Privacy Policy

VERSION: 11.15.2021

This Privacy Policy (“Privacy Policy”) describes how ReinventAuctions, Inc.
(“ReinventAuctions”) collects, uses and shares information when you use the Services (as defined
in Section 1) owned or operated by ReinventAuctions. The term ReinventAuctions includes any
subsidiary, affiliate, successor or assign of ReinventAuctions. The terms “you” and “your” mean
any person who views, accesses, uses, monitors, provides information to the Services, or obtains
information from the Services, including any authorized user approved to access the Services on
your behalf. By submitting information to ReinventAuctions, by conducting business with
ReinventAuctions, or by using the Services, you agree to the terms of this Privacy Policy and
expressly consent to the collection, processing, transmission, use, disclosure, posting, publishing,
making public, and sharing of your information for the purposes set out in the Services and in this
Privacy Policy. By accessing or otherwise using the Services, you acknowledge that you have
read, understood and agree to be legally bound by this Privacy Policy. If you do not agree to be
bound by this Privacy Policy, please cease accessing or using the Services.

The Services

ReinventAuctions provides: (a) a real-time business-to-business live
bidding and online wholesale auction service and related mobile and desktop applications and
services for Buyers and Sellers to list, sell, bid on, buy and transact upon (i) automotive vehicles
through the trading platform website located at https://dealer.reinventauto.com (“ReinventAuto”);
(ii) motorcycles, scooters, e-bikes, all-terrain vehicles, utility-terrain vehicles, off-road vehicles,
off-highway vehicles, low-speed vehicles, golf carts, snowmobiles, and personal watercraft
vehicles through the trading platform website located at https://dealer.reinventpowersports.com
(“ReinventPowersports”); (iii) recreational vehicles through the trading platform website located
at https://dealer.reinventrv.com (“RevinventRV”); (iv) marine vehicles, boats, watercraft, and
outboard motors through the trading platform website located at https://dealer.reinventmarine.com
(“ReinventMarine”); (b) the websites located at https://reinventauctions.com,
https://reinventauto.com, https://reinventpowersports.com, https://reinventrv.com,
https://reinventmarine.com; (c) all information, text, logos, icons, features, functions, integrations,
interfaces, images, pictures, photographs, graphics, sounds, videos or other materials contained in
subsection (a) or (b) above; (d) such ancillary services that ReinventAuctions performs in
providing a frictionless wholesale transactions; and (e) any additional service offerings, additions,
modifications, enhancements or updates provided by ReinventAuctions (collectively, subsections
(a) through (e) are, the “Services”). Each type of vehicle listed in the previous sentence shall be
collectively referred to and defined herein as “Vehicle(s).”

Privacy Policy Updates

ReinventAuctions may, from time to time, in its sole and
absolute discretion, relocate, update and modify the Privacy Policy which is hereby currently
posted at https://reinventauctions.com/privacy-policy.
The Privacy Policy will indicate the date posted, and the use of the Services by you after such posting will bind your
thereto. In the event there is any conflict or inconsistency between the current or any future Privacy Policy, the most
recently posted version shall prevail, supersede, and govern over any previous versions.

Information We Collect

ReinventAuctions uses information that is collected from the
Services for the following general intended uses and purposes:

• Personal identifiable information, including, but not limited to, names, email addresses,
  phone numbers, physical addresses, and such other information provided through the use
  of the Services.
• Dealership account information, including, but not limited to, dealer’s registration
  information, re-seller information, payment information, Vehicle purchases and sales, tax
  information, and such other information provided through the use of the Services.
• Vehicle information, including, but not limited to, information which ReinventAuctions
  may receive from a third-party inventory or dealer management system (“Dealer
  Management System”), VIN information, manufacturer/make/model/color/year
  information, standard equipment/options information, engine/transmission information,
  mileage or hours operated information, condition reports, descriptions, images, pictures,
  photographs, graphics, sounds, videos, history information, transaction information,
  payment information, title information, title transfer information, arbitration of disputes
  and such other information provided through the use of the Services, which shall be
  collectively referred to and defined herein as “Vehicle Information.”
• Any information ReinventAuctions may receive from Third-Party Service Providers (as
  defined in Section 13).
• Any information ReinventAuctions may receive from Third-Party Service Providers (as
  defined in Section 13).
• Any information which ReinventAuctions may receive from social media platforms,
  message boards, or blogging platforms used by the Services.
• Any Services usage, analytic, diagnostic, website session, application session, and esignature verification information, including, but not limited to, session identifiers, e-mail
  addresses, computer IP address, ISP or mobile carrier, locations, county of origin, operating
  system used, browser type used, type of devise used, sites accessed, pages accessed,
  Vehicles accessed, session history, session time, session date, other unique identifiers and
  such other information provided through the use of the Services.
• All communication between you and ReinventAuctions, including, but not limited to
  communication through the Services, email, text messages, short message services
  messages (“SMS”), multi-media message service (“MMS”), social media platforms,
  message boards, or blogging platforms used by the Services.

Information We Use

ReinventAuctions uses information that is collected from the
Services for the following general intended uses and purposes:

• To transmit, post, publish, advertise, market and promote information about you, other
  users of the Services, Vehicles, Vehicle transactions, and Vehicle Information to third
  parties to facilitate Vehicle transactions between you, other users of the Services, and third
  parties.
• To facilitate and complete Vehicle transactions, payments, title transfers, delivery,
  ancillary services, and the possible arbitration of disputes between you, other users of the
  Services, and third parties.
• To operate, provide, improve, enhance, protect, promote, market and advertise the
  Services.
• To operate, process, provide and establish accounts for you or other users of the Services.
• To communicate between ReinventAuctions, you, other the users of the Services, third
  parties, including, but not limited to communication through the Services, email, text
  messages, SMS, MMS, social media platforms, message boards, or blogging platforms
  used by the Services.
• To allow Third-Party Service Providers to assist ReinventAuctions to operate, provide,
  improve, enhance, protect, promote, market and advertise the Service.
• To facilitate ReinventAuctions’ evaluation, development, enhancement, modification, improvement and support of the Services.
• To facilitate ReinventAuctions’ internal record keeping, internal reporting, and support purposes.
• To verify the information that you, other users of the Services, or third parties provide to ReinventAuctions
  or through the Services.
• To verify, evaluate and/or monitor your creditworthiness.
• To authenticate the identity of you, other users of the Services, or third parties your for
  purposes of electronic signatures verification.
• To promote, market and advertise ReinventAuctions and the Services, including but not
  limited to, on Third-Party Sites (as defined in Section 12), through Third-Party Service
  Providers, through third parties, on social media platforms, message boards, or blogging
  platform used by the Services.
• To collect, compile and aggregate Vehicle transaction, Vehicle industry and Vehicle
  Information for use by ReinventAuctions or for the sale to third parties.
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• To investigate, prevent, protect, or take action regarding threatened, suspected or actual (a)
  violations of laws or illegal activities, (b) unethical or immoral activities, (d) financial
  injury, bodily injury, or death, (e) fraud or abuse, or (f) violations of ReinventAuctions
  terms or policies.
• To enforce or defend the rights of ReinventAuctions, including, but not limited to, in any
  legal, judicial, government or administrative proceedings.

Information We Share

ReinventAuctions may share information collected about you,
other users of the Services, Vehicles, Vehicle Information, and Vehicle transactions to (a) other
users of the Services and third parties for use on the Services, (b) Third-Party Service Providers,
(c) third parties outside of the Services, and (d) government, administrative and judicial
authorities, for the following general intended uses and purposes:

• To transmit, post, publish, advertise, market and promote information about you, other
  users of the Services, Vehicles, Vehicle transactions, and Vehicle Information to third
  parties to facilitate Vehicle transactions between you, other users of the Services, and third
  parties.
• To transmit, post, publish, advertise, market, promote and makes public on the Services
  information to facilitate Vehicle transactions between you, other users of the Services, and
  third parties.
• To facilitate and complete Vehicle transactions, payments, title transfers, delivery,
  ancillary services, and the possible arbitration of disputes between you, other users of the
  Services, and third parties.
• To communicate between ReinventAuctions, you, other the users of the Services, and third
  parties, including, but not limited to communication through the Services, email, text
  messages, SMS, MMS, social media platforms, message boards, or blogging platforms
  used by the Services.
• To promote, market and advertise ReinventAuctions and the Services, including, but not
  limited to, on Third-Party Sites, through Third-Party Service Providers, through third
  parties, on social media platforms, message boards, or blogging platform used by the
  Services.
• To operate, provide, improve, enhance, modify, improve, protect, promote, market,
  advertise and support the Services.
• To verify information you, other users of the Services, or third parties provide to
  ReinventAuctions or through the Services.
• To verify, evaluate and/or monitor your creditworthiness.
• To authenticate the identity of you, other users of the Services, or third parties your for
  purposes of electronic signatures verification.
• To investigate, prevent, protect, or take action regarding threatened, suspected or actual (i)
  violations of laws or illegal activities, (ii) unethical or immoral activities, (iii) financial
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  injury, bodily injury, or death, (iv) fraud or abuse, or (v) violations of ReinventAuctions
  terms or policies.
• To enforce or defend the rights of ReinventAuctions, including, but not limited to, in any
  legal, judicial, government or administrative proceedings.
• To respond to subpoenas issued in any legal, judicial, government or administrative proceedings.
• To sell compiled and aggregated Vehicle transaction, Vehicle industry and Vehicle
  Information to third parties. Any Vehicle transaction, Vehicle industry and Vehicle
  Information sold by ReinventAuctions will be anonymized to remove and will not contain
  any personally identifiable or Dealer account information.

Cookies and Similar Tracking Technologies

ReinventAuctions uses a number of
technologies to collect information from and about the devices you use to access the Services.
Your devices, depending on their settings, may also transmit location information to the Services.
A cookie is a small amount of data, which often includes an anonymous unique identifier, and is
sent to your browser from a device and are stored on your device (“Cookies”). Cookies are
required to use the Services and are used to record current session information. ReinventAuctions
may, from time to time, use similar technologies, including web beacons, pixel tags, flash objects,
location tracking and/or third-party widgets for purposes of enhancing the Services. You can set
your device to notify when you receive a Cookie, giving you the chance to decide whether or not
to accept it. However, if you do not accept Cookies, you may not be able to use all of the features
of the Services.

Security

ReinventAuctions uses commercially reasonable technical, physical and
administrative measures to protect the confidentiality, integrity and security of all information
collected in using the Services. ReinventAuctions cannot guarantee the security of your
information on the Internet and cannot guaranty the security of the information you provide will
not be accessed, disclosed, altered or destroyed by unauthorized persons. ReinventAuctions will
make all legally required disclosures of any breach of security, confidentiality or integrity of your
information, in a manner and within the time period required by applicable laws.
ReinventAuctions will cooperate and disclose information with government and law enforcement
officials, as may be necessary to enforce and comply with the law. However, it is your
responsibility to maintain the confidentiality of your password(s) and other user credentials. You
may be required to log-in to your ReinventAuctions account after a certain period of time has
elapsed to protect you against others accidentally accessing your account.

Retention, Data Storage and Transmission

All information you provide to
ReinventAuctions is secured on servers with restricted access. ReinventAuctionsreservesthe right
to use Third-Party Service Providers, who are bound by strict confidentiality guidelines, to perform
certain functions. ReinventAuctions will store your information for as long as there is a business
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need for it in accordance with applicable record retention policies and a range of legal, accounting,
financial, and regulatory recordkeeping requirements. Information may also be stored locally on
the devises you use to access the Services.

Opt-Outs, Changes and Questions

s. If you have any questions about this Privacy Policy
or its implementation, if you would like to update your information previously submitted to
ReinventAuctions, request to have outdated information removed, or withdraw consent to the use
or disclosure of your information, you may contact ReinventAuctions by sending an email to
support@reinventauctions.com. If you wish to stop receiving email communications from
ReinventAuctions, you may “unsubscribe” using the link at the bottom of the email you receive.
If you wish to stop receiving text messages or SMS communications from ReinventAuctions,
respond to the messages with the word “STOP.” However, the use of email, text messages and
SMS are an essential function of the Services, therefore, if you opt-out of emails, text messages,
or SMS you may not be able to use all the functionality of the Services. If you wish to be placed
on our postal mailing Do Not Contact list, you may contact ReinventAuctions by sending an email
to support@reinventauctions.com.

California Privacy Rights

If you are a California resident, the California Consumer
Policy Act (“CCPA”) provides you with certain rights concerning your information, including the
right to know how and for what purpose businesses collect it, the right to access your data, the
right to opt-out of it being sold to third parties and, subject to certain exclusions for legitimate
business purposes, the right to have it deleted. If you have further inquiries about your information
under the CCPA or wish to opt-out, please contact us by sending an email to
support@reinventauctions.com

Minor Child Use of Services

The Services are intended to use by an adult general
audience. The Services are not intended for use by, to solicit information from, or to market any
products or services to minor children or individuals under the age of eighteen (18). If
ReinventAuctions learns that any minor child or individuals under the age of eighteen (18) has
provided any information through the Services, ReinventAuctions will use commercially
reasonable efforts to promptly delete it.

Third-Party Websites

The Services may periodically link to third-party websites
(“Third-Party Sites”). This Privacy Policy governs only the Services, and this Privacy Policy
does not apply to Third-Party Sites. Any information collected or received by these Third-Party
Sites is subject to the Third-Party Sites’ privacy policies. If you decide to access any linked ThirdParty Site, you do so at your own risk. While ReinventAuctions has implemented this Privacy
Policy, ReinventAuctions cannot control, and are not responsible for, the manner in which any
Third-Party Sites use that information. Accordingly, you should review their privacy policies
before accessing or using any Third-Party Sites.

Third-Party Service Providers

The Services receive or may provide information to
Third-Party Service Providers to assist in the operation of and in providing the Services (“ThirdParty Service Providers”). ReinventAuctions will require any Third-Party Service Provider: (a)
to protect this information in a manner consistent with this Privacy Policy; (b) to use commercially
reasonable technical, physical and administrative measures to protect the confidentiality, integrity
and security of all information, and (c) to prohibit the use of the information for any purpose other
than to carry out the Services.

Jurisdictions

ReinventAuctions stores and processes and information in United States of
America. If you are located outside the United State of America, please note that information
collected via the Services may not provide an equivalent level of protection as the data protection
laws in your own country. ReinventAuctions make no representation that the Services or Privacy
Policy complies with the laws of any foreign jurisdictions, including the European Union’s
General Data Privacy Regulation. If you choose to provide us the Services from outside the United
States, you do so at your own risk and are responsible for compliance with any applicable foreign
laws.