State-Specific Privacy Policy

REV 06/23

STATE-SPECIFIC PRIVACY POLICY AND NOTICE AT COLLECTION

This STATE-SPECIFIC PRIVACY POLICY AND NOTICE AT COLLECTION (“Policy” and/or “Notice”) of RESOLV, a Bridgestone Americas, Inc. brand (“RESOLV”, “we,” “us,” or “our”) applies solely to residents of the State of California (“consumers” or “you”). We adopt this Policy and Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) and other California privacy laws, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”). Any terms defined in the State Privacy Laws have the same meaning when used in this Policy and Notice. The general Privacy Policy on our website is also applicable to you, but to the extent any information in the general Privacy Policy conflicts with this Policy, the information in this Policy shall apply to you.

Information We Collect

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, we may collect the following personal information from you:

Category	Examples
Identifiers.	Real name, alias, postal address, unique personal or online identifier, Internet Protocol address, email address, social security number, driver’s license number, vehicle identification number, or vehicle license plate number.
Purpose of Collection/Usage of Identifiers We may collect and use the personal information in this category to: provide the package and goods or services requested; provide you with information about products and services requested; provide you with information about other products and services; enforce our obligations and rights; improve our websites and/or mobile applications; improve our customer service; work on testing, research, analysis and product development; respond to law enforcement, regulatory or judicial requests; evaluate or conduct a merger, divestiture, or restructuring; and protect the rights, property or safety of RESOLV or other parties.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, signature, social security number, address, telephone number, driver’s license or other government issued ID number, credit/debit card number, bank account number or other financial information. Some personal information included in this category may overlap with other categories.
Purpose of Collection/Usage of Personal Information Categories listed in Cal. Customer Records Statute We may collect and use the personal information in this category to: provide the package and goods or services requested; accept payment from you for products or services; provide you with information about other products and services; enforce our obligations and rights; improve our websites and/or mobile applications; improve our customer service; work on testing, research, analysis and product development; respond to law enforcement, regulatory or judicial requests; evaluate or conduct a merger, divestiture, or restructuring; and protect the rights, property or safety of RESOLV or other parties.
Protected classification characteristics under California or federal law.	Physical disability
Purpose of Collection/Usage of Protected Classification Characteristics We may collect and use the personal information in this category to: comply with applicable laws (including ADA).
Commercial information.	Records of personal property (including details about vehicle, e.g., vehicle identification number, vehicle license plate number, year, make, model, trim, mileage, driving conditions, mobile Device ID), products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Purpose of Collection/Usage of Commercial Information We may collect and use the personal information in this category to: provide the package and goods or services requested; provide you with information about products and services requested; provide you with information about other products and services; enforce our obligations and rights; improve our websites and/or mobile applications; improve our customer service; work on testing, research, analysis and product development; respond to law enforcement, regulatory or judicial requests; evaluate or conduct a merger, divestiture, or restructuring; and protect the rights, property or safety of RESOLV or other parties.
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Purpose of Collection/Usage of Internet or Other Similar Network Activity Information We may collect and use the personal information in this category to: provide information about products and services requested; provide you with information about other products and services; improve our customer service; improve our websites and/or mobile applications; work on testing, research, analysis and product development; respond to law enforcement, regulatory or judicial requests; and protect the rights, property or safety of RESOLV or other parties.
Geolocation data.	Physical location or movements.
Purpose of Collection/Usage of Geolocation Data We may collect and use the personal information in this category to: provide information about products and services requested; provide you with information about other products and services; improve our customer service; improve our websites and/or mobile applications; work on testing, research, analysis and product development; respond to law enforcement, regulatory or judicial requests; and protect the rights, property or safety of RESOLV or other parties.
Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Purpose of Collection/Usage of Inference Data We may collect and use the personal information in this category to: provide information about products and services requested; provide you with information about other products and services; improve our customer service; improve our websites and/or mobile applications; work on testing, research, analysis and product development.
Sensitive Data	Driver’s license or other government identification number, social security number, account login and password, credit/debit card number, bank account number or other financial information
Purpose of Collection/Usage of Sensitive Data We may collect and use the personal information in this category to: provide the package and goods or services requested; accept payment from you for products or services; provide you with information about other products and services; enforce our obligations and rights; improve our websites and/or mobile applications; improve our customer service; work on testing, research, analysis and product development; respond to law enforcement, regulatory or judicial requests; evaluate or conduct a merger, divestiture, or restructuring; and protect the rights, property or safety of RESOLV or other parties.

Personal information does not include:

· Publicly available information from government records.

· De-identified or aggregated consumer information.

· Information excluded from the State Specific Laws’ scope, like:

· Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sources of Information Collected:

· Identifiers, California Customer Records Statute Personal Information Categories, and Commercial Information

o Obtained directly from submissions on our website (www.resolveauto.com) or any RESOLV mobile application

o Obtained indirectly from customers through information we collect in the course of providing services to them

· Protected Classification Characteristics under California or Federal law

o Obtained directly and indirectly from activity on our website (www.resolveauto.com) or any RESOLV mobile application. For example, American with Disabilities Act requires websites to be accessible to those with disabilities – tool is provided to consumers to set up preferences such as large font, voice recognition, etc.

· Internet or Similar Network Activity

o Obtained directly and indirectly from activity on our website (www.resolveauto.com) or any RESOLV mobile application

· Geolocation Data

o Obtained directly from activity on our website (www.resolveauto.com) or any RESOLV mobile application

· Inferences

o Obtained directly and indirectly from activity on our website (www.resolveauto.com) or any RESOLV mobile application

o Obtained indirectly from customers through information we collect in the course of providing services to them

Sharing or Disclosure of Personal Information with Third Parties

We may disclose or share personal information to or with a third party for a business or commercial purpose and have done so in the preceding twelve (12) months. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

· Identifiers

· California Customer Records Statute Personal Information categories

· Protected Classification Characteristics under California or Federal Law

· Commercial Information

· Internet or other similar activity

· Geolocation Data

· Inferences

We may disclose your personal information for a business purpose to the following categories of third parties:

Service providers
Our affiliates
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Government agencies as required by state or federal law

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any personal information. Additionally, we do not knowingly collect, disclose or sell the personal information of minors under the age of 16.

Additionally, we do not knowingly disclose or sell the personal information of minors under the 16 years of age.

Your Rights and Choices

The State Privacy Laws provide consumers who are California, Virginia, Colorado, and Connecticut residents with specific rights regarding their personal information. This section describes the rights granted under the State Privacy Laws applicable to you and explains how to exercise those rights.

Opt-Out Rights

We do not sell your personal information for monetary or other valuable consideration or share your personal information for reasons other than the business purposes described above. Regardless, California residents have the right to direct us to not sell or share their personal information at any time, including for cross-context behavioral advertising (also known as targeted ads), and Connecticut, Colorado, and Virginia residents have the right to direct us to not sell their personal information at any time. Also, Connecticut, Colorado, and Virginia residents have the right to opt out of processing their personal data for the purpose of targeted ads or profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise these opt-out rights, you (or your authorized agent) may submit a request to us by visiting My Privacy Rights.

If you wish to change your mind and opt back in to any rights at any time, you can email: privacy@bfusa.com.

You do not need to create any new account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Right to Limit Our Use of Your Sensitive Personal Information

We may use Sensitive Personal Information about you for the business or commercial purposes described above. Subject to a few exceptions, you may limit our use of this Sensitive Personal Information to only uses that are reasonably necessary to perform services or provide goods. To exercise this right, please go to My Privacy Rights.

Access and Deletion Rights

Right to Access Specific Information:

You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past twelve (12) months, using the following e-mail address or by calling the number below:

privacy@bfusa.com or (888) 928-0287

***(Please note the website you are coming from in the subject line of the e-mail so that we may more efficiently verify and respond to your request.)***

You may request the categories of personal information collected and/or specific pieces of personal information collected, so please specify which you are requesting in the e-mail you send.

We may use your name, address, email, and/or phone number to verify your identity. Information provided will be compared to and validated against company records.

Once we receive and confirm your verifiable consumer request to know categories of personal information collected, we will disclose to you:

The categories of personal information we collected about you
The categories of sources from which we received the personal information we collected about you
Our business or commercial purpose for collecting or selling that personal information
The categories of third parties with whom we share that personal information
The categories of personal information that we disclosed for a business or commercial purpose and the categories of recipients

Once we receive and confirm your verifiable consumer request to know specific pieces of personal information collected, we will disclose to you:

The specific pieces of personal information we collected about you (also called a data portability request)

We are not obligated to provide you with this information more than twice within a 12-month period.

Right to Request Deletion of Personal Information:

You have the right to request that we delete any of your personal information that we collected from you and maintained, subject to certain exceptions. You can submit a deletion request using the following e-mail address or by calling the number below:

privacy@bfusa.com or (888) 928-0287

***(Please note the website you are coming from in the subject line of the e-mail so that we may more efficiently verify and respond to your request.)***

We may use your name, address, email, and/or phone number to verify your identity. Information provided will be compared to and validated against company records. The consumer will be required to respond to an email from us to confirm the deletion request.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request for certain reasons set reasons set forth in CCPA, which will be described to you if all or a portion of your deletion request is denied.

Right to Correct:

You have the right to request that we correct inaccuracies in your personal information collected by us, using the following e-mail address or by calling the number below:

privacy@bfusa.com or (888) 928-0287

***(Please note the website you are coming from in the subject line of the e-mail so that we may more efficiently verify and respond to your request.)***

General Rights Request Information:

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your or your household’s personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. If an authorized agent submits a request on behalf of a consumer, the authorized agent must provide proof of his/her/its registration as an authorized agent with the Secretary of State.

Response Timing and Format:

We will try to fully respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our response to you electronically via the email address provided on the request form. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights granted by the State Privacy Laws. Unless permitted by the State Privacy Law applicable to you, we will not:

Deny you goods or services
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
Provide you a different level or quality of goods or services
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Retention of Personal Information

We retain personal information only for so long as reasonably needed to fulfill the purposes for which we collected or obtained it or as otherwise required by law. We use reasonable business criteria to establish retention periods for personal information.

Changes to Our Privacy Notice

We reserve the right to change this State-Specific Privacy Policy and Notice at Collection in our discretion and at any time.

Contact Information

If you have any questions or comments about the State-Specific Privacy Policy and Notice at Collection, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under the State Privacy Laws, please do not hesitate to contact us at (888) 928-0287 or privacy@bfusa.com.