JM Family Enterprises, Inc. and its subsidiary JM Smart Lot ("we," "us," or "our") are committed to protecting your privacy. This Data Privacy Policy explains how we collect, use, disclose, and safeguard your information.

1. Information We Collect

Personal Information

When you use our App Clip, schedule a test drive, or create an account, we may collect: name, email address, phone number, and dealership affiliation. When you scan a QR code, we record the scan event associated with the vehicle but do not collect personal data unless you voluntarily provide it.

Device and Usage Data

We collect aggregated scan counts, engagement metrics, and device telemetry (battery voltage, GPS coordinates of IoT devices on the lot, firmware versions). IoT device GPS data is used solely for asset tracking and geofencing on dealership property.

2. How We Use Your Information

3. California Consumer Privacy Act (CCPA)

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

To exercise these rights, contact us at privacy@jmfamily.com or call 1-800-555-0199. We do not sell your personal information.

4. Data Retention

We retain personal information for as long as necessary to provide our services and fulfill the purposes described in this policy. Engagement analytics data (scan counts, trends) is retained in aggregate form and is not personally identifiable.

5. Data Security

We implement industry-standard security measures including encryption in transit (TLS 1.3), encryption at rest (Azure Cosmos DB encryption), role-based access control via Microsoft Entra ID, and SCIM 2.0 automated user provisioning and deprovisioning.

6. Contact Us

For questions about this policy, contact our Data Protection Officer at privacy@jmfamily.com.