Privacy Policy

Last modified: January 29, 2021

Introduction

Atturo Tire ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.atturo.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

· On this Website.

· In email, text, and other electronic messages between you and this Website.

· Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

· When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

· Us offline or through any other means, including on any other website operated by Company or any third party; or

· Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. This privacy policy is not a contract and does not create any legal rights or obligations.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

· By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");

· That is about you but individually does not identify you; and/or

· About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

· Directly from you when you provide it to us.

· Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

Personal information does not include:

· Publicly available information from government records.

· Deidentified or aggregated consumer information.

· Information excluded from the CCPA's 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), clinical trial data, or other qualifying research 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.

Information You Provide to Us.

The information we collect on or through our Website may include:

· Information that you provide by filling in forms on our Website. This includes information provided at the time of posting material or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website. For example:

o The Website gives you the ability to locate an Atturo dealer near you through the Dealer Locator. Atturo will ask for your postal code to identify a dealer near your location.

o The Website also includes the ability to submit photos to post as part of the Vehicle Gallery. Atturo will ask for your name, email, vehicle and tire information, accessories, and primary use.

o The Website allows you to submit questions, comments or concerns to us. Atturo will ask for your name, email, phone number and your message.

o The Website also includes the ability for dealers to access brand files. Atturo will ask for the unique login for each dealer.

· Records and copies of your correspondence (including email addresses), if you contact us.

· Your responses to surveys that we might ask you to complete for research purposes.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

· Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

· Estimate our audience size and usage patterns.

· Store information about your preferences, allowing us to customize our Website according to your individual interests.

· Speed up your searches.

· Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

· Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

Third-Party Use of Cookies and Other Tracking Technologies

This document only addresses the use and disclosure of information we collect from you. During your visit to this Website, you may view links that will take you to third party websites. These third party websites are not subject to Atturo's Privacy Policy. Different rules may apply to their use or disclosure of the personal information you disclose to them. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:

3250 N. Oak Grove Ave.
Waukegan, IL 60087

info@atturo.com

(855) 632-8031

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

· To present our Website and its contents to you.

· To provide you with information, products, or services that you request from us.

· To fulfill any other purpose for which you provide it.

· To provide you with notices about your account, including expiration and renewal notices.

· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

· To notify you about changes to our Website or any products or services we offer or provide though it.

· To allow you to participate in interactive features on our Website.

· In any other way we may describe when you provide the information.

· For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

· To our subsidiaries and affiliates.

· To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Atturo Tire 's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Atturo Tire about our Website users is among the assets transferred.

· To fulfill the purpose for which you provide it.

· For any other purpose disclosed by us when you provide the information.

· With your consent.

We may also disclose your personal information:

· To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

· To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Atturo Tire, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

· Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

· Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt out by sending us an email stating your request to info@atturo.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@atturo.com.

Accessing and Correcting Your Information

If you have given Atturo information in the past and wish to change or delete such information, please contact Atturo at: info@atturo.com or by telephone at (855) 632-8031.

Notice to International Users

The Website is intended for users in the United States. If you choose to visit the Website or otherwise provide Atturo with your information, you consent to the transfer and storage of that information on our servers located in the United States and around the world. The information collected by Atturo may be subject to international and U.S. state and federal law. If you are accessing our Website from outside the U.S., please be advised that you are transferring your personal information to us in the United States where data protection and privacy laws may be different than the laws of your country. By using our website, you consent to the transfer and use of your personal information in accordance with this Policy.

Notice to California Consumers

If you reside in the United States in the State of California, we are required by California law to provide you with additional information about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy. Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.

Our Website has collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Description	Collected
A. Identifiers.	We collect your name, phone number, vehicle information, and email address when you submit a photo to the Vehicle Gallery or submit a question or comment through Atturo's website. We collect your IP address automatically when you use our services. We collect your device identifier automatically when you use our services.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	We collect your name, phone number, vehicle information, and email address when you submit a photo to the Vehicle Gallery or submit a question or comment through Atturo's website.	YES
C. Protected classification characteristics under California or federal law.	We do not collect information about your age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	When you engage in transactions with us, we create records of goods or services purchased or considered as well as purchasing or consuming histories or tendencies.	YES
E. Biometric information.	We do not collect information about your genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	We collect information about your browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	We collect your IP address automatically when you use our services. We may be able to determine your general location based on your IP address.	YES
H. Sensory data.	We do not collect audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	We do not collect current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	We do not collect education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	We do not profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Our Website obtains the categories of personal information listed above from the following categories of sources:

· Directly from you. For example, from forms you complete or products and services you purchase. Source category types may include

· Indirectly from you. For example, from observing your actions on our Website.

CCPA Notice: Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

· To provide, support, personalize, and develop our Website, products, and services.

· To create, maintain, customize, and secure your account with us.

· To process your requests, purchases, transactions, and payments and prevent transactional fraud.

· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

· To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

· For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

· As described to you when collecting your personal information or as otherwise set forth in the CCPA.

· Marketing to our customers on social media.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

CCPA Notice: Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. We do not sell your personal information.

CCPA Notice: Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

· The categories of personal information we collected about you.

· The categories of sources for 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.

· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

· sales, identifying the personal information categories that each category of recipient purchased; and

· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

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

We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

· Calling us at (855) 632-8031

· Emailing us at info@atturo.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent contact us at the information listed above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

· First and last name.

· Email address.

· Zip code.

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability 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, specifically in electronic form to be sent to the email address provided by the consumer making such request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

Atturo Tire does not sell personal information of its customers to third parties for monetary gain. However, we provide customers the ability to exercise the right to opt-out or opt-in to the sale or disclosure of their personal information in compliance with the California Consumer Privacy Act.

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by:

· Calling us at (855) 632-8031

· Emailing us at info@atturo.com

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting Atturo. You do not need to create an 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.

CCPA Notice: Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@atturo.com.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Atturo Tire collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Phone: (855) 632-8031

Email: info@atturo.com

Postal Address:

Atturo Tire

Attn: Customer Service

3250 N. Oak Grove Ave.

Waukegan, IL 60087