This Privacy Policy ("Privacy Policy") applies to the tools, features, and services (collectively, the "Services") offered by Vroom, Inc., or its subsidiaries, including Left Gate Property Holding, LLC d/b/a Texas Direct Auto or Vroom (together, "Vroom", "we", "us", or "our"), through any Vroom website, including Vroom.com and Texas Direct Auto.com (together, "Sites") or Vroom mobile applications ("Apps"), as well as offline interactions with you related to your sale, trade, purchase or financing of a vehicle through Vroom.

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent to our collection, use and sharing of your information as described in this Privacy Policy. Also, your use of Vroom's Services is subject at all times to our Terms of Use, which incorporates the Privacy Policy. Unless otherwise stated, any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here.

When you use the Services, Vroom and our third-party service providers may collect information about you and the device(s) you use to access the Services. We collect a variety of information, such as:

• Account Information and Other Information You Provide Voluntarily. You may create an account through the Services and, if you do so, we will collect your name, email address, login information and telephone number. We also may collect your address for vehicle registration, pickup or delivery, as well as certain documents required for financing or to complete registration, where applicable. Further, we collect any additional information that you voluntarily provide to us directly or through the Services, such as when you communicate with us in person or by email, text message, telephone or chat, ask us a question, respond to our surveys, post comments, or provide reviews or testimonials.
• Vehicle Information. If you are interested in selling or trading in your vehicle to Vroom, you may obtain a vehicle appraisal from us through the Services. In order to provide an appraisal, we request and collect your Vehicle Identification Number ("VIN"), vehicle history, and information about the condition of your vehicle. We also will request your name and contact information to contact you about the appraisal.
• Financial Application Information. When you submit an application to third-party lenders through the Services to finance a vehicle purchase from Vroom, or for a pre-qualification for financing, we collect information such as your name, email address, telephone number, date of birth, address, employment and income information, veteran or military status, and social security number. Depending on the lender's requirements, we may need to collect additional information from you.
• Credit Report Information. When you submit an application for pre-qualification or financing, we use a third-party service provider to request credit report information from consumer reporting agencies to determine your eligibility for financing. This information may include your credit or FICO score and other information in your credit file.
• Payment or Other Financial Information. When you make a purchase or sell us a vehicle through the Services, we may collect your credit card information or bank account information, such as the name and contact information of your financial institution, account type, account number, and routing number. Your credit card information is processed and stored by a third-party service provider.
• Commercial Information. When you use the Services, we collect information about the transactions you conduct with us, such as vehicle purchases and appraisals, and about the vehicles that you have searched for or otherwise expressed or indicated an interest in.
• Location Information. With your consent, our Apps may collect geolocation information from your device in order to tailor our Services to you, for example, showing you vehicles closer to your location. You may opt out of location sharing by accessing the location settings on your device and setting your device not to share its location with us.
• Information Provided by Third Parties. When you view and make inquiries about Vroom vehicle listings posted on sites other than the Vroom Sites, we will receive the information you submit in connection with your inquiry, such as your name, email address or phone number. We also may receive information about you from other third parties, including, without limitation, social media platforms, marketing vendors, data analytics companies or data brokers, vehicle history services, government agencies, including Departments of Motor Vehicles, reputation and identity verification services, and insurance companies.
• Information Collected Automatically. When you use the Services, we or our third-party service providers may automatically receive and record certain information from your device or through the Services. For example, this may include your device's IP address, user-agent, web pages you visit or features you use within the Services, the date and time of your activities on the Services, time since your last visit, links you click, searches conducted, the website visited before navigating to the Services, your software and hardware attributes (including browser and operating system type and version, app version, device type, and device identifiers), demographic and interest data based on browsing activity, and your general location inferred from your IP address. To obtain such information, we or our third-party service providers may use the following technologies to recognize your device and collect information about your device and Services usage:
  • Server Logs: When you use the Services, we automatically receive and record certain information from your computer or other device and your browser. To obtain such information, we may use the server logs or applications that recognize your device and gather information about its online activity.
  • Cookies: Cookies are small files that are stored on your device by your web browser. The cookies we may use include session cookies (which expire once you close the browser) and/or persistent cookies (which stay on your browser and may be used by the browser on subsequent visits to the Services, unless deleted by you). Cookies allows us to recognize whether you have visited before and may store user preferences and other information. If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.
  • Web beacons, tags, and similar technologies: The Services or the emails that you receive from us may use an application known as a "web beacon" (also known as a "tag" or "pixel") and similar technologies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For example, it may allow an email sender to determine whether a user has opened a particular email.
  • Unique Identifiers: We may use unique identifiers to collect information about your use of the Services on an individual basis, such as length of time spent on a particular page and pages viewed during a particular log-in period. We use this information to evaluate and improve the Services. These may include, for instance, a unique identifier associated with a cookie stored on your browser. It may also include a mobile advertising identifier associated with your mobile device, such as Apple's Identifier for Advertisers ("IDFA") and Google's Advertising ID. We may use mobile advertising identifiers to collect information for interest-based advertising and analytics purposes, as described in the section below titled "Analytics and Interest-Based Advertising."
  • Local Storage: We use Local Storage Objects ("LSOs") such as HTML5 to store content information and preferences. Your browser may offer its own management tool to manage LSOs.
• Feedback and Surveys. From time to time we may ask you to complete surveys or provide feedback to help us improve our Services. If you choose to participate in one of our surveys or provide feedback, we collect the information you provide as part of that survey. Participation is compeltely voluntary, and you therefore have a choice whether to disclose your information.
• Resume or Job Application Information. If you submit an application for employment with Vroom, we will collect your resume and any other information you provide to be considered for a position. In order to submit an application, we may direct you to a third-party service provider through which you will submit your materials.

The specific information actually collected by Vroom and its third-party service providers will depend on the portion of the Services you access.

We and our third-party service providers use the information collected for a variety of purposes. For example, to:

• Provide the Services. To provide our Services to you, carry out the transaction(s) you request, conduct credit checks to determine whether you qualify for financing, fulfill and enforce the terms of any agreement you have with us, process payments, respond to your requests or inquiries, conduct internal recordkeeping, and secure your information and our Services to you.
• Communicate with you. To communicate with you regarding the Services, your purchase or sale of a vehicle, your application for financing, your purchase of warranties or other ancillary products, and to respond to your questions or requests concering the Sites, Apps or the Services offered by us.
• Consider you for employment with us. To consider your application for employment with us.
• Send marketing materials or other promotional messages. To send you marketing materials or other promotional messages via mail, email, text, push notifications or other methods regarding our Services or other products or services offered by our Business Partners that may be of interest to you.
• Tailor our content and advertisements. To Tailor content on the Sites and Apps and target our advertising, including as described in the section below titled "Analytics and Interest-Based Advertising."
• Conduct analytics and improve our Services. To count and recognize users of the Services, analyze how the Services are used, improve the Services, create new products and services, and conduct analytics, including as described in the section below titled "Analytics and Interest-Based Advertising."
• Compile aggregated and de-identified information. To compile aggregated and de-identified statistics or reports that we may share with our Business Partners or other third parties.
• Protect Vroom, You, or Others. To protect, investigate, and deter against fraudulent, harmful, unauthorized or illegal activity, or otherwise as we believe to be necessary to protect the rights, property, or safety of Vroom, our employees and contractors, you or the general public.
• Legal purposes. For legal or other necessary purposes, including as decribed below in the section titled "Vroom's Sharing of Information with Third Parties."
• Lawful business purposes. Where permitted by law, for other purposes related to managing our business.

We may share the information we collect or receive about you with third parties for a variety of reasons, including as follows:

• Affiliates. We may share your information with our corporate affiliates for the purposes described in this Policy.
• Service Providers. Vroom may share your information with third-party service providers who perform services on our behalf, such as:
  • Vehicle inspectors
  • Vehicle history providers
  • Vehicle listing and advertising platforms
  • Reconditioning service providers
  • Suppliers
  • Sales management database providers
  • Customer contact center and phone support providers
  • Payment processors
  • Credit check providers
  • Lenders
  • Financing services companies
  • Shipping providers
  • Email and other marketing and promotion vendors
  • Customer data aggregator platforms
  • Media and marketing agencies
  • Web hosting services
  • Operating systems and platforms
  • Data analytics and advertising providers
  • Survey providers
• Government Agencies. We may share your information with government agencies, including Departments of Motor Vehicles, in order to complete your transaction(s).
• Business Partners. We may share information about you with vendors, lenders, financial services companies, vehicle listing and advertising platforms, and other third parties with which we have a commercial relationship ("Business Partners") to fulfill your request for Services; to meet the terms of any agreement that you may have with us or our Business Partners; to share promotions with you; for Business Partners to contact you directly about their products and services; for benchmarking and data analytics by Vroom or our Business Partners; or to manage our business. In particular, we share your credit application details with certain Business Partners in connection with your request for financing.
• Third-Party Plugins. The Services integrate certain third-party plugins. Even if you do not click on these plugins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.
• Other Users or the Public. Your reviews and testimonials may be publicly viewable or viewable by anyone who uses the Services. Therefore, if you upload or share any information as part of a review or testimonial, unless otherwise expressly stated by Vroom, such information may become publicly available. This means that the information may be collected, used, or redistributed by others, so please proceed with caution before providing any sensitive or confidential information as part of a review or testimonial.
• Customized Audiences and Similar Programs. We may partner with Facebook, Google and other social media and social marketing partners to deliver advertisements to our users via the Facebook Custom Audiences program, Google Customer Match or similar third-party programs. In order to identify and reach our users on Facebook, Google or another third-party service, we may share your information with Facebook, Google or another third-party service. For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media or social marketing providers.
• Legal Purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
  • To comply with applicable law or a court order, subpoena, or other legal process;
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situation involving threats to our property or the property or physical safety of any person or third party; or
  • To establish, protect, or exercise our legal rights or defend against legal claims.
• Organizational Transfers. In the event of a merger, sale of assets, sale of equity, investment, reorganization, bankruptcy, consolidation, or similar transaction, we may share information we possess to facilitate the transaction, including during due diligence, or as a corporate asset transferred to the acquiring entity. You acknowledge that such sharing and transfers may occur, and that any acquirer of us or our assets may continue to use your information as set forth in this Policy.
• Aggregated and De-Identified Information. From time to time, Vroom may also share aggregated or de-identified information about users, such as by publishing reports on trends in the usage of the Services.

We partner with certain third parties to collect information to engage in analytics, auditing, research and reporting. These third parties may use server logs, web beacons, tags, pixels, mobile advertising IDs (such as Apple's IDFA or Google's Advertising ID), and similar technologies, and they may set and access cookies on your computer or other device. In particular, our Services use Google Analytics to help collect and analyze certain information for the purposes discussed above. You may learn more about Google Analytics' data practices by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here.

We may also use analytics providers that engage in heat mapping and that record mouse movements, clicks, scrolls, and keystrokes during your use of the Services. These analytics help us identify and address technical issues and understand usage of our Services, which we use to improve the Services for you.

We also partner with third parties to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites, mobile apps and devices (commonly referred to as "interest-based advertising"). Our advertising partners may collect information about your activities on our Services on your current device and combine it with information about your activites on other websites, mobile apps, and devices. They may collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Apple's IDFA or Google's Advertising ID), cross-device linking, and similar technologies. For example, our advertising partners may use the fact that you visited our Sites to target advertising to you on non-Vroom websites and mobile apps on your current device or on other devices you use. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies, and not this Policy. You can opt out of interest-based advertising in web browsers and mobile apps on your current browser or device by following the instructions below.

• Web Browser Opt-Out. To opt out in web browsers, please visit optout.aboutads.info and optout.networkadvertising.org. To help preserve your choices, you can install the "Protect My Choices" extension that is available at http://www.aboutads.info/PMC.
• Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the advertising preferences on your mobile device. For example:
• In iOS 7+, visit Settings > Privacy > Advertising > Limit Ad Tracking.
• In Android, visit Settings > Google > Ads > Opt out of interest-based ads or Opt out of Personalized Advertising.

You can also opt out for participating companies by downloading the Digital Advertising Alliance's AppChoices tool here at and following the instructions in the app. For more information about opting out on mobile devices, please click here.

Please note that the opt-outs described above will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile advertising identifiers, change browsers (including upgrading certain browsers), or use a different device, any opt-out cookie or tool may no longer work and you will need to opt out again. If you choose to opt out, you will still see advertisements while browsing online, however the advertisements may be less relevant to you and your interests. Although our Services currently do not respond to "do not track" browser headers, you can limit tracking by these third parties and by taking the steps discussed above.

If you want to limit our collection and/or use of your information, you have several choices, including:

• Limiting Information provided to Vroom:

  You can always opt not to disclose certain information to us; however, if you choose not to provide us with certain information, you may not be able to access certain features or services.

• Terminating your Account(s):

  You may be able to limit our collection and use of some of your information by terminating your Account(s) on the Services.

• Your choices for Advertising:

  You can opt-out of the collection of information by certain third parties as described in the section above titled "Analytics and Interest-Based Advertising." Most browsers will allow you to erase cookies from your computer's hard drive or from your device, block acceptance of cookies or receive a warning before a cookie is stored. You may also be able to erase or disable other tracking technologies using the settings of your browser or mobile device. However, please note that if you block or erase tracking technologies then our Services (and your experience) may be limited.

You may opt-out of receiving emails from us by clicking "unsubscribe" at the bottom of the message. Please note that if you unsubscribe from our marketing communications, you will still receive administrative messages.

If you are registered for an Account, you can access and modify certain information associated with your Account by logging into the Sites. If you want to learn more about the information that Vroom has about you, you may do so by contacting us at privacy@vroom.com.

If for any reason you wish to close your Account or delete your information, you can email privacy@vroom.com and we will make reasonable efforts to submit to your request, subject to applicable laws, rules, regulation or court order. Please note that unless you instruct us otherwise, or as set forth in this Privacy Policy, we may retain and use information collected from you after termination of your Account, for as long as reasonably required, for the purposes of which such information was collected, including, without limitation, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms or Privacy Policy, all as permitted under any applicable privacy laws. Aggregate and/or anonymous information derived from your Account and/or use of the Services may remain on our servers indefinitely.

The Services may contain links to third-party websites. If you follow a link to any of these websites, please note that these websites, and any services that may be accessible through them, have their own privacy policies. We are not responsible for the privacy practices of other websites. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites. This Privacy Policy applies solely to information collected in connection with the Services.

The Services are directed to users in the United States. We currently only buy and sell vehicles in the United States. The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. Vroom also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any information to us, you expressly consent to such transfer and processing.