Last Updated: December 13, 2023

This Privacy Policy describes how Ionna LLC and our subsidiaries and affiliated companies (collectively, “Ionna,” “we,” or “us”) collect, use, and disclose information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), or when you otherwise interact with us, such as through our website or by email interaction or information requests. We may provide different or additional notices of our privacy practices with respect to certain products or services, in which case this Privacy Policy will not apply. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

If you are a California resident, please see the “Your California Privacy Rights” section.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics

Transfer of Information to the United States and Other Countries

Your Choices

Your California Privacy Rights

Additional Disclosures for Individuals in Europe

Contact Us


COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you fill out a form, submit or post content through our Services communicate with us via the Services or third-party platforms, or otherwise communicate with us. The types of information about you that we collect include your name and email address, and any other information you choose to provide.

Information We Collect Automatically

We automatically collect certain information about your interactions with us or our Services, including:

● Activity Information: We collect information about your activity on our Services, such as your time spent on our website or the features with which you interact.

● Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.

● Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).

● Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see [the Your Choices section below.

Information We Collect from Other Sources

We obtain information from other sources. For example, we may collect information from data analytics providers, and mailing list providers. This information includes your name, email address, postal address and phone number.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products, or are interested in certain information, based on your browsing behavior and past purchases.


SE OF INFORMATION

We use the information we collect to communicate and share information with you. We also use the information we collect to:

• Personalize your experience with us;

• Communicate with you about products, services, and events offered by Ionna and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);

• Provide and administer our loyalty program;

• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);

• Personalize the advertisements you see when you use our Services based on information provided by our advertising partners;

• Comply with our legal and financial obligations;

• Create de-identified, anonymized or aggregated information; and

• Carry out any other purpose described to you at the time the information was collected.


SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

● We share personal information with vendors, service providers, contractors and consultants that access personal information to perform work for us, such as companies that assist us with web hosting, customer service, and marketing and advertising.

● We share personal information with third parties for their own services and marketing purposes, unless you opt out of this type of sharing.

● We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

● We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Ionna, our users, the public, or others.

● We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

● We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

● Personal information is shared between and among Ionna and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

● We share personal information with your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.


ADVERTISING AND ANALYTICS

We engage others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Ionna and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or change your settings using the consent management tool on our Services.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests.

Note that the third-party platforms may offer you choices about whether you see these types of customized ads.


TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Ionna is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent.


YOUR CHOICES

Account Information

You may update and correct certain account information at any time by emailing us at info@ionna.com.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails from Ionna by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.


YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) afford[s] consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information: real name, email address and internet protocol address. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Categories of Personal Information We Collect

Identifiers, such as your name, alias, postal address, unique personal identifier, online identifier, email address, account name, telephone number

Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

Affiliates and subsidiaries; Service providers; Third parties necessary to complete a transaction or request or with whom you have directed us to share your information; Business partners; For legal, security, and safety purposes; In connection with a corporate transaction; Entities to which you have consented to the disclosure

Categories of Third Parties to Whom Personal Data is Sold or Shared

Not sold or shared


CONTACT US

If you have any questions about this Privacy Policy, please contact us at info@ionna.com.

IONNA LLC is a limited liability company formed by BMW, GM, Honda, Hyundai, Kia, Mercedes-Benz and Stellantis.

©2023 IONNA LLC

20800 Madrona Avenue, Torrance, CA 90503