SmartAuction Mobile Application Privacy Policy

This Mobile Application Privacy Policy is effective as of April 4, 2013

SmartAuction is a business-to-business provider of Internet-based auction and vehicle remarketing services to buyers and sellers of vehicles at wholesale and to their duly authorized agents and representatives. The SmartAuction service is not intended for consumer use.

This privacy policy governs your use, on a mobile device, of the SmartAuction software application ("Application") created by Ally Financial Inc. ("Ally"). The Application includes the ability to search vehicles, bid on vehicles and manage offers.

What information does the Application obtain and how is it used?

User Provided Information - The Application obtains the information you provide when you download and log in to the Application. Registration is mandatory prior to using the basic features of the Application.

When you register with us and use the Application, you generally provide and we collect: (a) your user name and password to authenticate your account; (b) transaction-related information, such as when you make purchases or respond to any offers; (c) information you provide us when you contact us for help.

Automatically Collected Information - In addition, the Application may collect certain information automatically, such as the type of mobile device you use, your mobile device’s unique device ID, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application such as the frequency and duration of usage.

Does the Application collect precise real time location information of the device?

No. This Application does not collect precise information about the location of your mobile device.

Do third parties see and/or have access to information obtained by the Application?

Yes. We may share your information with third parties only in the ways that are described in this privacy statement. We may disclose User Provided data and Automatically Collected Information:

What are my opt-out rights?

Opt-out of further information collection by uninstalling the Application - You can stop further collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Data Retention Policy

We may retain User Provided data for as long as you use the Application and for a reasonable time thereafter.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate SmartAuction or to develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes.

Your Consent

By using the Application, you are consenting to our processing of User Provided data and Automatically Collected information as set forth in this Privacy Policy now and as amended by us. "Processing" means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States.

Contact us - If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us at 877-273-5572.