google Analytics Privacy Policy and information on Google Ads.
• Hotjar Privacy Policy.
• FullStory Privacy Policy.

We also utilize social media cookies which are set by a range of social media services (e.g., Meta Pixel). These cookies can track your browser across other sites and building up a profile of your interests and show you relevant ads. This may impact the content and messages you see on other websites you visit. Some cookies may fulfil more than one of these purposes.

1. How to delete and block our cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our site and our Services.

Collection of your data from our analytics cookies can be deleted. If cookies are deleted, the information collected prior to the preference change may still be used, however, we will stop using the disabled cookie to collect any further information from your user experience.

1. Changing your cookie settings

Your internet browser allows you to change your cookie settings. These settings are usually found in the “options” or “preferences” menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise, you should use the “Help” option in your internet browser for more details.

• Cookie settings in Microsoft Edge
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

1. Email Communications

If you provide your email address for receiving marketing communications, we will be notified when you open an email from us. This information helps us make our communications with you more interesting and improve our Services. [Unsubscribe [email protected]]

1. Phone Communications - Text Messaging (SMS)

If you submit your mobile phone number on our Website, you agree to receive text messages in connection with your tire shopping and other vehicle services interests. You may receive text messages from TireTutor and/or its Dealers through their respective third party providers.

If you agree to receive order-related updates from TireTutor, you may also receive text messages when, for example, your order is received, if there are any order-related concerns regarding your payment method, when your order and/or services are available, delivered, or if an exception or delay is experienced. You may also receive information about your Dealer, about your order and/or other vehicle services you have requested from the Dealer.

If you agree to receive marketing updates from TireTutor, you will receive text messages related to products, promotions and services available for your vehicle or within your area. You may also receive timely updates about tire maintenance and/or targeted messages based on your visits to our site.

If you provide your mobile phone number, we will collect your user or screen name, any comments or feedback that you send to us, or any other information that you choose to include in messages you send through text messages. When you send text messages, we will collect your messaging history and any information included in those messages.

Information we collect from you will be subject to TireTutor’s Terms of Use. By agreeing to receive text messages you agree to be bound by our policies.

Text messages from a Dealer will be subject to the Dealer’s policies, procedures, and compliance protocols, of which TireTutor has no control.

You can cancel the SMS service from TireTutor any time by texting “STOP” to the SMS received. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed from SMS messages from TireTutor. After this, you will no longer receive SMS messages from us.

If you are experiencing issues with TireTutor’s text messaging program you can reply with the keyword HELP for more assistance or email [email protected].

Carriers are not liable for delayed or undelivered messages. As always, message and data rates may apply for any messages sent to you from us and to us from you. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

1. How Do We Use Your Personally Identifiable Information?

We may use your personally identifiable information for the following purposes:

1. Our Services

Service Type

Data Category

Purpose

Sharing

Shop Tires

Year, make, model, trim of your vehicle, and size or placement of tires (collectively, “Vehicle Details”), tire brand preferences, vehicle license plate number, your city, state or zip code and email address (if provided).

To know the type of car you have to search for the right tires and other automotive services for your car.

We collect your email address if you enable notifications for price drops and availability of new tires for sale for this search.

We will share the information collected and the deals you looked at with the Dealers.

Research Tires

Vehicle Details, license plate number and your city and state.

To search for the right tires for your car and send you a copy of the deal you saved to your email address.

We will share the fact that you saved this deal with the relevant Dealer.

Get a Quote

Vehicle Details, your name, email, phone number.

To send your request to multiple (3-5) Dealers to have them bid on selling you tires for your vehicle.

We share your personalized quote request with the Dealers to respond.

Schedule Appointment

Vehicle Details, your name, email, phone number, billing address, preferred day and time of appointment.

To auto-email an appointment request directly to a Dealer to schedule your visit.

We share your appointment request and information with the Dealer to respond.

If you choose to book an appointment and pay in installments, we will share your name and billing address with Klarna, Inc.

Get a Quote via Phone

Phone number you called a Dealer from using our Website.

To know which consumers called which Dealers.

We share your phone number with our Dealers in our monthly reports.

We may also use your personally identifiable information for the following purposes:

• Provide and improve our Services to connect you with the best local deals on tires and services for your car, compare prices, present you personalized quotes, research tires and assist you with the booking of the requested services by a Dealer.
• Enable and facilitate acceptance and processing of payments, other transactions, and verification of your identity. We process payments through a licensed third-party service provider.
• Contact you (such as by text message (SMS), email, phone calls, mail, or push notifications) to provide information like booking confirmations and updates.
• Respond to your questions and requests for information.
• Collect and enable customer feedback, service-related reviews, and comments.

1. Marketing communications

• Market our Services, optimize such marketing to be more relevant to you, and measure and analyze the effectiveness of our marketing and promotions.

1. Interest-based advertising

When you visit our Website both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). We will use interest-based advertising to:

• Customize content for you that we think you might like, based on your usage patterns.
• Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible.

You may see our ads on other websites or mobile apps (such as Nextdoor) because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Website, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We use Google Ads, Meta Ads Manager and other advertising platforms and networks. To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the resources provided by the Network Advertising Initiative and Digital Advertising Alliance.

1. Legal Compliance

• Comply with applicable laws, protect our and our users’ rights and interests, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process.
• Operate our business using lawful business purposes and as permitted by law.

1. The California Consumer Privacy Action (CCPA). The CCPA provides that any for-profit entity doing business in California (whether or not the business is actually based in California) that collects or processes consumers’ personal information (or on whose behalf such information is collected) may be required to provide a CCPA privacy policy and if they satisfy a certain threshold. If such thresholds are met, the CCPA requires businesses to document the controls they have instituted to protect consumer privacy rights in a written privacy policy notice and at point of contact policy. TireTutor at this time does not meet the necessary thresholds to require compliance with CCPA.

1. How Do We Share Your Personally Identifiable Information?

We may share your personally identifiable information as described below to provide our Services to you:

1. Our Affiliates

We may share your personally identifiable information with our Affiliates. Our affiliates may access, share and use your personally identifiable information as described in this Policy.

1. Third-Party Service Providers

We employ a limited number of service providers to perform tasks on our behalf in connection with the delivery of our Services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics and to serve you with advertising tailored to your interests). Our service providers do not have any right to use the personally identifiable information we share with them beyond what is necessary to assist us.

• Payment Information. We do not collect, store, or share any credit card or payment information. When you provide your credit card and payment information, this information is processed directly through third-party service providers.

1. Processing of Payments: Your payment will be processed by Stripe, Inc. or another Payment Card Industry Data Security Standard (PCI DSS) compliant Level 1 Service Provider pursuant to the highest industry standards and guidelines for PCI compliance. The service provider will collect, use, process and share your payment and billing information, including your credit card number, expiration date and CVC in accordance with its own Privacy Policy.
2. Financing Options: You can pay for certain tires or services in installments with Klarna, Inc., an online payment company. For clarity, the actual financing service is carried out by and the payments are directly made to Klarna. Klarna will directly collect, process and share your personally identifiable information, which may include payment information, in accordance with Klarna’s own terms and conditions and privacy policy. When you use Klarna, you agree to Klarna’s Terms and Conditions and Privacy Policy.

• Online Comments. We respect and value relevant and useful comments. To enable you leave comments on TireTutor news, we partner with Disqus, Inc. who offers an online public comment sharing platform where users login and create profiles to participate in conversations with peers and enjoy an interactive experience. Using this functionality is subject to Terms of Service and Privacy Policy of Disqus. When you use Disqus you agree to Disqus’ Terms of Service and Privacy Policy.

THE VIEWS AND OPINIONS EXPRESSED THROUGH DISQUS ARE THOSE OF THE USERS OF DISQUS AND DO NOT NECESSARILY REFLECT THE VIEW OR OPINIONS OF TIRETUTOR.

1. Our Business Partners

To connect you with the best deals on tires for your car, present personalized quotes, and book appointments, we may share your first name, last name, contact and vehicle information with the Dealers with whom we contract with, so the Dealer can contact you relating to a tire purchase or other automotive service or request that you submit a Dealer review.

If you use our “Get A Quote” service, all information you provide in the form will be made available to our network of Dealers. You may receive calls, emails, and text messages (SMS) from Dealers and service centers at the number provided (including via autodial or prerecorded calls) or via other contact information provided in the form, with their quotes on tires or service for your car.

1. Advertisers

We may allow advertisers and/or merchant partners such as tire manufacturers (each an “Advertiser” and collectively, “Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers. We may provide any of the information we collect from you to an Advertiser in a format that it no longer links to you or another individual. Based on such de-identified information, Advertisers may segment and select the appropriate audience for their advertisements and/or offers. For example, we might use the fact you are located in Boston, Massachusetts to show you ads or offers for Boston businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an Advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad by clicking on it, the Advertiser may conclude that you fit the description of the audience they are trying to reach.

1. Aggregated or Anonymized Information

We may de-identify your personally identifiable information so that you are not identified as an individual. In addition to Advertisers, we may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

1. Business Transfers

We may choose to buy or sell our assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personally identifiable information could be one of the assets transferred to or acquired by a third party.

1. Legal Compliance

We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of TireTutor, our employees, our users, or others.

1. How Do We Store and Protect Personally Personal Information?

We keep personally identifiable information, in a form which permits us to identify you, for no longer than is necessary for the purposes for which it was collected or until consent to hold the personally identifiable information is revoked, provided that there is no other basis for us to hold the information, such as to comply with our legal, tax, accounting, financial reporting and other regulatory obligations, where we are required to retain the information by our contractual commitments to our business partners (such as Dealers). Where we retain personally identifiable information, we do so in accordance with any records retention obligations that are imposed by applicable law.

We maintain a variety of physical, electronic, and procedural safeguards to protect your personally identifiable information. For example, we store personally identifiable information in secure cloud-managed platforms, use commercially reasonable tools and techniques to protect against unauthorized access to our systems. We implement periodic and mandatory password change policies and requite two-factor authentication to systems where personally identifiable information is stored. We also restrict access to personally identifiable information to the TireTutor employees and service providers (other than Affiliates or Dealers) who need such access in the course of their duties for us.

We endeavor to protect the privacy of your account and other personally identifiable information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

1. How Can I Request You to Remove My Information?

If you request, we will remove your name and all other personally identifiable information that you have provided for the Services. In order to request deletion of information, please contact us at [email protected]. We will consider any such request seriously and promptly, although we may choose not to delete information if it is necessary for our compliance with legal obligations, or we otherwise have a substantial need to retain the personally identifiable information. Please understand that it may be impossible or impracticable to delete this information completely, due to backups and records of deletions. In addition, please understand that, if you request removal of your information, you may be unable to utilize associated features of the Services. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

1. What are My Rights?

You may also request access to, correction, or restriction of your personally identifiable information. You may also have rights to restrict or to object to portability of your information to third parties, such as our Affiliates. Such rights may be exercised by contacting us at [email protected].

1. Age of Users; Compliance with COPPA

We do not knowingly gather personal information (as defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”) from anyone under the age of 18 in a manner not permitted by COPPA.

• Children under the age of 13 are not permitted to use, access, or register for the Services in any way.
• Minors who are 13 or older, but under the age of 18, may only share personally identifiable information with us under the supervision of a parent or a legal guardian who agrees to be bound by this Policy.

If we learn that TireTutor has collected personally identifiable information from a child (i) under the age of 13 or (ii) between the ages of 13 – 18 without the supervision of a parent or a legal guardian who agrees to be bound by this Policy, we will delete that information as quickly as possible.

If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at [email protected]. We will remove the data to the extent required by applicable laws.

We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without their affirmative authorization.

If you are a California resident under 18 years old and registered to use our Services, you can ask us to remove any content or information you have posted. To make a request, email us at the email address set out in “Contact Us” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

1. Changes to Policy

TireTutor reserves the right, at its sole discretion, to modify this Policy at any time and without prior notice. If we modify the Policy, we will either post a notification of the modification on our Website and/or otherwise provide you with notice of the change. The date of the last modification will also be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Services, you are indicating that you agree to be bound by any modifications to the Policy.

1. Contact Us

If you have any questions about the Services, please do not hesitate to contact us at [email protected].

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