Privacy Policy

1. Introduction

Carculus Automotive LLC (“Company,” “we,” “us,” or “our”) operates the Blue Sky Dealer automotive retail training simulation platform at www.blueskydealer.com (“Platform”). This Privacy Policy applies to personal information collected through the Platform, our website, and any related communications.

We are committed to protecting your privacy and handling your personal information responsibly. If you have questions or concerns about this Privacy Policy, please contact our Privacy Team at privacy@blueskydealer.com.

2. Information We Collect

2.1 Information You Provide Directly

• Account registration information: name, email address, username, and password
• Professional profile information: job title, dealership or organization name, years of experience, career track, and professional certifications
• Payment and billing information: credit card details and billing address (processed securely by our payment processor; we do not store full card numbers)
• Communications: messages, support requests, and feedback you send to us
• Survey and assessment responses: answers to in-platform assessments, scenario decisions, and simulation inputs
• User preferences: notification settings, display preferences, and feature configurations

2.2 Information Collected Automatically

• Usage data: pages visited, features used, simulation modules accessed, session duration, and navigation paths
• Simulation performance data: scenario completion rates, decision patterns, scores, benchmarking results, and career track progress
• Device and technical data: IP address, browser type and version, operating system, device identifiers, and screen resolution
• Log data: access logs, error logs, and activity timestamps
• Cookies and tracking technologies as described in Section 7

2.3 Information from Third Parties

• Payment processors: transaction confirmation and fraud signals
• Single sign-on providers: if you register via Google or another SSO service, we receive basic profile information with your consent
• Employers or dealership administrators: if your account is created or managed by an Organization, the administrator may provide your professional information

2.4 Information We Do Not Collect

Blue Sky Dealer is a professional training platform. We do not collect Social Security numbers, driver's license numbers, or sensitive personal information unrelated to your professional profile. We do not knowingly collect personal information from individuals under 18 years of age.

3. How We Use Your Information

3.1 Platform Operation and Service Delivery

• Creating, maintaining, and authenticating your Account
• Delivering Platform features, simulation modules, and career track content
• Processing subscription payments and managing billing
• Providing customer support and responding to inquiries
• Sending transactional communications (receipts, subscription confirmations, password resets)

3.2 Personalization and Performance Tracking

• Tracking and displaying your simulation progress, scores, and career track advancement
• Personalizing the Platform experience based on your professional role and usage history
• Generating performance reports and benchmarking comparisons
• Recommending relevant training modules and content

3.3 Platform Improvement and Analytics

• Analyzing usage patterns to improve Platform functionality and content quality
• Developing new features, simulation scenarios, and training modules
• Conducting internal research on training effectiveness and user engagement
• Monitoring Platform performance, stability, and security

3.4 Communications and Marketing

• Sending newsletters, product updates, and promotional communications (with your consent or where permitted by law)
• Notifying you of changes to the Platform, Terms of Service, or this Privacy Policy
• Conducting user surveys and feedback programs

3.5 Legal and Compliance

• Complying with applicable laws, regulations, and legal processes
• Enforcing our Terms of Service and protecting our legal rights
• Preventing fraud, abuse, and security threats
• Responding to law enforcement requests where required by law

4. How We Share Your Information

We do not sell your personal information. We share information only as described below.

4.1 Service Providers

We share information with third-party vendors who perform services on our behalf, including cloud hosting providers, payment processors, email delivery services, analytics platforms, and customer support tools. These providers access information only as necessary to perform their services and are contractually required to protect your information.

4.2 Organizational Accounts

If your Account is associated with an Organizational subscription (e.g., a dealership or automotive group), your usage data, simulation performance, career track progress, and professional profile may be visible to designated administrators of that Organization.

4.3 Aggregated and De-Identified Data

We may share aggregated, anonymized, and de-identified data derived from Platform usage for industry research, product development, and general business purposes. This data does not identify individual users.

4.4 Business Transfers

If Carculus Automotive LLC undergoes a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. We will provide notice of such transfers as required by applicable law.

4.5 Legal Requirements

We may disclose your information when required by law, court order, or other legal process, or when necessary to protect the safety, rights, or property of the Company, Users, or the public.

4.6 With Your Consent

We may share your information for other purposes with your explicit consent at the time of sharing.

5. Data Retention

• Account and profile data: retained for the duration of your active Account plus up to 3 years following Account deletion
• Simulation performance and progress data: retained for the duration of your active Account plus 2 years
• Billing and payment records: retained for 7 years as required by applicable tax and financial regulations
• Communications and support records: retained for 3 years from the date of the communication
• Log and technical data: retained for 12 months for security and operational purposes

Upon Account deletion, we will delete or anonymize personal information within 90 days, subject to the above retention periods and any legal hold requirements.

6. Data Security

We implement administrative, technical, and physical safeguards including:

• Encryption of data in transit using TLS/HTTPS protocols
• Encryption of sensitive data at rest
• Access controls limiting personal data access to authorized personnel with a legitimate business need
• Regular security assessments and monitoring
• Secure password hashing using industry-standard algorithms
• Multi-factor authentication options for Account access

In the event of a data breach that poses a risk to your rights, we will notify affected users as required by applicable law, including California Civil Code § 1798.82.

7. Cookies and Tracking Technologies

7.1 Types of Cookies

• Strictly necessary cookies: required for authentication, session management, and core Platform functionality; cannot be disabled without impairing Platform operation
• Functional cookies: remember your preferences (e.g., language, display settings) to improve your experience
• Analytics cookies: collect anonymized usage data to help us understand how the Platform is used
• Marketing cookies: may be used to deliver relevant communications; we do not serve third-party advertising on the Platform

7.2 Managing Cookies

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality. We honor Global Privacy Control (GPC) signals where technically feasible.

8. Third-Party Links and Integrations

The Platform may contain links to third-party websites or integrate with third-party tools (such as SSO providers). This Privacy Policy does not apply to third-party sites or services. We are not responsible for the privacy practices of third parties.

9. Children's Privacy

Blue Sky Dealer is intended for individuals 18 years of age and older. We do not knowingly collect personal information from individuals under 18. If you believe a minor has provided us with personal information, please contact us at privacy@blueskydealer.com.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”).

10.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories:

10.2 Sale or Sharing of Personal Information

We do not sell your personal information for monetary consideration. We do not share personal information with third parties for cross-context behavioral advertising purposes. We have not sold or shared personal information from California consumers in the preceding 12 months.

10.3 Your California Privacy Rights

As a California resident, you have the right to:

• Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of collection, the business or commercial purposes, and the categories of third parties with whom we share information
• Delete: Request deletion of personal information we have collected about you, subject to certain exceptions
• Correct: Request correction of inaccurate personal information we maintain about you
• Opt-Out of Sale/Sharing: While we do not sell or share personal information for advertising, you may submit a Do Not Sell or Share request at any time
• Limit Use of Sensitive Personal Information: Request that we limit use to purposes strictly necessary to provide the Platform
• Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights

10.4 How to Exercise Your Rights

Submit a verifiable consumer request by:

• Email: privacy@blueskydealer.com (subject line: “California Privacy Request”)
• Web: www.blueskydealer.com/privacy-request

We will respond within 45 days, with one 45-day extension available upon notice. We will verify your identity before processing requests.

10.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf with written authorization signed by you.

10.6 Shine the Light

We do not disclose personal information to third parties for their direct marketing purposes (California Civil Code § 1798.83).

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy at www.blueskydealer.com/privacy and, where appropriate, by email. Your continued use of the Platform after the effective date constitutes acceptance.

12. Contact Us

Carculus Automotive LLC — Privacy Team

Blue Sky Dealer

700 Larkspur Landing Cir, Larkspur, CA 94939

Email: privacy@blueskydealer.com

Website: www.blueskydealer.com/privacy

State of Formation: California

For California-specific requests, include “California Privacy Request” in your email subject line.