Les Schwab Tire Centers Privacy Values and Policy

Effective Date: 7/1/2024

Last Reviewed: 7/1/2024

At Les Schwab, we are committed to protecting the privacy of our customers’ information. We know that your financial and personally-identifiable information is confidential and private. Our goals are to serve you as effectively and conveniently as possible and to ensure that information you share with us remains confidential. As part of our commitment, we have adopted the following privacy principles and have implemented them at all levels of our organization.

This Privacy Policy (the “Policy”), is provided to help you understand how we protect the privacy of your financial and personally-identifiable information. This Policy provides you with an opportunity to understand the way we manage your financial and personally-identifiable information. This Policy is provided to you jointly by all the Les Schwab companies listed at the end of this Policy and their affiliated member-dealers (collectively, “Les Schwab”). Les Schwab is comprised of several affiliate companies, all in the business of serving our customers’ tire needs. All of these affiliated companies and affiliated member-dealers may share your information among themselves and use your information in accordance with this Policy.

PLEASE READ this Policy carefully. This Policy applies to the data collected when Les Schwab provides a consumer product or service to you and/or when you apply for retail credit with Les Schwab and/or when you use our website located at www.lesschwab.com and other websites owned or controlled by Les Schwab (collectively, the “Site”), as detailed below in the section entitled How We Collect Personal Information. By providing personally-identifiable and/or financial information to Les Schwab and/or by using the Site, you signify to us that you have read and understand the terms of this Policy. You may also be presented with additional opportunities to review this Policy when taking certain actions at a Les Schwab location or on the Site.

VALUES

Four Key Values Form the Foundation of Our Privacy Policy

• Information security is a priority. One of our highest priorities is to secure our customers’ personal and financial information. We regularly review security systems to protect against unauthorized access to information.
• Privacy is a shared responsibility. You trust us to care for your tire needs, and you have the right to feel confident we are responsibly managing your account and information about you.
• Responsible use of personal information is beneficial. Information is important for meeting your needs and providing consistent quality in our service to you. Information flow and privacy are a balance. We must meet expectations for privacy while still managing personal information to conduct our business and serve you.
• Information must be shared to efficiently fulfill your requests, deliver products and services and administer and update accounts.

This Policy applies to all our affiliate companies. Having the same privacy information apply across all our companies makes it easy to understand and convenient for people to make informed choices about the management of their financial and personally-identifiable information.

Modifications to This Policy

We may need to update or revise this Policy from time-to-time in response to changing legal, technical, or business developments. We will post any new or revised Policy here, and you should review this Policy regularly to make sure that you are aware of its terms. You can determine if this Policy has been revised since your last visit to the Site by referring to the Last Updated date at the top of this Policy. Where required by law, Les Schwab will provide notification of changes to this Policy via the Personal Information that you have provided to us, if any. If we intend to use earlier-collected Personal information and Automatically-Collected Information in accordance with the terms of the revised Policy and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will provide you notification and/or request your consent prior to such use. Your continued use of the Site following any changes to this Policy signifies to us that you have read and understand this Policy as revised.

Information Covered by This Policy

This Policy applies to all information that Les Schwab collects through the performance of its services that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). As used in this Policy, Personal Information does not include: (i) publicly available information from government records, (ii) deidentified or aggregated consumer information, (iii) 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) or clinical trial data, (iv) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In the past twelve (12) months we have collected the following types of Personal Information about consumers, including, but not limited to:

Information You Provide to Us: Depending on your interaction with us or the products or services we provide to you, we may collect Personal Information that you provide to us. For example, we collect information when you visit our stores and buy our products. We collect information when you sign up to receive news, notifications, or other communications from us. We also collect information when you request customer support; engage with us on social media; fill out a form; or participate in a survey or promotion. The types of information we collect directly from you may include:

• Identification information, such as your first and last name, photo, social security number, birth date, driver’s license number or other identification documentation (e.g., passport or tax identification number), auto license number, employment information such as your employer and title;
• Contact information, such as your mailing address, email address, phone number, and professional contact information; and
• Payment information, such as your bank account information, credit card information, and other financial information, including a billing address.

You are never under any obligation to provide Personal Information to us, but you may not be able to purchase goods or services from Les Schwab, apply for retail credit with Les Schwab without providing requested Personal Information, or use certain features of the Site. When you do provide us with Personal Information, we will only use that Personal Information in accordance with this Policy. This Policy covers Personal Information we collect about you during the course of our relationship as well as after the relationship has ended.

Automatically Collected Information: This Policy also covers information we automatically collect and store when you visit the Site or conduct certain transactions with us.

As you navigate and browse the Site, we use website analytics tools to automatically collect and store information about your visit to and use of the Site, such as:

1. the date and time of your visit,
2. the duration of your visit,
3. the type of browser and browser language you use,
4. your Internet Protocol (“IP”) address,
5. your mobile device ID, operating system and version, and mobile network information,
6. type of computer or other operating device used, as well as its operating system and version,
7. the actions you take on the Site or when you interact with HTML-formatted email messages that we send you (such as the web pages viewed and the links clicked),
8. the websites (if any) from which you linked to the Site,
9. the website(s) you visit after visiting the Site. See information below in the section entitled Our Targeted Advertising Practices regarding our use of this information to track your online activity and deliver targeted advertising, and
10. location information about your general location inferred from your device, network, or ISP, when you access the Site. If you choose to enable location services on your device, we may collect more precise geolocation information from you that enables us to serve you location-based ads, notify you of products and services available in your area, and provide location-based services or Site functionality.

When you conduct certain transactions with us, whether online, over the phone, or in one of our stores, we may automatically collect information about you related to the transaction, such as:

• Purchase Information: When you make a purchase or return, we collect information about the transaction. This may include product details, purchase price, warranty information, date and location of the transaction. It may also include account notes about the transaction.
• Personal Preferences: Customer preferences, inquiries and comments, and any other personalized data you advise us about or which we learn about during your visit.
• Location Information: We may collect or infer information about your general location when you visit our stores, or turn on your Bluetooth, Wi-Fi or other geolocation functionality on your device while conducting a transaction with us. As described above, if you choose to enable certain location services on your device, we may collect more precise geolocation information that enables us to notify you about or serve location-based products, services, offers, or ads available in or pertaining to your area.
• Video and Images: We use cameras to capture video and images in and around our Stores. We may use these videos and images for security, fraud, loss prevention, law enforcement or incident reporting, or other operational purposes, such as analyzing traffic patterns.

Information We Receive From Other Sources: We may also obtain information about you from other sources and combine that with the information we collect about you. If we receive Personal Information from a third-party source and/or if we combine the information we receive from these third-party sources with your Personal Information, we will treat that information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use and share such information.

We may obtain information from third parties and append it to our existing user information to better understand users’ interests and to provide more relevant content.

We may append information about you that is publicly available or information that is aggregated and/or depersonalized by third parties. This information may include, for example, household income range, employment and education history, or postal code. This may include personal information such as names, age, race, gender, marital status, email address, physical address, or phone number.

How We Collect Personal Information

We rely on many sources of information to understand and meet your needs. We collect Personal Information about you in a variety of ways.

• Credit Applications: When you apply online for a credit pre-approval decision through the Site (where available) we collect your name, social security number, date of birth, contact information including your phone number(s), e-mail address, home address, and mailing address. When you submit your full credit application or other information you give us when you visit us online, in person, over the phone, or through the mail related to opening a line of credit with us we, in addition to the Personal Information listed above, also collect your government issued identification number, your vehicle license number, as well as information about your income and employment, including your employer, your income, your financial institution and a checking account number, and information about any liabilities, such as rent or mortgage payments, and whether you have or have had any collections, judgments, or bankruptcies. As described below, we may also collect Personal Information about you related to your credit application from third parties such as TransUnion, Equifax, and Experian.
• Store Visits and Offline Transactions with Les Schwab: When you interact with a Les Schwab company to provide you with a product or service, such as when you visit our stores, make an appointment over the phone or contact customer service, or attend or otherwise participate in a promotional event that we host or participate in, we may ask you to provide certain Personal Information, including your first and last name, phone number, e-mail address, mailing or other physical address, government identification number, vehicle license number, vehicle identification number, and payment information (which may include payment card information). Depending on the interaction, some communications may be recorded for purposes of quality assurance and training.
• Online Services and Transactions with Les Schwab: When you interact with the Site, including through software applications made available by us for use on or through computers and mobile devices (the “Apps”), such as to request a product or service, make appointments or purchases, communicate with us by email, fax, or online chat services, connect with us on or post to our social media pages that we control from which you are accessing this Policy (collectively, our “Social Media Pages”), sign up for a newsletter, or participate in a survey, contest or promotional offer, we may ask you to provide certain Personal Information, including your first and last name, phone number, e-mail address, or social media handle or identifier.
• Automatically Collected Information: In addition to the information collected through your online transactions with Les Schwab, as described in greater detail above under the heading Automatically Collected Information, we automatically collect certain types and categories of Personal Information when you engage in certain interactions with us as well as when you interact with the Site.
• Information Collected from Third-Party Sources: We collect Personal Information including education, employment and information regarding creditworthiness from consumer reporting agencies, public databases, joint marketing partners, member dealers, and other third parties.
• Physical & Mobile Location-Based Services: We may collect Personal Information if you download one of our Apps or choose to participate in certain programs. For example, we may collect the precise physical location of your device by using satellite, cell phone tower, WiFi signals, or other technologies. We may collect this data if you opt in through the App or other program (either during your initial login or later) to receive special offers and to enable location-driven capabilities on your mobile device. If you have opted-in, the App or other program may continue to collect location data when you are in or near a store until you log off or close application (i.e., the App or other program may collect this data if it is running in the background) or if you use your phone’s or other device’s setting to disable location capabilities.

How We Use Your Personal Information

When we collect or you supply us your Personal Information, we will use it for the purpose(s) set forth in this Policy at the time of collection of such Personal Information, examples of which are listed below, and will not use it for any other purpose without first providing you notification of our intent to do so. In addition to the specific uses of your Personal Information described below, we may also use your Personal Information to contact you regarding your account or to provide information about products, services, or promotional offerings that may be of interest to you based on your relationship with us. At any time, however, you may request that we not contact you about products or services that may be of interest to you. We respect your privacy and your right to limit the reasons for which we contact you.

Some specific ways in which we use Personal Information are listed below:

• Processing your credit application. Specifically, we collect the personal information described above in relation to your credit application for the purposes of determining credit eligibility and servicing your credit account if you are approved for and open a line of credit with us.
• To fulfill or meet the reason you provided the Personal Information, or otherwise for the reasons described to you at the time of collection of your Personal Information. For example, if you share your name and contact information to purchase our products or services, we will use that information to process your payment and facilitate delivery of our products or services. Where applicable, we will also use your Personal Information to (i) comply with Department of Transportation registration requirements; (ii) track warranty information on product or service you purchase from us; (iii) charge your Les Schwab credit account or credit card for purchasing a product or service, to process your retail credit application, (iv) to respond to any requests you may have about your account or a transaction; or facilitate new product orders or process returns. We may also save your Personal Information to facilitate new product orders, process returns, or contact you for the purpose of manufacturer product recalls.
• To provide, support, personalize, and develop our Site, products, and services.
• To create, maintain, customize, and secure your credit or other 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 experience on the Site and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Site, third-party sites, and via email or text message (with your consent, where required by law).
• To analyze purchase patterns and infer customer preferences.
• To help maintain the safety, security, and integrity of the Site, our products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve the Site, our products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Les Schwab’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Les Schwab about our website users is among the assets transferred.

SMS Terms and Conditions

Les Schwab allows customers to receive user prompted single instance information alerts and service reminders via text messaging, as well as alerts sent via text message in relation to servicing your account if you have a credit account with Les Schwab. The Les Schwab Short Code is 52225.

To opt-in to service reminders text “JOIN” to 52225.

If you opt-in to receive service reminders, you will receive up to 4 messages per appointment.

Consent to receive marketing text messages is not required as a condition of purchasing any goods or services. Texts may be sent using an automatic telephone dialing system.

You can opt-out of the Les Schwab SMS program at any time by texting “STOP” to 52225. A one-time confirmation message will be sent back to you.

To request support at any time, text “HELP” to 52225, send an e-mail to emailsupport@lesschwab.com or call 1-844-486-5252.

Les Schwab may amend these SMS terms and conditions, or modify or cancel this service or any of its features without notice.

Les Schwab is not liable for failed, delayed, or misdirected delivery of, any information sent through this service; any errors in such information; or any action you may or may not take in reliance on the information provided. LES SCHWAB WILL NOT UNDER ANY CIRCUMSTANCE BE LIABLE TO YOU FOR SPECIAL, INDIRECT, PUNITIVE, EXEMPLARY OR CONSEQUENTIAL DAMAGES.

Les Schwab is supported by all major cellular network carriers. Message and Data Rates may apply. Check with your service provider for details on specific fees and charges that may apply to you. Our participating carriers include, but are not limited to AT&T, Sprint, Verizon Wireless, U.S. Cellular®, T-Mobile® and MetroPCS®. The mobile carriers are not liable for delayed or undelivered messages.

Our Targeted Advertising Practices

We use third-party services to track and analyze your Site activity, as well as to track websites you visit after visiting the Site. In order to gather this information regarding your online activity, we use third-party persistent cookies on the Site. A persistent cookie remains on your computer or device, even after you close your browser software or otherwise end your online session.

We also use other third-party services to serve online Les Schwab advertisements to you on other websites after you’ve visited the Site. This practice is known as online behavioral advertising, and you will see our advertisements across the Internet unless you opt-out, as discussed below. We, along with third-party vendors, use cookies to inform, optimize, and deliver advertisements based on your online activity, including your past visits to the Site.

If you would like to opt-out of receiving targeted advertisements like this, you can opt-out by visiting the Network Advertising Initiative opt-out page. Note that even if you opt-out, you may still see Les Schwab advertisements, but they will not be delivered based on your online activity. If you are a resident of California, Colorado, Oregon or Utah, you may have additional rights, including the right to opt-out, relating to the use of your Personal Information for our Targeted Advertising purposes. Please refer to the section entitled Supplemental Privacy Notice for California, Colorado, Oregon and Utah Residents below for a complete description of these rights.

The advertisements described in this section are different from marketing communications you will receive if you are on our promotional mailing list, which is discussed above in the section entitled How We Use Your Personal Information.

Social Media Integrations

Certain pages of the Site might include social media features. These features might require us to implement cookies, plug-ins, or application programming interfaces (APIs) provided by such social media platforms to facilitate the communications and features. When you provide us with information through these platforms, the information also becomes subject to their privacy statements. In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third-party platforms. As a result, we cannot be responsible for any use of your information or content by a third-party platform, which you disclose at your own risk. We encourage you to review the privacy statements of these platforms.

Sharing Personal Information

At times we may share your Personal Information for our business purposes both internally within the Les Schwab family of companies as well as with third-parties, as described in greater detail below.

Personal Information Shared within Les Schwab Companies

In order to respond to your requests for credit and otherwise provide products and services to you, we may share Personal Information among companies within the Les Schwab family of companies. The Les Schwab companies that may receive Personal Information include tire centers and warehouse distribution centers. Les Schwab may share this information within other Les Schwab companies as a normal part of conducting business and offering products and services. All of these companies may use your information in accordance with this Policy, including to provide marketing communications to you. All of these companies are listed below.

Personal Information Shared with Affiliated Member-Dealers

We may share Personal Information with Les Schwab’s affiliated member-dealers. This is necessary in order to honor your request for information about Les Schwab products or services, to track and honor warranties applicable to product and services purchased by you, to respond to your requests for credit, or to provide an affiliated member-dealer with information for purposes of contacting you in their regular course of business, including for purposes of manufacturer product recalls or marketing products or services to you. Again, note that all of these affiliated member-dealers may use your Personal Information in accordance with this Policy, including to provide marketing communications to you. The affiliated member-dealers are required to comply with this Policy in order to protect the privacy of your Personal Information. Please click on this link to view a list of affiliated member-dealers.

Other Personal Information Sharing

At times, we may retain independent contractors to analyze data we collect, including Personal Information, solely to help us improve the goods and services Les Schwab provides to you. In addition, we may provide Personal Information to independent contractors we engage to enable us to process your Personal Information for auditing, research, and analysis, or to provide other services for Les Schwab such as billing and payment processing services. Further, we use third parties as described above in the section entitled Our Targeted Advertising Practices, and we share your Personal Information with them. These independent contractors are not authorized to use your Personal Information in any way other than to perform the requested services for Les Schwab, and these independent contractors are required to keep your Personal Information confidential. Les Schwab does not sell your Personal Information for monetary consideration; however, we do share your personal information in certain circumstances (See Sharing Personal Information and Our Targeted Advertising Practices). We may also share Personal Information about you with companies or other organizations outside of Les Schwab as required by or permitted by law. For example, we may share Personal Information to:

• comply with the Department of Transportation’s tire registration requirements; protect against fraud, illegal activities, or situations involving threats or potential threats to the safety of any person or entity;
• establish or exercise legal rights or defend against legal claims;
• respond to a subpoena or court order; or
• service your credit account.

Disclosure as Part of a Merger, Acquisition, or Sale

We may transfer your Personal Information if Les Schwab is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which Personal Information is among the assets transferred.

How We Keep Personal Information Secure

Information security is one of our highest priorities. This priority is emphasized by employee training, an internal information handling policy, this Policy, and the agreements we may sign with external suppliers and affiliated member-dealers. Employees who violate our policies regarding privacy are subject to disciplinary action, and our suppliers and affiliated member-dealers are bound to maintain privacy under the terms of our agreements with them. We regularly review security standards in an effort to guard against unauthorized access to Personal Information.

Retention

We will retain your Personal Information in accordance with our document retention policy and applicable laws. This retention period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to have sufficient information to carry on ordinary business activities, including our compliance with applicable laws. The Personal Information collected to serve targeted online advertising may be retained for the purpose of serving such targeted online advertising to you until you opt-out of receiving these advertisements, as described above in the section entitled Our Targeted Advertising Practices. Also, we may retain your Personal Information beyond the end of your relationship with us if we believe in good faith that a law, regulation, rule, or guideline requires it.

Category of Information We Collect	Retention Periods
Identifiers	Indefinite - Required for product and service warranties and product recalls conducted in accordance with federal law
establish or exercise legal rights or defend against legal claims;	Indefinite - Required for product and service warranties and product recall conducted in accordance with federal law
Commercial Information	Indefinite - Required for product and service warranties and product recall conducted in accordance with federal law
Internet or other electronic network activity information.	365 Days
Geolocation Data	365 Days
Audio, electronic, visual, thermal, Olfactory, or similar information	365 Days

Automated Decision-Making

We use automated decision making to evaluate online credit applications in order to assist our employees in making fair and transparent lending decisions. If you apply for credit with us, the automated decision making process will consider the information provided in your application, as well as publicly available information about your credit history and financial stability. The process is designed to inform us of the likelihood that you will be able to repay the loan, and to assign a credit score based on that likelihood. The decision to approve or reject a credit application is made by our employees and does not use artificial intelligence or machine learning.

You have the right to request a review of any automated decision made in connection with your credit application, and to obtain an explanation of the decision. If you have any questions or concerns about our use of automated decision making for credit applications, please do not hesitate to contact us.

Sensitive PI

We are committed to diversity and inclusion in the workplace and strive to ensure that our employee demographics reflect the communities we serve. In order to assess and address any potential disparities, we may collect and use sensitive personal information about the race and ethnicity of our employees and customers.

We only collect this information from trusted vendors who have appropriate safeguards in place to protect the privacy and security of the sensitive data. The information is used solely for the purpose of comparing employee ethnicity against customer percentages and is not shared with any third parties.

Children’s Privacy

The Site is not directed at nor intended for use by children under the age of 16, and we do not knowingly collect any Personal Information directly from children under the age of 16. If you are under age 16, you should not use the Site and you should not send us personal information about yourself.

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA, COLORADO, OREGON AND UTAH RESIDENTS

If you are a California, Colorado or Utah consumer, the information below (“Supplemental Privacy Policy”) also applies to you, in addition to this Policy. This Supplemental Privacy Policy provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Oregon Data Privacy Act of 2024 (the “OCDPA), or the Utah Consumer Privacy Act of 2022 (the “UCPA”), and any and all regulations arising therefrom. Some portions of this Supplemental Privacy Policy apply only to consumers of particular states, and we have indicated where those portions are state-specific.

Do Not Track

The Site does not respond to browser “Do Not Track” signals. Some third-party websites not owned, operated, or controlled by us may keep track of your browsing activities when you visit them, which enables them to tailor what content they present to you. If you are visiting such sites, your browser may allow you to set a Do Not Track or “DNT” signal on your browser so that third parties such as advertisers know you do not want to be tracked. Third parties that have content embedded on the Site (e.g., social media buttons) may set cookies on your browser and/or obtain information about the fact that your browser visited the Site from a certain IP address.

We honor and respond to the global privacy control (“GPC”) signal. Please note that when your browser broadcasts the GPC signal, we will limit the functionality of the Site and prevent the Site from transmitting your personal information to third parties. We will also treat this signal as a verified request to stop selling your personal information and stop processing your information for purposes of targeted advertising. However, the GPC signal does not fully identify you by name or email address. Therefore, we may not be able to honor this request for other interactions you may have with us. You may also submit an Opt-Out privacy request with your email, phone number, and other personal information for us to complete the opt-out process.

The Personal Information We Collect and Disclose

The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of vendors or third parties with whom that category of personal information is shared. As this chart shows, we may share or sell personal information to third parties or disclose certain personal information to vendors for business purposes.

Category of Personal Information	Unique Identifiers
Examples	Real name, signature, alias, address, unique personal identifier, online identifier, IP address, email address, account name
Sources from which this personal information is collected	Directly from you via the Site Direct communication with you online and in our stores Social media interaction with you Marketing agencies Third parties Marketing campaign Collected with customer knowledge
Business Purpose for collection	Provide information, products and services Security, credit or fraud prevention Provide customer service and assess satisfaction Personalize customer experience Improve products and services Improve marketing and customer communications Comply with legal/regulatory obligations Business operation Customer credit scoring Billing and payments
Types of vendors or third parties with whom this personal information is shared	Business partners Analytic providers Accounting and financial service providers Business communication and collaboration provider Data storage service provider Data verification and geocoding solutions provider Device management solutions provider Digital solutions provider Hosting services provider Information and digital services provider IT services Managed file transfer vendor Risk management solution provider Sales and marketing provider Security vendors
Types of vendors or third parties with whom this personal information is sold	Not Applicable

Category of Personal Information	Contact and Financial Information
Examples	Name, address, telephone, email, credit card number, debit card number, or any other financial information
Sources from which this personal information is collected	Directly from you via the Site or at a store when applying for credit. Third parties Marketing campaign directly from customer
Business Purpose for collection	Complete transactions Other services and discounts Process claims Prevent fraud Analytics of customer data Business operations Legal/regulatory obligations Warranty Tracking service quality
Types of vendors or third parties with whom this personal information is shared	Payment processors Credit check firms Lenders Hosting services provider IT services provider Managed file transfer vendor Digital solutions provider Data verification and geocoding solutions provider Accounting and financial service providers Risk management solution provider Security vendors Sales and marketing provider Advertising vendor
Types of vendors or third parties with whom this personal information is sold	Not Applicable

Category of Personal Information	Characteristics of Protected Classifications
Examples	Age, gender, disability
Sources from which this personal information is collected	During sale directly from customer Marketing campaign directly from customer Third Parties Marketing agencies
Business Purpose for collection	Comply with legal/regulatory obligations Ensure eligibility for services (e.g. over 18) Accommodate special needs Providing services to customer Business Operations Safety recall Warranty
Types of vendors or third parties with whom this personal information is shared	Managed file transfer vendor Risk management solution provider Hosting services provider
Types of vendors or third parties with whom this personal information is sold	Not Applicable

Category of Personal Information	Commercial Information
Examples	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Sources from which this personal information is collected	Directly from you via the Site Direct communication with you Social media interaction with you Marketing agencies
Business Purpose for collection	Provide you with goods and services Invite participation in surveys and feedback Customer service communications Improve promotions
Types of vendors or third parties with whom this personal information is shared	Web hosters Marketing consultants Contractors Analytics providers Social media platforms
Types of vendors or third parties with whom this personal information is sold	Not Applicable

Category of Personal Information	Internet or Other Electronic Activity
Examples	Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement
Sources from which this personal information is collected	Directly from you via the Site Direct communication with you Social media interaction with you Marketing agencies Marketing campaign directly from customer Third parties Analytics of customer data
Business Purpose for collection	Provide you with goods and services Invite participation in surveys and feedback Customer service communications Improve promotions Tracking service quality Online tracking Business operations Comply with legal/regulatory obligations Security incidents/fraud
Types of vendors or third parties with whom this personal information is shared	Payment processors Contractors Advertising vendor Sales and marketing provider Analytics providers Social media platforms Digital solutions provider Security vendors Hosting services provider
Types of vendors or third parties with whom this personal information is sold	Not Applicable

Category of Personal Information	Geolocation Data
Examples	Device location - Not precise Geolocation
Sources from which this personal information is collected	From your digital device Direct communication with you Social media interaction with you Third Parties Marketing campaign directly from customer
Business Purpose for collection	Provide you with goods and services Customer service communications Improve promotions Safety recall Analytics of customer data Tracking service quality Business operations Legal/regulatory obligations Security incidents/fraud
Types of vendors or third parties with whom this personal information is shared	Hosting Services Provider
Types of vendors or third parties with whom this personal information is sold	Not Applicable

Category of Personal Information	Inferences Drawn from Other Categories to Create a Profile
Examples	Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Sources from which this personal information is collected	Directly from you via the Site Direct communication with you Social media interaction with you Marketing agencies Third Parties
Business Purpose for collection	Provide you with goods and services Customer service communications Improve promotions Safety recall Analytics of customer data Tracking service quality Business operations Legal/regulatory obligations Security incidents/fraud
Types of vendors or third parties with whom this personal information is shared	Marketing consultants Analytics providers Social media platforms Hosting services provider
Types of vendors or third parties with whom this personal information is sold	Not applicable

Sensitive Personal Information We Collect and Disclose

Your Rights to Your Personal Information

California, Colorado, Oregon and Utah consumers have certain rights with respect to the collection and use of their personal information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California consumers. Consumers in Colorado, Oregon and Utah have similar rights.

You have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12-month span. Please note, there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

Rights and Choices Applicable to California Residents

The CCPA provides certain consumers (California residents) with specific rights regarding their Personal Information. This section describes CCPA rights applicable to California residents and explains how they can exercise those rights.

Individual versus Household Submissions

Any privacy request submitted will be processed as an individual request. Separate requests must be submitted for each individual within a household.

Access to Specific Information and Data Portability Rights

You have the right to request that Les Schwab disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we have collected about you.
• The categories of sources for the Personal Information we have 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.
• The specific pieces of Personal Information we have collected about you (also called a “data portability request”).
• 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.
• Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• 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, or otherwise perform our contract with you.
• Comply with Department of Transportation registration requirements, National Highway Traffic Safety Administration requirements, track warranty information on product or service you purchase from us, respond to any requests you may have about your account or a transaction, or contact you for the purpose of manufacturer product recalls.
• Service your credit account with us in the ordinary course of business andaccording to the terms and conditions of your application and security agreement with us.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• 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 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-888-431-8770
• Visiting: Website Request

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or a legally authorized representative.
• 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. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

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

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 the verifiable consumer request’s receipt. 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 usable and should allow you to transmit the information from one entity to another entity.

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

If you are 16 years of age 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 collect or sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. 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 legally authorized representative) may submit a request to us by visiting the following Internet Web page link: Website Request

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 disclosures and/or sales at any time by:

• Calling us at 1-888-431-8770
• Visiting: Website Request

We will only use Personal Information provided in an opt-out request to review and comply with the request.

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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We currently do not provide any financial incentives related to the collection, use, or sale of your Personal Information.

Contact Information

If you have any questions or comments about this Policy, the ways in which we collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

• Calling us at 1-888-431-8770
• Visiting: Website Request

Right to Appeal

Right to Appeal (CO, Residents) – If you are a resident of Colorado, and you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by clicking on the form.

Visiting: Appeal Request

Please include your full name, the basis for your appeal, and any additional information to consider. Depending on the applicable law, within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to your appeal.

If the appeal is denied, you may contact:

• Colorado Attorney General - complaint submission link https://complaints.coag.gov/s/contact-us
• Phone: (720) 508-6000
• Email: attorney.general@coag.gov

Legal Disclaimer

We cannot guarantee that your Personal Information will never be compromised. Further, while we employ reasonable measures to protect your Personal Information, we cannot guarantee unauthorized third parties will not defeat those measures or use non-public Personal Information for improper purposes. Nevertheless, we value your business and have adopted this Policy and undertaken reasonable security measures as an endeavor to respect your privacy and to keep your Personal Information confidential.

Les Schwab Companies Providing This Policy

This Policy is provided by the Les Schwab companies listed below.

• Les Schwab Tire Centers of Portland, LLC
• Les Schwab Tire Centers of Washington, LLC
• Les Schwab Tire Centers of California, LLC
• Les Schwab Tire Centers of Central California, LLC
• Les Schwab Tire Centers of Idaho, LLC
• Les Schwab Tire Centers of Boise, LLC
• Les Schwab Tire Centers of Montana, LLC
• Les Schwab Tire Centers of Nevada, LLC
• Les Schwab Tire Centers of Utah, LLC
• Les Schwab Tire Centers of Colorado, LLC
• Les Schwab Tire Centers of Oregon, LLC
• Les Schwab Warehouse Center, LLC

Unenforceability

If any part of this Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision, and the remainder of the Policy will continue in full force and effect.

Questions

If you have questions regarding this Policy or need additional information, please contact privacy@lesschwab.com.