Privacy Policy

1. Data We Collect#

The platform processes the following categories of data. Not every category applies to every interaction.

• Identifiers and contact data — first name, last name, email address, phone number, postal address, and the NexusID pseudonymous identifier we assign to each unique shopper.
• Vehicle interest data — search queries, vehicles viewed, vehicles favorited, trade-in valuations requested, financing applications started or submitted.
• Transaction data — sold-deal records (VIN, sale price, dealer, sale date) ingested from the dealer's DMS (Dealer Management System) and CRM.
• Service data — service appointments, repair-order line items, mileage at last service, and recall status.
• Behavioral data — pages viewed on the dealer's website, dwell time, scroll depth, click-stream events, and the device and browser used.
• Communication data — chat transcripts with the dealer's on-site chat, ADF/STAR lead emails routed through the platform, and AI-Connector conversations forwarded by ChatGPT, Perplexity, Claude, Gemini, or Bing.
• Inferences — propensity scores, in-market segments, and intent signals derived from the categories above.

We do not knowingly collect Social Security numbers, drivers-license numbers, financial-account numbers, geolocation precise to ±1,850 feet, biometric identifiers, health information, or contents of mail / email / messages other than those addressed to the dealer.

2. How We Collect It#

• Directly from the consumer — when they fill out a contact form, request a test drive, schedule service, or chat with the dealer.
• Automatically from the consumer's browser or device — first-party cookies, the NexusMotive analytics pixel, and standard web-server logs.
• From the dealer — DMS and CRM data exports, ad-account telemetry, and direct uploads of customer lists for re-marketing the dealer is authorized to perform.
• From OEM partners — Toyota Motor North America and Lexus inventory feeds, incentive feeds, and offer catalogs.
• From AI shopping surfaces — when ChatGPT, Perplexity, Claude, Gemini, or Bing calls the AI Inventory Connector on behalf of an end user.

3. Why We Use It#

We process data for the following business purposes:

• Operating the dealer's website, inventory search, finance calculator, trade-in tool, chat, and lead-routing pipeline.
• Routing leads to the dealer's CRM so the dealer's sales team can follow up with the shopper.
• Measuring ad performance and computing closed-loop attribution for the dealer's Google, Meta, Microsoft, and TikTok ad accounts (the dealer owns the accounts; we are the measurement layer).
• Building and maintaining the NexusID identity graph so a shopper recognized at Dealer A can be re-recognized at Dealer B in the same network when both dealers authorize it.
• Detecting fraud, abuse, and bot traffic against the platform.
• Producing dealer-facing analytics and benchmarks (anonymized aggregates with a minimum cohort size of 20 — no individual is identifiable).
• Complying with our legal obligations, enforcing our Terms of Service, and defending claims.

4. PII Isolation — Cryptographic, Not Just Procedural#

Every active dealer tenant on NexusMotive is provisioned with a dedicated AWS KMS customer master key (CMK). All personally identifying fields stored in the platform database (name, email, phone, address, chat transcript bodies, lead notes) are encrypted at rest with AES-256-GCM using a per-tenant data-encryption key derived from that CMK.

The IAM key-policy on each tenant's CMK denies kms:Decrypt to the platform-admin role pattern. This means NexusMotive employees with platform-admin privileges literally cannot decrypt a dealer's customer PII — the denial happens at the AWS API boundary and is enforced by AWS, not by application code.

Cross-tenant analytics (the kind that surface on dealer benchmark dashboards or in OEM reports) read only NexusID values plus anonymized aggregates with a k-anonymity floor of 20. No plaintext PII, no dealer code, no individual record ever crosses a tenant boundary.

This architecture is auditable. We can — and on request, will — produce the KMS key policies, the application-layer encryption envelope format, and the access-log evidence that proves the claim above.

5. Who We Share Data With#

NexusMotive shares personal information only as follows:

• The originating dealer — leads, deals, service records, and chat transcripts are returned to the dealer whose website the consumer interacted with.
• Sub-processors — listed in the Data Processing Addendum. Each sub-processor is contractually bound to process data only on our instructions and to maintain security controls at least as protective as ours.
• Ad platforms (Google, Meta, Microsoft, TikTok) — for the dealer's own ad-measurement and audience activation. We forward NexusID and hashed identifiers; we do not forward plaintext PII.
• Law enforcement — only in response to a valid subpoena, court order, or other legal process, after we have evaluated the request for facial validity.
• A successor entity — in the event of a merger, acquisition, or sale of assets, subject to the same protections in this policy.

NexusMotive does not sell personal information for money. We do not share personal information for cross-context behavioral advertising outside the dealer's own ad accounts. If our practice ever changes we will update this policy and offer a clear opt-out before any new sharing begins.

6. Your California Privacy Rights (CCPA / CPRA)#

If you are a California resident, you have the right to:

• Know what personal information we have collected about you, the sources, the purposes, and the categories of recipients (Cal. Civ. Code §1798.110, §1798.115).
• Delete personal information we have collected about you, subject to the statutory exceptions (Cal. Civ. Code §1798.105).
• Correct inaccurate personal information we maintain about you (Cal. Civ. Code §1798.106).
• Opt out of the sale or sharing of your personal information (Cal. Civ. Code §1798.120) — we do not sell or share for cross-context behavioral advertising, but you may still submit the request.
• Limit the use and disclosure of sensitive personal information (Cal. Civ. Code §1798.121) — we do not use or disclose sensitive PI for purposes beyond those permitted by §7027 of the CCPA regulations.
• Non-discrimination — we will not deny you service, charge you a different price, or provide a different level of service because you exercised a privacy right (Cal. Civ. Code §1798.125).

To exercise these rights, email privacy@nexusmotive.com or write to the postal address in the Contact section below. We will verify your identity in line with §7060 of the CCPA regulations and respond within 45 days, with a one-time 45-day extension where reasonably necessary. You may designate an authorized agent to submit requests on your behalf with appropriate documentation.

7. FTC Safeguards Rule — Information Security Program#

Because NexusMotive provides services to automotive dealers — which the Federal Trade Commission classifies as financial institutions under the Gramm-Leach-Bliley Act — we maintain a written information security program designed to satisfy the FTC Safeguards Rule.

Key elements of the program:

• Designated qualified individual — a Chief Information Security Officer accountable to the NexusMotive board for the program.
• Risk assessment — at least annual written risk assessments scoped to the platform, its sub-processors, and the dealer ecosystem.
• Safeguards — multi-factor authentication on all administrative access, encryption at rest and in transit, vulnerability scanning, penetration testing, and least-privilege access controls.
• Service-provider oversight — written contracts with all sub-processors that flow down the Safeguards Rule's technical and organizational measures.
• Incident-response plan — documented playbook, named on-call roster, breach-notification SLAs to dealers within 72 hours of confirmation, and forensic-evidence-preservation procedures.
• Annual board report — written report from the qualified individual to the board summarizing the program's status, material risks, and any incidents.

8. Cookies and Similar Technologies#

NexusMotive uses first-party cookies to operate dealer websites, remember preferences, and produce ad-measurement signals. We do not deploy third-party advertising cookies on the dealer's domain without the dealer's explicit opt-in.

See the dedicated Cookies Policy at /legal/cookies for the full list of cookies, their categories, their durations, and how to control them.

9. Data Retention#

We retain personal information only as long as needed for the purposes described in this policy or as required by law:

• Lead records — retained for the duration of the dealer's subscription plus 24 months, unless the dealer instructs earlier deletion.
• Call recordings, voicemail and text messages: retained for at least two years from the communication, and not removed earlier by age.
• Closed deal records — retained for 7 years to satisfy federal and state record-keeping rules applicable to motor-vehicle sales.
• Service-appointment and repair-order data — retained for 7 years.
• Website-analytics events — retained for 26 months at row-level granularity, then aggregated and anonymized.
• NexusID identity-graph nodes — retained indefinitely in pseudonymous form (hashed identifiers only). Plaintext PII linked to a NexusID is removed when the underlying lead, deal, or service record is deleted.
• Backups: retained for 14 days. Deletion requests are honored in production immediately; the corresponding backup copy falls out of the retention window within 14 days.

10. Children's Privacy#

NexusMotive's services are directed to adult consumers shopping for vehicles, financing, and service. We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected information from a child under 13, we will delete it as soon as reasonably practicable.

If you believe a child has provided us with personal information, please contact privacy@nexusmotive.com so we can investigate and act.

11. Security#

We implement administrative, technical, and physical safeguards designed to protect the personal information we process. These include AES-256-GCM encryption at rest, TLS 1.2 or higher in transit, per-tenant KMS keys, multi-factor authentication on administrative access, role-based access control, comprehensive audit logging, automated vulnerability scanning, and an annual third-party penetration test.

No security program is perfect. If you have reason to believe your interaction with us is no longer secure, please contact privacy@nexusmotive.com immediately.

12. Cross-Border Transfers#

NexusMotive operates exclusively in the United States. Our infrastructure, sub-processors, and personnel are located in the United States. We do not target the European Economic Area or the United Kingdom, and our services are not offered there.

If you are accessing the platform from outside the United States, you understand that your information will be transferred to and processed in the United States, where data-protection laws may differ from those in your country.

13. Changes to This Policy#

We will post any material changes to this policy at this URL and update the "Last updated" date at the top. For changes that materially expand the categories of data we collect or the purposes for which we use it, we will provide additional notice — by email if we have your address, or by a prominent in-product notice — before the change takes effect.

The current published version is tracked via the LEGAL_VERSION constant exposed at the bottom of this page so dealers, partners, and AI marketplace reviewers can detect updates programmatically.

14. Contact Us#

For privacy questions, rights requests, or to report a suspected security issue:

• Email — privacy@nexusmotive.com
• Postal — NexusMotive, Inc., Attn: Privacy, 1 NexusMotive Way, Wilmington, DE 19801, USA