Privacy Policy

1. Definitions

For clarity and consistency, the following terms have the meanings set out below throughout this Privacy Policy:

• "Platform" means the 10BelowCars website, mobile interfaces, and related online services.
• "Services" means the features, tools, and functionality 10BelowCars makes available through the Platform.
• "Dealer" means an independent, licensed automobile dealership that uses the Platform to advertise vehicles priced at $10,000 or less.
• "Shopper" means an individual who browses listings, saves searches, or contacts a Dealer through the Platform.
• "User" means any person who accesses or uses the Platform, including Dealers and Shoppers.
• "Personal Information" means information that identifies, relates to, or can reasonably be used to identify an individual or business.

2. Information We Collect

We collect information that you provide directly to us, information generated as you use the Platform, and information from third parties that help us operate. The categories of Personal Information we may collect include:

• Account information — such as name, email address, phone number, and dealership details submitted at registration.
• Listing information — vehicle details, photos, and related content that a Dealer submits to create a listing.
• Inquiry information — name, phone number, email, and any message submitted when a Shopper contacts a Dealer.
• Communications — messages sent between Shoppers and Dealers and certain support correspondence with 10BelowCars.
• Usage and device information — described further below.

We collect only information that is reasonably necessary to provide and improve the Platform. We do not request sensitive data such as Social Security numbers through our public forms.

3. Information Dealers Provide

When a dealership registers, a representative provides business and contact information, including dealership name, contact name, phone number, email, address, city, state, ZIP code, website, and optional logo or business description. Dealers also provide the details that make up each vehicle Listing, including year, make, model, trim, price, mileage, color, VIN, description, and photos.

Dealers are responsible for ensuring that the information they publish about vehicles is accurate and that they have the right to display any photo or image they upload.

4. Information Shoppers Provide

Shoppers can browse Listings without providing Personal Information. When a Shopper uses a feature that requires information — such as contacting a Dealer, requesting financing information, or submitting a trade-in inquiry — the Shopper provides details such as name, phone number, email, and notes about the vehicle of interest.

When a Shopper contacts a dealership through the Platform, the inquiry is forwarded to the selected dealership so that the dealership may respond. The relationship between the Shopper and the dealership is separate from the relationship between the Shopper and 10BelowCars, and dealers maintain their own privacy practices, which may differ from ours.

5. Automatically Collected Information

As you interact with the Platform, we and our service providers may automatically log certain technical information, such as IP address, browser type and version, device type, operating system, referring pages, pages viewed, and the dates and times of your visits. This information helps us operate, secure, analyze, and improve the Platform and detect or prevent fraud.

6. Cookies and Similar Technologies

We may use cookies, local storage, and similar technologies to keep you signed in, remember your preferences, measure traffic, and understand how features are used. You can set your browser to refuse cookies or alert you when cookies are being sent; however, some features of the Platform may not function properly if cookies are disabled.

We do not use these technologies to collect sensitive Personal Information.

7. Analytics and Service Improvement

We may use analytics and similar measurement tools, including those provided by third parties, to understand how visitors find and use the Platform, to identify popular features, and to detect problems. Aggregated or de-identified information may be used to improve Listings, search, and overall performance. Where a third-party analytics provider is used, it processes information under its own privacy practices.

8. How We Use Information

We use the information we collect for the following purposes:

• Operate, maintain, and improve the Platform;
• Create and display vehicle Listings;
• Forward Shopper inquiries to the dealership a Shopper selects;
• Communicate with Dealers and Shoppers about their accounts, Listings, and inquiries;
• Process Subscriptions and maintain limited business records;
• Detect, prevent, and respond to fraud, abuse, and security issues;
• Conduct identity verification, account-security monitoring, and duplicate-account prevention;
• Protect marketplace integrity and prevent abuse of the Platform;
• Perform internal quality assurance and analyze usage to improve search relevance and platform functionality;
• Develop and evaluate future Services; and
• Conduct internal business operations, comply with legal obligations, and enforce our Terms.

We process information based on the context — for example, to perform a request a Shopper has made, to operate a Dealer's account, to fulfill a contract, or to protect our legitimate interests in operating a safe and reliable Platform.

10. Email and Account Communications

We send emails relating to account registration, listing activity, support requests, payment confirmations, and important updates about the Platform. Where we send marketing communications, you may opt out using the unsubscribe link in the message or through your account settings, without affecting transactional messages that are necessary to operate your account.

11. Dealer Inquiry Forms

When a Shopper completes an inquiry form — for example, a general message, financing inquiry, or trade-in inquiry — the information entered on that form is shared with the dealership associated with the Listing so that the dealership can respond. Additional forms may be added where applicable. The dealership, not 10BelowCars, is responsible for how it handles that information once received.

12. Marketing Preferences

Where we send promotional messages, we honor your choices. You can manage your preferences through your account settings where available, or by following the unsubscribe or opt-out instructions included in any marketing communication. Opting out of marketing does not stop account-related or legally required messages.

13. Stripe Payment Processing

Subscription payments to 10BelowCars are processed by Stripe. When you enter payment information, it is generally handled directly by Stripe, and 10BelowCars does not store your full card number on its own systems. We receive confirmations and limited business records needed to manage your Subscription and maintain accurate accounting.

Your payment information is processed under Stripe's privacy practices and the applicable card-network rules. 10BelowCars does not process payment for any vehicle purchase, deposit, or financing arrangement between a buyer and a Dealer.

14. Third-Party Service Providers

We engage trusted third parties to help operate the Platform, such as payment processors, cloud-hosting providers, email-delivery providers, SMS-delivery providers, analytics providers, and providers of vehicle history or map references. These providers may process limited information on our behalf under confidentiality obligations consistent with applicable law.

Each third-party provider is responsible for its own privacy practices. We encourage you to review the privacy policies of any external service that you interact with.

15. Data Sharing

We do not sell your Personal Information. We share information only as described in this policy or as reasonably necessary to operate the Platform:

• With Dealers — to forward Shopper inquiries to the dealership a Shopper selects.
• With service providers — such as payment processors, cloud-hosting providers, email and SMS providers, and analytics providers, under appropriate confidentiality terms.
• With professional advisors — including accountants, attorneys, and insurers, where reasonably necessary to obtain advice or protect our interests.
• For safety and legal reasons — to detect or prevent fraud, protect rights or safety, respond to lawful requests, or as otherwise required by law.
• In connection with a business transfer — including successors in a merger, sale, or restructuring, as described below.

We share information with these parties only when reasonably necessary and consistent with applicable law. While we take steps to protect information shared with Dealers, each Dealer is an independent business and is responsible for its own handling of information received.

16. Data Security

We use reasonable safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, and loss. These safeguards include administrative, technical, organizational, and physical measures — such as access controls, secure system configuration, staff handling procedures, and protections for facilities and equipment.

However, no system is completely secure, and we cannot guarantee the absolute security of information transmitted over the Internet or stored by us or our service providers.

17. Legal Compliance and Law Enforcement

We may access, preserve, or disclose Personal Information where we believe disclosure is reasonably necessary to comply with legal obligations, respond to lawful requests such as subpoenas or court orders, protect the legal rights, property, or safety of 10BelowCars, our Users, or others, investigate potential fraud, or help prevent unlawful activity. Where permitted by law, we may limit or contest requests that we believe are improper.

18. Data Retention

We retain Personal Information for as long as reasonably necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we delete it or de-identify it, unless retention is required by law. Listing content may be retained in backups or logs for a limited period in the ordinary course of operations.

19. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Access or request a copy of certain Personal Information we hold about you;
• Request correction of inaccurate information;
• Request deletion of certain Personal Information;
• Opt out of the sale or sharing of Personal Information, where applicable;
• Limit the use of sensitive Personal Information, where applicable; and
• Withdraw consent to certain processing.

To exercise any of these rights, contact us using the information at the end of this policy. We will respond within the timeframe required by applicable law and may need to verify your identity before acting on a request.

20. State Privacy Rights

Some U.S. states provide residents with additional privacy rights. Where you reside in a state with such rights, you may exercise them as described above, subject to any applicable exceptions. In particular, residents of certain states may have specific rights to know what Personal Information is collected, to access or delete it, and to opt out of certain processing, consistent with state law.

We do not sell Personal Information as the term is typically defined under state privacy laws, and we do not process sensitive Personal Information beyond what is necessary to operate the Platform.

21. Children's Privacy

The Platform is not directed to children under the age of eighteen (18), and we do not knowingly collect Personal Information from children. If you believe a child has provided us with Personal Information, please contact us and we will take steps to delete that information.

22. International Users

The Platform is intended primarily for Users located within the United States and is directed at U.S. law and practice. If you access the Platform from outside the United States, you understand that your information will be processed in the United States under this policy, and by using the Platform you consent to that processing. Where applicable law requires additional notice or rights, we will address them to the extent reasonably possible.

23. External Links

The Platform may contain links to external websites that are not operated by 10BelowCars. We are not responsible for the privacy practices or content of those sites and encourage you to review their policies. This policy applies only to information collected through the Platform.

24. Business Transfers

If 10BelowCars is involved in a merger, acquisition, restructuring, reorganization, or sale of all or part of its assets, Personal Information may be transferred as part of that transaction. We will notify you, where required by law, before your information is transferred to or becomes subject to a different privacy policy.

25. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page shows when the current version took effect. If we make material changes, we will provide notice through the Platform or by other reasonable means. Your continued use of the Platform after a change takes effect constitutes acceptance of the revised policy.

26. Contact Information

If you have questions about this Privacy Policy or how we handle your information, please contact us: