Privacy Statement

Navigation Research Company Wide Privacy Policy

EFFECTIVE DATE: January 02, 2021

Welcome to Navigation Research Co., Inc. services! This Privacy Policy (“Policy”) describes how Navigation research Co., Inc.
(“we,” “us,” or “our”) collects, uses, and discloses information that we obtain about your use of the Navigation Research websites
(the “Site”), including TRUscore™ branded products (“TruscoreCertified” apps.), TRUscoreCertified™ software (“TRuscoreCard”
apps), collectively “the Service,” including information that we collect from the TRUscore Certified vehicle scanner devices.

Does this Policy apply to you?

 This Privacy Policy applies to all commercial or personal uses of our Services globally and you should not use the Services if you do
not agree to this Privacy Policy.

 This Privacy Policy applies to EEA (European Economic Area) data subjects unless the data subject is using the Services under
direction from a service provider where the service provider and the data subject owner /vehicle have an agreement between them
covering the use of the Services. In such a case the service provider and or his/her institution is the Data Controller for data
collected from/by TRUscore Certified scan tools and the TRUscore Certified App, and the service provider or his/her institution’s
privacy policy will apply, not this Privacy Policy.

 If you are located in the United States or a country outside the EEA, your information is stored in the United States. By using or
downloading the Service, you agree that your personal information, including any information about your vehicle’s health that you
provide directly to us or that we collect through your use of the Service, may be transferred to and stored in the United States.

 If you are an EEA user, we will store your information in the European Union.

The Information We Collect About You. We collect information directly from you, from your devices, from your vehicle and from
our apps and devices or third party services we offer to you and to which you connect, as well as automatically through your
voluntary use of our Service.

When You Create, Update, or add information to Your Profile. When you register to use the Service, we collect the personal
information you provide us, including your name, email address, password and phone number. We also collect any additional
information you choose to add to your profile on our website, apps or dealer and vehicle profiles during the use of the Service.

We collect additional automated information from TRUscore Devices you connect to TRUscore Certified Apps on your

When you Use a TRUscore Certified Device. We securely collect raw vehicle data using a patented wireless hardware tool that
securely connects directly to our servers and via BLE to your devices, separately and concurrently. It performs a raw data (think
electrocardiogram (“ECG,” “EKG”) measurement and recording of available vehicle diagnostic data including average RPM, oil
pressures, raw sensor data, and many other precise indicators of present or future malfunctions affecting the vehicles heart or
extremities where data recording can be taken (e.g. engine, transmission, drive axel, ABS, AIR Bags entertainment bus, etc.)
depending on the capability of the vehicle. TRUscore works most all vehicles sold in the United States since 2008. The TRUscore
scan device must have cellular service for the Service to operate. We may collect additional vehicle and environmental information
through or from your mobile device at the time of connecting to our servers for data recording. This includes vehicle accelerometer
and stored crash data, odometer data, pictures, video, sound recordings, visual vehicle condition data, local time, local time zone,
owner name and geographic location.

You may use your mobile device to add notes, tags, or sound or voice memos to TRUscore data recordings you make with any
TRUscore connected device. Many users use this feature to supplement TRUscore data recordings with pictures or video
information concerning vehicles, repairs, or information related to their specific vehicle’s health conditions. Please note that we
collect information provided through notes, tags, or voice memos, including any personal or sensitive information you choose
to provide through this feature.

Information Collected From Your Phone. In addition to the collection described above, we collect basic information from your
mobile device, including device model and OS version, device ID, device language, activities within the App and how long the App is

If you choose to connect your mobile device to a compatible third-party service, such as TRUscore Certified Market Places, AUL
Corp., finance or trade evaluators, or any other third party offered through our site as a convenience, with your permission, we
collect information from your user profile including but not limited to: name, username and email address.

When You Use A Premium Feature. When you choose to participate in a premium service, we collect additional information from
you related to those services. Some premium features are paid services. When you make payments through the Service, you may
need to provide your shipping address and financial account information, such as your credit card number, to our third-party service
providers. We do not collect or store financial account information, though we may receive transaction identifiers and summary
information that does not include credit card or bank account numbers.

When You Contact Us. When you contact Navigation Research Company directly, such as when you contact our Customer
Support team, we will receive the contents of your message or any attachments you may send to us, as well as any additional
information you choose to provide.

How We Use Your Information
We process your information, including your personal information, for the following purposes:

 To provide our Service to you, to communicate with you about your use of our Service, to respond to your inquiries, and for other
customer service purposes.

 To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and
instructions, and to otherwise personalize your experiences while using the Service.

 To research and develop new products and features, to the extent permitted by law and, where required, with your consent.

 For marketing, promotional and informational purposes, to the extent permitted by law and, where required, with your consent. For
example, we may use your information, such as your email address, to send you news and newsletters, special offers, and
promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information
that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving these emails at
any time as described below.

 To better understand how users access and use our Service, both on an aggregated and individualized basis, in order to improve
our Service and respond to user desires and preferences, and for other analytical purposes.

 To tailor the content and information that we may send or display to you, to help us understand if a recorded scan charged to your
account is a dealers vehicle data, an auction vehicles data, a “for sale by owner” vehicle data or for internal use; a test for the
system to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while
using the Service.

 To administer surveys and questionnaires.

 To comply with legal obligations, as part of our general business operations, and for other business administration purposes.

 Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving
potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy.

How We Share Your Information. We may share your information, including personal information, as follows:

Navigation Research Company Third Party Partners. We may share data collected from your devices from the Service with
other third-party partners, excluding your personal information.

Navigation Research Company. We may share data collected from your devices, including information collected from your
connected devices, with anyone that we designate to receive your information, excluding your personal information.

Aggregate and De-Identified Information. We may share aggregate or de-identified information—so that it cannot reasonably be
used to identify an individual or vehicle—with third parties for marketing, advertising, research or similar purposes.

Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and
disclosure of your personal information will be subject to this Policy.

Service Providers. We provide selected information we collect from you to third party vendors, service providers, contractors or
agents who perform service functions needed by us to run the business, such as providers of hosting, email communication,
customer support services, analytics, marketing, and advertising, based on our instructions, and in compliance with this Policy and
any other appropriate confidentiality and security measures.

Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to
another company, or as part of a bankruptcy proceeding or reorganization, we will give affected users notice before transferring any
personal information to a new entity.

In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial
proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

 Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders,
or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we
provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or
counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to
a person.

To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate,
prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person
or vehicle, or a fraud in violations of our Terms of Use or this Policy, or as evidence in litigation in which TRUscore Certified or
Navigation Research Company is involved.

Third Party Analytics. We use automated devices and applications internally for our Service and to monitor our external web
services for TRUscore Certified Market Places, our Ai based Condition analytics, and our apps. We use third parties services such
as Google Analytics and MixPanel, to evaluate usage of our Web Service. We also may use other analytic means to evaluate our
Service. We use these tools to help us improve our Service, performance, and user experiences. Users may opt-out of Mixpanel’s
analytics tracking by visiting If you choose to use the Mixpanel opt-out, you will need to access the opt-
out on each device you use.

Privacy Shield Information For EU and Swiss Individuals

Navigation Research Company complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework
as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred
from the European Union and Switzerland to the United States pursuant to the Privacy Shield. Navigation Research Company has
certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in
this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy
Shield program, and to view our certification, please visit

In compliance with the Privacy Shield Principles, Navigation Research Company commits to resolve complaints about your privacy
and our collection or use of your personal information pursuant to the Privacy Shield. EU and Swiss individuals with inquiries or
complaints regarding our Privacy Shield policy should first contact Navigation Research Company at the contact address below.
Navigation Research Company, Inc.
Attn. Privacy
P.O. Box 2079
Liberty Texas 77575

Navigation Research Company has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to
BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the
Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please visit for more information and to file a

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option
may be available before a Privacy Shield Panel.

The Federal Trade Commission has jurisdiction with enforcement authority over Navigation Research Company, Inc. compliance
with the Privacy Shield.

The Privacy Shield Principles describe Navigation Research Company’s accountability for personal data that it subsequently
transfers to a third-party agent. Pursuant to the Privacy Shield Principles, Navigation Research Company remains liable for the
transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to
the damages.

Note that Navigation Research Company may be required to release the personal data of EU and Swiss individuals pursuant to the
Privacy Shield in response to legal requests from public authorities including to meet national security and law enforcement


Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins
and account settings. In addition to improving user experience, we use cookies and similar technologies for analytic and advertising
purposes. You can manage your cookies locally by adjusting your browser settings, or you can opt-out of targeted advertising
through cookies by visiting or Because there is not yet a common
understanding of how to interpret Do Not Track signals, we are unable to respond to Do Not Track requests from browsers, however
we are monitoring for updates and will revisit this policy once a common standard is established.

Third-Party Links

Our Service may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy
Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information
practices of such third party websites.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access,
disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things,
signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping
your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your
account via unauthorized password activity.

Access to, Storage of and Deleting My Personal Information

You may access and modify personal information that you have submitted by logging into your account and updating your profile
information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and
archived pages of the Service for a period of time. Your personal data including sent scan data are stored and accessible on your
device from the TRUscore Certified cloud.

We store information associated with your account until your account is deleted. You can delete your account at any time by
contacting Customer Support at Please note that it may take a bit of time to delete your account
information, and we may preserve it for legal reasons or to prevent harm, including as described in the How Information Is Shared

What Choices Do I Have Regarding Promotional and Informational Emails?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out
instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. We may
still send you emails about your account or any services you have requested or received from us.

Users Under 18

Our services are not designed for users under 18. If we discover that a user under 18 has provided us with personal information, we
will delete such information from our systems.

Your California Privacy Rights.

This Privacy Policy complies with the California Consumer Privacy Act (CCPA), which requires that we provide California residents
with notice that you have the right to:

 opt-out of the sale of personal information,

 know about personal information collected, disclosed or sold,

 to request deletion of personal information, and

 to be treated without discrimination should you exercise these rights.

More information regarding the: sources from which we collect personal information can be found above in the section titled “The
Information We Collect About You”; business and commercial purposes for which we collect your personal information can be
found above in the section titled “How We Use Your Information”; categories of recipients with whom personal information is
shared or sold can be found in the section above titles “How We Share Your Information.”

We do not sell any personal information collected from your use of the Navigation Research Company TRUscore Certified Service.

We do use cookies on our website that collect and share information collected from your browser for behavioral targeting which is a
“sale” under the CCPA. We will not do this if you click the “Do Not Sell My Personal Information” link on the website. In addition you
can opt out of all collection of your data for behavioral advertising by visiting or

To make a request under the California Consumer Privacy Act, or for any questions or concerns about our Privacy Policy or
practices, please contact us at

GDPR – Rights For EEA Users and Navigation Research Company Capabilities for Worldwide Users

What Rights Do I Have? Individuals located in the European Economic Area (EEA) have certain rights in respect of your personal
information. Navigation Research Company will provide the capabilities to exercise these certain rights to all our worldwide users,

 the right of access to your personal data;

 the right to correct or rectify any inaccurate personal data;

 the right to restrict or oppose processing of personal data;

 the right to erase your personal data; and

 the right to personal data portability.

We rely on your consent as a lawful basis processing personal data for the following purposes:

 initial collection of personal data through the Service;

 providing you with marketing or promotional communications. You may opt out of such communications at any time by clicking the
“unsubscribe” link found within Navigation Research Company or TRUscore Certified email updates and changing your contact

We process personal data in order to perform our contract with you.

Additionally, we process personal data based on our contractual obligations to provide you the Service as described in the section
“How We Use Your Information”, including:

 To enable the Service to function as expected;

 To communicate with you in response to customer service inquiries, to deliver non-promotional, service-related emails, or to
administer surveys and questionnaires; and

 To tailor your experience based on your general region. For example, we process mechanical and electrical Interpretation Service
requests from EEA-based users through an EEA-based mechanical and electrical Services partner.
In some cases, Navigation Research Company may process vehicle data and other information pursuant to a legal obligation or to
protect your vehicle in the Untied States.

How May I Exercise My Individual Rights? Navigation Research Company or TRUscore Certified users whose data is governed
by this Privacy Policy located worldwide may access and update their personal information as follows:

 Account holders may access and update personal information through their account settings in the Navigation Research platform;

 Account holders may exercise their rights to data deletion and data portability by contacting Navigation Research’s Data Controller
Representative at

 Navigation research Company does not retain any personal information from users who do not create TRUscore Certified accounts.
Please note that Navigation Research Company may request additional information from you to verify your identity before we
disclose any personal or account information.

Contact Us

If you have questions about our privacy practices, please contact us at
Navigation Research Company, Inc.

Attn. Privacy
P.O. Box 2079
Liberty TX 77575

If you are an EEA customer and are unable to reach Navigation Research Company at the contact information provided above
regarding your issue, you have the right to contact your local Data Protection Authority.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to
check back periodically. We will post any changes to this Policy on our Service. If we make any changes to this Policy that materially
affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you
with notice in advance of such change.

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