Last Updated: November 29, 2023
‍
‍Ekho, Inc and its affiliates (collectively, “Ekho”, “we”, or “us”) provide services and software to OEM partners, enabling them to sell vehicles and accessories via their websites. In connection with our websites (“Sites”) and in order to provide the Ekho Dealer Services (the “Services”), we collect personal information from visitors to our Sites and OEM partners interested in adding our Services to their offerings (“OEM Partners”). We also collect the personal information of end users who purchase vehicles and accessories manufactured by OEM Partners via the Services (“End Users”).

This Privacy Notice describes how we collect, handle, and disclose personal information on our Sites or when you use the Services, including any affiliated websites, software or platforms owned or operated by Ekho on which this Privacy Notice appears. When an End User visiting an OEM Partner’s website wishes to purchase a vehicle (and/or accessories), the End User will be automatically redirected to an Ekho-powered page to complete relevant information as described in and governed by this Privacy Notice. With respect to End Users, Ekho is the data controller for the personal information that it collects. In such cases, our processing of personal information is described in this Privacy Notice.

From time to time, we may update this Privacy Notice as we change or update our data collection practices, or as applicable privacy laws are updated. We encourage you to review this Privacy Notice to understand our information handling and privacy practices. If you have any questions, you may contact us at support@ekhodealer.com. You can also navigate this Privacy Notice more easily by clicking on the sections listed in the Table of Contents below.
‍
Table of Contents
‍Information We Collect
Payment Processing
Children’s Privacy
How We Use Your Information
When We Disclose Your Information
Third-Party Websites
Information Security
Processing in the United States
Your Choices
Contact Information
Changes to this Privacy Notice

‍1. Information We Collect
‍We collect information directly from you, through automated means, such as cookies, or via third parties. The type of personal information we collect depends on how you use or Sites and Services, as described in further detail below.
‍
a. Information you provide to us
‍
Ekho Site Visitors
‍You may visit our Sites without submitting any personal information, in which case we will only collect information via automated means, as explained below.

‍OEM Partners
‍If you are an OEM Partner (or a potential OEM Partner) and contact us or book a demo via our Sites, we collect your first and last name and your business email. We also collect information about your business, including business type and website URL.

‍End Users
‍If you are an End User purchasing a vehicle and/or accessories via the Services, we will collect information to enable you to purchase and pay for the vehicle and/or accessories, complete the vehicle registration and titling process (if applicable), and otherwise complete any transactions you request. The information that we collect consists of the following:Account information: full name, email address, phone number and password.Shipping information: full name, physical address.Payment information: credit card information is collected directly by our third-party payment processors as described here.Product information: information about the products you purchase, including any customizations.Titling and registration information: full name, date of birth, gender, phone number, military status, a photo of your driver's license, driver’s license number, and physical address.Chat information: if you use our chat feature, we will collect any information that you provide via the chat feature. You will first be asked to consent to the collection of information via the chat feature.Note about Information Collected in Connection with a Request to Finance a Vehicle: if you wish to finance a vehicle when purchasing through Ekho, we collect specific information on behalf of a third-party lender to determine your eligibility and facilitate the financing if approved. This includes your social security number, employment information, housing information, and other non-public information that is required to evaluate your application. You will receive a separate notice regarding our data collection practices if you seek to finance your vehicle purchase.

b. Automatically collected information
‍When you visit and interact with our Sites and Services, we automatically collect information about your device, browser, and activity:Cookies and other tracking technologies. We (or our authorized service providers) automatically collect information about you through cookies or similar technologies. We use this information for various purposes, including to: ensure that the Sites and Services function properly, understand how you use the Sites and Services, and obtain usage metrics.Most browsers provide choices with respect to these technologies. For example, by modifying your browser preferences, you may have the choice to accept all cookies or be notified when a cookie is set. Please consult the “Help” section of your browser (e.g., Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari). You can learn more about cookies and how they work at www.allaboutcookies.org, or by visiting your browser preferences. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Sites or Services.Log data and device information. We collect information about the device you use to connect to the Sites and Services and how you use them. This information includes your device’s IP address, your device type, browser type, internet service provider, operating system, and unique device identifiers. It also includes activity and usage information, such as the frequency with which you use the Sites and Services, how long you stay connected, the pages that you navigate to, links that you view, and other ways that you interact with the Sites and Services.Location Information. When you access the Sites and Services, we may collect information about your device’s location by inferring your general location such as via your device’s IP address. When using the Services, if you buy a vehicle through Ekho and opt to pick it up from a pick-up location, we will ask to use your precise geolocation information to find the closest pick-up location.Analytics. We use third-party analytics providers who may deploy cookies and similar technologies to analyze traffic to the Sites and Services and understand the usage of the Sites and Services. For example, we use Google Analytics, an analytics tool that helps us understand how Site Visitors engage with the Sites. To learn more about Google Analytics’ data practices, please visit Google’s support page. We also use a service provided by Mixpanel to provide us with analytics data regarding users’ interactions with the Sites and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected by visiting mixpanel.com/optout.Do not track. “Do Not Track” (“DNT”) is a standard for web browsers that aims to inform the websites you visit that you do not want information about your online activity collected over time and across third-party websites or online services. Although we do our best to honor the privacy preferences of our users, we do not respond to DNT or other similar signals from your browser at this time. For more information, visit www.allaboutdnt.com.

c. Information received from third parties
‍From time to time, we process personal information from third parties, which consists of data from our partners, such as transactional data from payment service providers, insurance service providers, identity verification providers, or information from our OEM Partners. We may also combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered through an OEM Partner sales inquiry/submission with information we receive from a third-party sales intelligence platform to enhance our ability to market our Services to potential OEM Partners. Third parties from whom we may receive information include:Our payment processors (see below);Fraud prevention services;Our OEM Partners;Insurance partners;Document signature partners;Dealer compliance partners (e.g., for registration and titling);Companies that offer co-branded services or products;Law enforcement and other governmental authorities;Analytics providers; andPublicly available sources.Note that if you seek to finance your vehicle, we will receive additional information from third parties in connection with the review of your application for financing, including credit reporting agencies (among others), as disclosed in our separate notices.

‍2. Payment Processing
‍When you make or receive payments via our Services, your credit card or other payment information is collected and processed by third-party payment processing services (Stripe) that comply with payment card industry standards. For example, if you pay with a credit card, the payment information that you provide through the Services is transmitted directly to our payment processor. We only receive limited information from our payment processors, and never receive or store full credit card or payment information.

‍3. Children’s Privacy
‍Our Sites and Services are not designed for or directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided personal information to Ekho through the Sites or Services, please contact support@ekhodealer.com and we will endeavor to delete that information from our databases.

‍4. How We Use Your Information
‍We use your personal information to:
Provide and manage the Sites.Process transaction(s) and provide and manage the Services.Provide support and communicate with you.Customize the Services for you.Measure usage and improve the Sites and Services.Maintain security and prevent fraud.Comply with our legal obligations.As otherwise necessary or appropriate.

‍5. When We Disclose Your Information
‍We disclose your personal information as described below:To our affiliates.To our service providers and partners.To government agencies.To our OEM Partners.To comply with legal requirements.In connection with a sale or business transaction.To others, at your direction or as necessary.

‍6. Third-Party Websites
‍Some links on the Sites or Services may redirect you to third-party websites and services that we do not operate. How these websites and services use your personal information is governed by their own privacy policies. We encourage you to review and understand their privacy policies before disclosing any personal information to them.

‍7. Information Security
‍We implement and maintain reasonable administrative, physical, and technical measures designed to safeguard and protect personal information under our control from unauthorized access, use, and disclosure. Nevertheless, because no data transmission or storage system is completely secure, we cannot guarantee the security of your information.

‍8. Processing in the United States
‍Ekho operates the Sites and Services in the United States and processes personal information in the United States. As such, when you visit the Sites or submit an inquiry, your personal information may be processed outside of the country or region in which you reside. Our Services are not intended for use outside the United States.

‍9. Your Choices
‍You have certain choices and may exercise certain rights with respect to our use of your personal information. Please note that rights and requests may be subject to applicable exceptions.Exercise your marketing choicesCalifornia Consumer Notice

‍10. Contact Information
‍You may contact us about this Privacy Notice or our privacy practices at support@ekhodealer.com or 130 Orchard Street, New York, NY 10002.

‍11. Changes to this Privacy Notice
‍The “Last Updated” date at the top of this page indicates when this Privacy Notice was last revised. We may from time to time update this Privacy Notice to reflect changes in our information handling and privacy practices or applicable law. If we make material changes to this Privacy Notice, we will provide you with notice of such changes (such as an updated notice posted on the Sites or a message delivered to the email address that we have on file for you).