GSM Privacy Policy

Introduction

Your privacy concerns and trust are important to us. This Privacy Policy has been prepared to help
you understand what information is collected through your interactions with us on our websites or anywhere this Privacy Policy is posted, and how this information is used. If you have questions
about this Privacy Policy, you may contact us at privacy@forcemarketing.com. To the extent
permitted by applicable jurisdiction, by accessing the website for us or anywhere this Privacy Policy
is posted, you consent to this Privacy Policy. 

This Privacy Policy describes our privacy practices for data that we collect:

• through our website (the “Website”);
• through our social media pages that we control, if any (collectively, our “Social Media
Pages”), and
• through our mail and email messages and through direct communications with us.

Collectively, we refer to the above as the “Services”. Force Marketing and our related entities, strive
to make our websites and online resources useful tools and rewarding experiences for our
customers by tailoring the content to your personal needs and interests.

This way, the content of our online interactions will be as relevant as possible for you.

With respect to unrelated, third party websites, such as third party online retailers, advertisers, or
unrelated sites that we may happen to link to, or web sites that link to our website, those third
parties may collect personal information directly from you. The information policies and practices
of these unrelated parties are not covered by this Privacy Policy. We do not control the privacy
policies of third parties even if we may provide hyperlinks or other access to their web sites. We are not responsible or liable for their independent policies and practices. Please review their privacy
policies and practices. It is your responsibility to review them and decide if you are satisfied with
their protections. For persons with disabilities, please email us at privacy@forcemarketing.com for
further guidance on Force Marketing’s Privacy Policy.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will
notify you of changes to this Privacy Policy. If we make any material changes, we will notify you by
email (sent to the e-mail address specified in your account) or by means of a notice on our Services
prior to the change becoming effective. We may provide additional “just-in-time” disclosures or
additional information about the data collection, use and sharing practices of specific Services.
These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your personal information.

What Personal Data Is Collected by Force Marketing?

Personal information is data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. When you interact with us, at various points we may collect your personal information in accordance with the law. You may choose not to provide certain personal information; however, your interactions with us may be limited, or you may be unable to access certain functionalities of our Services. Below we have listed the categories of personal information that we may collect from you. If you decide to provide us with your email address in order to sign up for notifications regarding specials, news and tips, we will use your email address only for the purpose of communicating with you regarding our specials, news and tips, and we will not sell or otherwise transfer your email address to any third party. We will engage or plan to engage certain trusted third parties to perform services for us, including, without limitation, services relating to hosting and maintenance, customer communications, customer relationships, quality assurance testing, and database storage. We will only provide your email address to these third party service providers to the extent necessary for them to provide the services to us for which they have been engaged.

We may maintain:
• Contact Information. Your first and last name, email address, postal address, phone
number, user name, password, social media handle or other similar contact information.  We may also collect your signature and employer information.
• Survey Information. The information you provide in response to a survey that you choose to
respond to.
• Demographic Information. Demographic information, such as your geographic location,
date of birth, anniversary date, or any other significant date.
• Online Interactions. We collect aggregated analytics data about website visitors, such as
your internet protocol (IP) address, location information, when you use our Website or
interact with us through social media.
• Personal Information Received From Third Parties. We may receive some of the above sated
personal information about you from third parties such as social media sites, through
technology such as cookies, and when you use third party agents or third party services to
make requests for information.

How We Collect Personal Data

We collect personal information in the following manner:

Personal information that you provide:

• Online Interactions. We may collect personal information from you when you visit our
website, interact with us on Social Media, or send us requests over emails.
• Direct Interactions. We may collect personal information from you when you visit our
locations, tell us your preferences, or schedule an appointment.
• Other Sources. We collect personal information from other sources, such as public
databases, joint marketing partners and other third parties.

Personal Information that we collect from you automatically

We use certain tracking technologies to improve the functionality of the websites and your
experience when you access it. We also keep a record of third party websites accessed when you
are on our website and click on a hyperlink. However, we do not track users to subsequent sites and do not serve targeted advertising to them. We do not, therefore, respond to Do Not Track (DNT) signals. If you connect to our site using a mobile device, we may collect device information, including the device ID, model and manufacturer; the operating system; the location (to the city level), and the IP address. We also use Google Analytics to track how often people gain access to or read our content. We use this information in the aggregate to understand what content our site visitors find useful or interesting, so we can produce the most valuable content to meet their needs.  We will also use third parties, including but not limited to Google Analytics, who will use cookies or similar technology to transmit information about you and your use of our website, such as your browser type, search preferences and other data.

We will also use the information collected to retarget and remarket to you.

Anonymized and Aggregated Data

Anonymization is a data processing technique that removes or modifies personal information so
that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e.
information about our customers (i.e., you) that we combine together so that it no longer identifies
or references an individual customer).

We may use anonymized or aggregate customer data for any business purpose, such as to better
understand customer needs and behaviors, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties. Types of data we may anonymize include contact information, survey information, and demographic information.

How Does Force Marketing Process or Use Personal Data?

We use the personal information we collect to communicate with you, provide the products or
services you have requested, understand your needs, provide you with a better service, and in
particular, for the following purposes:

• To conduct transactions you request.
• To respond to your questions and to contact you, and to provide notice about the status
of our website or the specific services you have requested.
• To assist us in providing better information, and to help us improve our website and
services.
• To learn more about our website traffic patterns and other use in order to improve the
functionality and features of our website.
• To help us operate, maintain and improve our systems, our website, and your user
experience.
• To facilitate corporate acquisitions, mergers or transactions.
• To send you information about Force Marketing and its related companies, which may or
may not relate to the reason for which you interacted with us. You may unsubscribe or
opt out of marketing-related communications or emails from us by clicking the
unsubscribe link on any email marketing communication you receive; however, you may
not be able to optout of receiving critical Service-related communications.

We do not collect any categories of personal information beyond the categories of personal
information outlined above, and not for the purposes other than outlined above. If we plan to
collect and use personal information for any purposes beyond the ones outlined in this notice,
additional consent needs to be obtained prior to use.

How and Why Does Force Marketing Share Personal Data with Third Parties?

Force Marketing does not sell, rent, or share personal information to or with any third party not
affiliated with, related to or owned by Force Marketing, except service providers who may assist us in such areas as our promotions, credit checks, data storage and order processing, as further
detailed below. Force Marketing will never give or sell your personal information to unaffiliated third
parties to be used for the purposes of sending you unsolicited commercial offers. We do not share
personal data about you with third parties except as follows:

• With service providers under contract who help with parts of our business operations.
Our contracts require these service providers to only use your information in connection
with the services they perform for us, and prohibit them from selling your information to
anyone else.
• Examples of the types of service providers we may share personal information with
include: (a) Network infrastructure; (b) Cloud storage; (c) Payment processing; (d)
Document repository services; (e) Sales; (f) Website Management; (g) Accounting; (h)
Customer Support; (i) Internet (e.g. ISPs); (j) Data analytics; (k) Information Technology.
• With our professional advisors who provide banking, legal, compliance, insurance,
accounting, or other consulting services in order to complete third party financial,
technical, compliance and legal audits of our operations or otherwise comply with our
legal obligations.
• -When required by law, or if we have a good faith belief that such action is necessary to:
(a) to identify, contact or bring legal action against someone who may be causing injury
to or interference with (either intentionally or unintentionally) our rights or property,
customers or other users of our website, or anyone else who could be harmed by such
activities; (b) to respond to judicial process and provide information to law enforcement
agencies or in connection with an investigation on matters related to public safety, as
permitted by law, or otherwise as required by law, or (c) to transfer your information as a
business asset in the event we or our related entities sell or buy other businesses or
entities, or we or substantially all of our assets are acquired.
• Administrative, technical or marketing purposes: We will share information with third
parties, business partners or related entities, subject to confidentiality agreements as
appropriate, for research and analytical purposes; for administrative or technical
support or other business purposes, or to analyze our data or to maintain and improve
our services or your user experience. We may also share aggregated information about
our customers with our advertisers and our marketing partners. We may share website
usage information about visitors to our website with third party advertising companies.
• Consent: We also share personal data with third parties, other than those described
above, when we have your consent to do so.

What Personal Data Rights Do You Have?

Depending on applicable law where you reside, you may be able to assert certain rights related to
your personal information identified below. If any of the rights listed below are not provided under
law for your jurisdiction, we have absolute discretion in providing you with those rights.
Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d)
where the request is frivolous or vexatious, or for other reasons.

Access and portability. You may request that we provide you a copy of your personal information
held by us. This information will be provided without undue delay. In certain circumstances, you
may request to receive your personal information in a structured, commonly used and machine-
readable format, and to have us transfer your personal information directly to another data
controller. To request access, see HOW CAN YOU EXERCISE THESE RIGHTS below.

Rectification of incomplete or inaccurate personal information. You may request us to rectify or
update any of your personal information that we have. You may do this at any time by contacting us
at privacy@forcemarketing.com.

Erasure or deletion. You may request to erase or delete your personal information, subject to
applicable law. To request erasure or deletion, see HOW CAN YOU EXERCISE THESE RIGHTS below.

Withdraw consent. To the extent the processing of your personal information is based on your
consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness
of your processing based on consent before your withdrawal. You may withdraw your consent by
contacting us at privacy@gsmarketing.com.

Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or
object to us processing your personal information under certain circumstances. We may continue
to process your personal information if it is necessary for the defense of legal claims, or for any
other exceptions permitted by applicable law.
Automated individual decision-making, including profiling. We do not rely on automated individual
decision-making or profiling tools.

How to make a privacy request

To make a privacy request, see the “HOW YOU CAN EXERCISE THESE RIGHTS” section below.

How to lodge a complaint

If you believe that we have infringed your rights, we encourage you to first submit a request by
sending us an email at privacy@forcemarketing.com, so that we can try to resolve the issue or dispute informally.

If you reside in the EU, you can file a complaint with your relevant data protection authority.
If you reside in the European Economic Area, United Kingdom, or Switzerland (collectively, “EEA
Residents”), you have additional rights with respect to your personal data, which include rights
under the EU’s General Data Protection Regulation (“GDPR”).

If you reside in California, USA, you have additional rights with respect to your personal information as granted by the California Consumer Privacy Act (“CCPA”).

California Privacy Rights

In addition to the rights provided for above, if you are a California resident, the California Consumer
Privacy Act provides some California residents with the additional rights listed below. To exercise
these rights see the “HOW YOU CAN EXERCISE THESE RIGHTS” section below.

Right to Know. You have the right to know and see what data we have collected about you over the
12-month period, including:

- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting your personal information; -The
categories of third parties with whom we have shared your personal information; and -The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request that we delete the personal information we have
collected from you (and direct our service providers to do the same). There are a number of
exceptions, however, that include, but are not limited to, when the information is necessary for us
or a third party to do any of the following:

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Fix our system in the case of a bug;
• Protect the free speech rights of you or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546
et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public
interests that adheres to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context
in which you provided it.

Other Rights. To the extent we sell your personal information to third parties, you also have the right
to request that we disclose to you: (i) the categories of your personal information that we sold, and
(ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. We do not sell your personal information in the
ordinary course of business and will never sell your personal information to third parties without
your explicit consent.

You will not receive discriminatory treatment by Force Marketing for exercising the above individual rights. Prohibited discriminatory treatment includes denying goods or services, charging different prices or rates for goods or services (including discounts or other benefits or imposing penalties), providing a different level or quality of goods or services to you, or even suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

How Can You Exercise These Rights?

To exercise access and deletion rights, email us at privacy@forcemarketing.com to submit a
request.

• If you are a consumer who has or may receive marketing materials from us, email
privacy@forcemarketing.com to submit a request.
• If you are a job applicant or a current or former FORCE MARKETING employee, email
careers@forcemarketing.com to submit a request.
• If you are an automotive dealership, a dealer group, or an automotive manufacturer
submitting a request on behalf of a consumer, please contact us at privacy@forcemarketing.com.

You will be asked for personal information such as name, phone number and/or email address to
verify your identity, as well as the type of right you want to exercise, such as access or deletion.

For access requests we must first verify your identity by using identifiers. Verification identifier may include but are not limited to: Name, Address, Email, and Phone Number. Once we verify your
identity, we will search for personal data collected and provide you a report with:

• list of categories of personal data we collected
• sources we collected from
• purposes of collecting
• categories of third parties with whom we share data

For deletion requests, once we verify your identity, we will confirm receipt of the deletion requests
and provide an estimated timeline for deletion completion unless the processing of your personal
information falls under a regulatory exception to deletion in which case we will notify you of such
exception. For deletion requests initiated through our web-based form, an additional confirmation
question will be asked to confirm that you want to delete your data.

California Authorized Agent: If you are a California resident, you may designate an authorized agent
to make a request to access or a request to delete on your behalf. We will respond to your
authorized agent's request if they submit proof that they are registered with the California Secretary
of State to be able to act on your behalf, or submit evidence you have provided them with power of
attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from
authorized agents who do not submit proof that they have been authorized by you to act on their
behalf, or are unable to verify their identity.

How Information Is Kept

Secure

FORCE MARKETING takes commercially reasonable precautions, including physical,
administrative, and electronic safeguards, to protect and secure the confidentiality and integrity of your personal information. For example, we encrypt communications through our website with
commercial strength encryption generally used by our industry. However, given the nature of the
Internet and the fact that network security measures are not perfect, we cannot guarantee the
absolute security of your information. If we are required to provide notice to you of a data security
breach, the notice will be provided in electronic form.

For EEA Data Subjects

Transferring personal data from the EU to the US

We have operations in the United States. Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We rely on derogations for specific situations as set
forth in Article 49 of the GDPR. In particular, we collect and transfer to the U.S. personal information only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

Legal Basis for Processing your Information
For individuals who are EEA Residents at the time their personal data is collected, we rely on legal
basis for processing your information under Article 6 of the EU General Data Protection Regulation
(“GDPR”). We generally only process your data where we are legally required to, where processing
is necessary to perform any contracts we entered with you (or to take steps at your request prior to
entering into a contract with you), for our legitimate interests to operate our business or to protect us, or you, property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal basis for processing.

Based on our contract with you or to take steps at your request prior to entering into a contract with
us so that we can provide you with our Services:

• To provide you Services
• To provide you with personalized Services
• To communicate with you
• To ensure quality
• To ensure security

Based on our legitimate interests, balancing any potential impact on you and your rights:

• To enhance your experience
• To facilitate corporate acquisitions, mergers, or transactions

Based on our legal obligations, the public interest, or in your best interest:

• To ensure security

Based on your consent:

• To enhance your experience
• To engage in marketing activities
• For any purpose

Right to Withdraw Consent

If you have given us consent in relation to particular processing or activities, you can withdraw your consent at any time by contacting us as indicated in the “HOW YOU CAN EXERCISE THESE RIGHTS” section. Children's Online Privacy

Our website is a general audience site and is not intended for use by children under 18. If you
become aware that a child under 18 years of age has provided personal data through the site, notify
us by email at the email address listed herein. If we become aware that a child under age 18 years
of age has provided personal information through this website, we will take steps to immediately
delete it.

Questions or Concerns

If you have any questions or concerns about this Privacy Policy or would like to contact us for any
reason, including the possibility of submitting a claim or correcting or changing your information,
you can write to privacy@gsmarketing.com or contact us at:

FORCE MARKETING
Attention: Privacy Officer
3098 Piedmont Rd. NE 4th Floor
Atlanta, GA 30305
Update 7/1/2024, 10:30:00 AM CT