Privacy Policy Effective Date: May 9, 2025

Your Privacy is Our Priority

TheCRM Corporation (“TheCRM”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, and protect your personal information. Please read this policy carefully as it explains your rights regarding your personal data and how to contact us if you have any questions or concerns.

Definitions

• “We, Us, Our”: Refers to TheCRM Corporation.

• Privacy Representative: Email: privacy@thecrm.com, address: 9401 Wilshire Blvd, Suite 900, Beverly Hills, CA 90212.

• Data Protection Officer: Richard Keith Latman, email: privacy@thecrm.com, address: 9401 Wilshire Blvd, Suite 900, Beverly Hills, CA 90212.

• Personal Information: Any information related to an identified or identifiable individual.

Personal Information We Collect

Categories of Information:

• Required Identifiers: Name, email, username, and birthdate.

• Optional Information: Contact details, professional details, payment preferences, vehicle-related information, and additional profile details provided at your discretion

• Commercial Information: Purchasing history via TheCRM’s services

How We Collect Information:

• Directly from you through our website, app, emails, or customer support.

• From third-party sources with your consent, such as credit reporting agencies or banks.

• Via automated systems like cookies or dealership monitoring systems.

How We Use Your Personal Information

We use your personal information to:

• Provide Services: Ensure seamless operation and personalization of our products.

• Prevent Fraud: Protect you and our business from fraudulent activities.

• Compliance: Conduct identity and regulatory checks as required by law.

• Enhance Operations: Improve efficiency, training, and quality control.

• Customer Communication: Maintain accurate customer records and provide relevant updates.

• Marketing: Notify you about products and services, subject to your preferences.

Promotional Communications:

• We may send promotional emails, text messages, or push notifications about our products and services. Where required, we will only do so with your explicit consent.

• For details regarding SMS messaging practices, consent, data sharing, and opt-out instructions, please refer to the section titled “SMS Messaging & 10DLC Compliance.”

SMS Messaging & 10DLC Compliance

• Mobile information will not be shared with third parties/affiliates for marketing or promotional purposes. All categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

• We do not sell, rent, or transfer consumer data to any third parties for marketing purposes. Data shared with service providers is solely for operational purposes and not for marketing use.

• Personal data will not be transferred to any external organization or affiliate except as required for core business operations and regulatory compliance.

• If you wish to be removed from receiving future communications, you can opt out by texting STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE. You may also contact us directly at privacy@thecrm.com to manage your preferences.

• We adhere to the TCPA (Telephone Consumer Protection Act) guidelines, ensuring that all SMS and telecommunication practices comply with regulatory requirements. We collect and process mobile information only with explicit consent and provide clear opt-out options for users.

• SMS data collected during messaging campaigns is securely stored and protected according to industry standards. This data will not be shared or used beyond the scope of the original consent.

• When registering messaging campaigns, TheCRM will ensure that a link to this Privacy Policy and related Terms and Conditions is included in the Campaign Details section to facilitate compliance and vetting.

Data Sharing

We only share your personal information with:

• Affiliates within TheCRM group.

• Service providers assisting in delivering our products (e.g., payment processors).

• Regulatory bodies as required by law.

• Note: We do not sell personal information to third parties.

Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by law. Once the data is no longer needed, we will delete or anonymize it.

California Consumer Privacy Act (CCPA)

• If you are a California resident, you have the right to:

• Request information about the categories and sources of personal data collected.

• Access specific personal information collected.

• Request deletion of your data, subject to exceptions

• Opt-out of the sale of your personal data (if applicable).

Data Security

We employ industry-standard measures to protect your data, including encryption and secure storage solutions. Access to personal data is restricted to authorized personnel.

Contact Us

For privacy-related inquiries or to exercise your rights, please contact:

• Email: privacy@thecrm.com

• Address: 9401 Wilshire Blvd, Suite 900, Beverly Hills, CA 90212

Accessibility

If you require this Privacy Policy in an alternative format (e.g., audio or braille), please contact us at the address above.

Updates to this Policy

This Privacy Policy may be updated periodically. We will notify you of any significant changes via email, our website, or other appropriate communication channels.