Retromotive respects every User’s privacy, and we are committed to being transparent with you about how we handle personal data. This Privacy Policy explains how Retromotive collects, shares, and uses personal data you provide to us when you use the Retromotive Website or otherwise interact with us.

Our Terms of Use also govern your access to our Website and use of Retromotive Services. Please read this Privacy Policy carefully before accessing our website, or using any Retromotive Services. If you have any questions, please contact us at wheels@retromotive.co

Retromotive (“we,” “us,” or “Our”) respects the privacy rights of its users and understands the importance of protecting and handling information collected about you under both the law and best practice. This Privacy Notice has been composed for providing you with the information that you are entitled to (in case you are a private person, i.e. a data subject) according to Article 13 and Article 14 of EU General Data Protection Regulation, i.e., Regulation (EU) 2016/679 (“GDPR”), the Australian Privacy Principles (APPs) and the United States of America laws.

This Privacy Policy and the statement is created to explain to you how we collect your data, how we process them, how we secure them, how we might share them as regards to providing our services and how we store them. This Privacy Statement also describes what rights you have regarding your data, how you give your consent, and how to withdraw your consent.

• Overview

• Acceptance And Use

• Who We Are

• Summary of Personal Information and Use

• Purposes of Data Collection

• Data Protection Principles

• Types Of Data We Collect From You

• How We Collect Your Information

• Information We Collect Automatically

• Cookie Policy

• How We Use Your Data

• Data Subjects

• With Whom We Share Your Data

• Your Data Protection Rights

• Our Policy Towards Children

• Data Security

• Data Controller and Complaints

• Fraud and Crime Prevention

• Terms and Conditions

• Jurisdiction

• Changes to our Privacy Policy

• Contact Us

This privacy policy covers Retromotive and its subsidiaries (collectively, “Retromotive we, us, or our). Using our website, you signify acceptance to the terms of this Privacy Policy, which is considered your official consent to process your personal information, your consent to the collection, use, and disclosure of your personal information as described further below.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue your access to the Retromotive website, and its related services.

Retromotive provides a premium quarterly publication focused on cars, people and their stories. We have no allegiance to brand, badge or tribe. The magazines clean, uncluttered layout strips everything back to reveal an intimate journey through beautiful imagery and engaging stories.

If you appreciate beautiful design, emotive imagery and have a genuine thirst to explore insightful stories, then Retromotive has something for you.

We may collect or obtain Personal Data about you, and this information may be stored or processed within the United States Region through the following methods:

• directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you use the services or sign up for an account with us); We may also receive Personal Information about you from third parties.

For data collection methods as described by Retromotive in this privacy statement, the following examples of uses of this Personal Information may be used for:

• Provision of Services to you

• Offering and Improving the website,

• Surveys

• Communication

• Advertising

• User Engagement

• Marketing

• Legal Compliance

We collect, process, and use personal data (under the definitions of the European Union GDPR) and the United States of America Laws to provide our services. Personal data means any information that enables us to identify you, directly or indirectly, such as name, email, address, telephone number, any form of identification number, or one or more factors specific to you or your beneficiary’s identity.

We are committed to complying with applicable data protection laws and will ensure that personal data is:

• Used lawfully, fairly, and transparently;

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

• Relevant to the purposes we have told you about and limited only to those purposes;

• Accurate and kept up to date;

• Kept only as long as necessary for the purposes we have told you about;

We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious, philosophical beliefs, mental health, sexual life, or any other information that may be deemed to be sensitive (collectively, “Sensitive Personal Information”) in the ordinary course of our services. Where it becomes necessary to Process Sensitive Personal Information, we would rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Information where the processing is required or permitted by applicable law;

• Detection and prevention of Fraud: We may Process your Sensitive Personal Information where the processing is necessary for the detection or prevention of crime (including the prevention of fraud);

• Consent: We may Process your Sensitive Personal Information where we have, under applicable law, obtained your prior, express consent before Processing your Sensitive Personal Information.

• Persons under 13. The Services are not intended for use by under 13 years and therefore no one under the age of 13 should provide any Personal Information. If it is discovered that we have collected Personal Information from someone under 13 years, we will delete that information immediately.

While using Retromotive, we may ask you to provide us with certain, personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include but is not limited to:

• Name

• Date of birth

• Email address

location data that describes your device’s precise geographic location (“Precise Location Data”).

You may choose to provide us with additional personal information. For example, we may collect your name, email address, and other personal information when you fill out a survey, participate in a promotion, request customer support, or otherwise communicate with us.

We may collect or obtain User Information about you: directly from you (e.g., where you contact us); in the course of our relationship with you; when you make your Personal Information public (e.g., if you make a public post about us on social media); when you download, install, or use our website, wesbite or any of our Services; when you register to use any part of website or Services; or when you interact with any third-party content or advertising on the website, website or Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. Retromotive is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This policy does not cover the practices of third parties who may provide information about you to Retromotive.

When you use the Services, including when you visit our website, we automatically collect information about how you use the Services and the devices you use to access the Services. We may also generate information about you. Examples of the Information we collect automatically are:

• IP Address

• Location information – general location information from your computer or mobile device or precise GPS location information from your mobile device.

• Unique Identifiers, including MAC Address, Ad IDs, and device attributes, such as operating system and browser type, and usage patterns.

• Usage Data, such as weblog data, referring and exit pages and URLs, device type, number of clicks, domain names, landing pages, pages, and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar Information

We may Process your User Information by placing or reading Cookies and similar technologies on the Services. Certain tracking technologies enable us to assign a unique identifier to you and relate information about your use of the Services to Other Information about you, including your User Information, to learn more about you so we can provide you with relevant content and advertising. Our partners and Retromotive also use these technologies to analyse trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers, and video viewing history; supplement to our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns.

The cookies that we use fall into the following categories:

Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences.

Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We use various types of cookies (including some that we place and others which we permit third parties to place on our site) for a number of purposes. The information collected by cookies allows us to monitor how many people are using our services and their interactions with other services, how many people open our e-mails, and for what purposes these actions are being taken. Cookies are also used to facilitate a user’s log-in, as navigation aids, and as session timers, and to restrict underage use of our tools and services. We do not link non-personal information from cookies to personally identifiable information without permission. If for any reason you do not want us to track your use of our site using cookies, you can opt out of this using your browser settings and can also select the option “Do Not Track” (for more information please refer to your browser). Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar.

We use web beacons to collect information about the use of our services. The information collected by web beacons allows us to monitor how many people are using our services, how many people open our e-mails, and determine for what purposes these actions are being taken. Our web beacons are not used to track activity outside of our services.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

To find out how to manage cookies on popular browsers:

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

• Microsoft Internet Explorer

• Opera

• Apple Safari

We may Process User Information for the following purposes: providing the Services to you; communicating with you; providing advertising to you on the Services; analysing engagement with our audience; observing user engagement and purchase activity across the service; conducting surveys; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our Services.

The purposes for which we may Process User Information, subject to applicable law, include:

• Provision of the Services to You: providing the website, and Services to you from Retromotive or its partners.

• Offering and Improving the Services: operating and managing the. Website, and Services for you; providing personalised content to you; communicating and interacting with you via the website, and Services; identifying issues with the website, and Services and planning improvements, or Services; and notifying you of changes to any of our website, and Services.

• Surveys: engaging with you to obtain your views on our website, and Services.

• Communications: communicating with you via any means (including via email, telephone, text message, social media, post, or in-person) regarding other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

• Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties.

• Audience Engagement: identification and development of audience engagement, advertising, and promotional strategies on various site and channels, both within the service.

• Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.

• Investigations: detecting, investigating, and preventing breaches of policy, and criminal offenses, under applicable law.

• Legal Proceedings: establishing, exercising, and defending legal rights.

• Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of website, website and Services when we have grounds to believe that the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations.

Legal Bases for Processing your Information:

All data collected from you may be transferred or processed in the United States of America. When your data is collected, we rely on legal bases for processing your information under the California CCPA regulation. We will only process your data only when required. The processing is necessary to perform any contracts we entered with you for our legitimate interests to operate our business and protect the Retromotive website and services.

California’s “Shine the Light” law permits customers in California to request specific details about how certain types of their information are shared with third parties and, in some cases, affiliates for those third parties’ and affiliates’ direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt-out of this type of sharing.

To exercise a Shine the Light request, please contact us. You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. Please provide enough information to determine if this applies to you in the body of your request. Please note that we will not accept inquiries via telephone, email, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.

If you are a Nevada resident, you have the right to opt-out of the sale of specific Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us here or email us with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

Retromotive only shares your personal information with third parties under the circumstances described below. We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.

• Authorized vendors: We may share your data with third-party vendors that help us operate our application, deliver our services, and comply with your instructions and contractual obligations. These include payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM), vendors.

• Advertising and Analytics Partner: We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device.

• Business Partners: We sometimes partner with third parties to offer you our services and other programs. To participate in these services, you may be required to provide your email address and additional personal information. We will only share your data with a business partner when you expressly authorise us to do so.

• Certain legal obligations: Retromotive may be required to disclose personal information if directed by a court of law or other governmental entities. Without limiting the preceding, we reserve the right to disclose such information where we have a good faith basis to believe that such action is necessary to: comply with applicable laws, regulations, court orders, government, and law enforcement agencies’ requests, protect and defend Retromotive’s or a third party’s rights and property, or the safety of Retromotive, our users, our employees, or others, prevent, detect, investigate and take measures against criminal activity, fraud, and misuse or unauthorised use of our website and to enforce our Terms of Use or other agreements or policies, to the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.

• With Your Consent: Retromotive may send your personal information to a third party when you consent to do so or in your direction.

We enable you to make numerous choices about your data: Below is the following data protection rights you have when you use our services.

• You may choose not to provide us with certain information.

• Suppose you wish to access, correct, update or request deletion of your personal information. In that case, you can do so at any time by contacting us through the customer services portal or at the information provided at the bottom of this Privacy Policy.

• If you request access to your data, we will confirm whether we hold your information and provide you with a copy, explaining how we process it and why, how long we store it for, and your rights associated with it.

• If you request the deletion of your personal information, we will erase it. Please note that we will need to retain any information that we require to fulfill our legal obligations or establish, exercise, or defend a legal claim.

• You can object to your personal information processing, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us through the customer services portal or at the information provided at the bottom of this Privacy Policy.

• You have the right to opt-out of the email marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.

• Opting Out Of Messages from Us: To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message sent to you (found at the bottom of the email) or send an unsubscribe request to us. We will process your request within a reasonable time after receipt.

• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your personal information. Please contact us for more information, and we will send you a link or our data protection officer’s address.

• The easiest way to submit your request to us is through our Customer support email found at the bottom of this Privacy Policy. We respond to all requests we receive from individuals wishing to exercise their data protection rights under applicable data protection laws.

Retromotive complies with the Children’s Online Privacy Protection Acts COPPA. This policy provides us with authorisation to process and receive data from children under 13 years but with a parental guardian’s supervision. We do not knowingly request to collect personal information from any person under the age of 13. We do not permit anyone below 13 years of age to use our services and application.

We are committed to maintaining your data’s security, having measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorised individuals, and we regularly upgrade our security as better methods become available. Our data centers and our partners utilise new physical security measures to prevent unauthorised access to the facility. All personal data are also protected in a location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.

Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry-standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.

Retromotive are the data controllers for the personal data collected in connection with the services in the European Economic Area and US region. Retromotive is also the data controller for the personal data collected in connection with the use of Retromotive services anywhere else. We may also transfer data to third-parties who use Retromotive’s services. We do so to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, etc., or other transfer mechanisms as may be available under applicable law. For Questions, comments, and complaints about our data practices, please send a message or complaints to our Data Protection Officer nathan@Engage4x4.com.au.

Sometimes, Retromotive will use fraud and crime prevention strategies to ascertain if your personal information or accounts is being used for fraud or money-laundering.

If we think there is a risk of fraud, we may stop activity on the accounts or refuse you access to them. We might also check and share your information with fraud prevention agencies. If fraud is identified or suspected, these agencies may keep a record of that information and we may refuse to provide any services. Law enforcement agencies may access and use this information.

To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website.

The United States of America Laws, including the California Consumer Privacy Acts CCPA laws, will govern this privacy policy and terms of service, related to this website and services.

Retromotive continually strives to implement new technologies and processes to protect you better, your privacy, and your use of the Retromotive service. As a result, changes to this privacy policy may be made by Retromotive from time to time. In no event will these changes result in the degradation of any security measures designed to protect you from unauthorized disclosure.

If you have any questions about this privacy policy, please contact us at wheels@retromotive.co