CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

NOTICE AT COLLECTION AND PRIVACY RIGHTS
Asbury World Wide LLC
Effective Date: January 14, 2026
Last Updated: January 14, 2026

INTRODUCTION

This California Consumer Privacy Act (CCPA) Notice supplements the information contained in the Privacy Policy of Asbury World Wide LLC ("Asbury," "we," "us," or "our") and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you").

We have prepared this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA), and other California privacy laws. Any terms defined in the CCPA or CPRA have the same meaning when used in this notice.

This notice describes how we collect, use, disclose, and protect your personal information, and explains the rights and choices available to you with respect to your personal information under California law.

1. INFORMATION WE COLLECT

1.1 Categories of Personal Information Collected

We have collected the following categories of personal information from consumers within the last twelve (12) months:

A. Identifiers

Examples: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.
Collected: YES

B. Personal Information Categories Listed in California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

Examples: Name, signature, address, telephone number, employment, employment history, education information. Some personal information included in this category may overlap with other categories.
Collected: YES

C. Protected Classification Characteristics Under California or Federal Law

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: NO (except in job application materials where voluntarily provided)

D. Commercial Information

Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES (inquiry history, interest in products/services)

E. Biometric Information

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: NO

F. Internet or Other Similar Network Activity

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected: YES

G. Geolocation Data

Examples: Physical location or movements.
Collected: YES (approximate location derived from IP address)

H. Sensory Data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: NO

I. Professional or Employment-Related Information

Examples: Current or past job history or performance evaluations.
Collected: YES (from job applicants and business contacts)

J. Non-Public Education Information (per Family Educational Rights and Privacy Act)

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO (except in job application materials where voluntarily provided)

K. Inferences Drawn from Other Personal Information

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: YES (preferences and interests based on website interactions)

L. Sensitive Personal Information

Examples: Social security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with required security or access code, password, or credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages; genetic data; biometric information for unique identification; health information; sex life or sexual orientation information.
Collected: NO (we do not collect sensitive personal information as defined by CPRA)

1.2 Sources of Personal Information

We obtain the categories of personal information listed above from the following sources:

Directly from you When you submit forms, sign up for newsletters, apply for jobs, contact us, or otherwise interact with our website
Automatically from you Through cookies, web beacons, and other tracking technologies when you visit our website
From third parties Business partners, service providers, analytics companies, social media platforms, data brokers, and publicly available sources
From affiliates Our parent company, subsidiaries, and affiliated entities

2. USE OF PERSONAL INFORMATION

2.1 Business and Commercial Purposes

We may use or disclose the personal information we collect for one or more of the following business or commercial purposes:

To fulfill or meet the reason for which the information was provided (e.g., to respond to your inquiry, process job applications)
To provide, support, personalize, and develop our website, products, and services
To create, maintain, customize, and secure your account with us (if applicable)
To process your requests, inquiries, and applications
To provide you with support and respond to your inquiries, including investigating and addressing your concerns
To personalize your website experience and deliver content and product offerings relevant to your interests
To help maintain the safety, security, and integrity of our website, databases, technology assets, and business
For testing, research, analysis, and product development, including to develop and improve our website and services
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets
To send you marketing and promotional communications (with your consent where required)
To conduct analytics and measure website performance
As described to you when collecting your personal information or as otherwise set forth in the CCPA

2.2 No Sale of Personal Information

We do not sell personal information in the traditional sense (i.e., we do not exchange personal information for monetary compensation). However, under the broad definition of 'sale' in the CCPA, our use of certain analytics, advertising, and marketing tools may be considered a 'sale' or 'sharing' of personal information. Specifically, our use of cookies and similar technologies for targeted advertising purposes may constitute a sale or sharing under California law.

3. DISCLOSURE OF PERSONAL INFORMATION

3.1 Categories of Third Parties

We may disclose your personal information to the following categories of third parties:

Service Providers: Companies that provide services on our behalf, including website hosting, data analysis, IT services, email delivery, marketing assistance, customer service, and payment processing
Business Partners: Partners with whom we collaborate to provide products, services, or information
Affiliates: Our parent company, subsidiaries, and other affiliated entities
Analytics and Advertising Providers: Companies that help us understand website usage and deliver targeted advertising
Professional Advisors: Lawyers, accountants, auditors, and other professional service providers
Government Authorities: Law enforcement, regulators, and other government entities when required by law
Business Transferees: Entities involved in a merger, acquisition, or sale of assets

3.2 Categories of Personal Information Disclosed

In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes:

Category A: Identifiers
Category B: California Customer Records personal information categories
Category D: Commercial information
Category F: Internet or other similar network activity
Category G: Geolocation data
Category I: Professional or employment-related information
Category K: Inferences drawn from other personal information

4. YOUR CALIFORNIA PRIVACY RIGHTS

The CCPA and CPRA provide California consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

4.1 Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and verify your request, we will disclose to you:

The categories of personal information we collected about you
The categories of sources from which the personal information was collected
Our business or commercial purpose for collecting or selling that personal information
The categories of third parties with whom we share that personal information
The specific pieces of personal information we collected about you (also called a data portability request)

4.2 Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, or reasonably anticipated within the context of our ongoing business relationship
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible
Debug products to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
Engage in public or peer-reviewed scientific, historical, or statistical research that conforms to all other applicable ethics and privacy laws
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
Comply with a legal obligation
Make other internal and lawful uses of that information that are compatible with the context in which you provided it

4.3 Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you. Once we receive and verify your request, we will use commercially reasonable efforts to correct the inaccurate personal information.

4.4 Right to Opt-Out of Sale or Sharing

You have the right to opt-out of the sale or sharing of your personal information. While we do not sell personal information for monetary compensation, our use of certain analytics and advertising technologies may constitute a 'sale' or 'sharing' under the CCPA.

To opt-out of the sale or sharing of your personal information:

Click the "Do Not Sell or Share My Personal Information" link on our website
Submit a request via email to privacy@asburyworldwide.com
Adjust your cookie preferences through our cookie management tool

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize the sale or sharing of your personal information. However, you may change your mind and opt back in to sales or sharing at any time.

4.5 Right to Limit Use of Sensitive Personal Information

You have the right to limit our use and disclosure of sensitive personal information to uses necessary to perform services or provide goods reasonably expected by an average consumer who requests those goods or services. However, we do not collect sensitive personal information as defined by the CPRA, so this right does not currently apply.

4.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
Provide you a different level or quality of goods or services
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

5. EXERCISING YOUR RIGHTS

5.1 How to Submit a Request

To exercise your rights described above, please submit a verifiable consumer request to us by:

Emailing us at: info@asburyworldwide.com
Calling us at: 954-292-7171
Mailing us at: Asbury World Wide LLC, 2941 Paddock Lane, Weston, FL, 33331

5.2 Verifiable Consumer Request Requirements

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

5.3 Verification Process

We will use a two-step verification process to verify your identity before responding to your request:

Step 1: Initial Verification

We will ask you to provide identifying information such as your name, email address, and phone number that matches information we have on file. We may also ask for additional information to verify your identity.

Step 2: Additional Verification for Sensitive Requests

For requests to delete personal information or access specific pieces of personal information, we may require additional verification steps, such as requiring you to provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

If we cannot verify your identity or authority to make the request, we will not be able to respond to your request or provide you with personal information.

5.4 Authorized Agents

You may designate an authorized agent to make a request on your behalf. To designate an authorized agent, you must:

Provide the authorized agent written permission to do so
Verify your own identity directly with us

We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

If you use an authorized agent to submit a request, we may require that you provide the authorized agent written permission to do so and verify your identity directly with us. We may also require that your authorized agent provide proof of their authority to act on your behalf.

5.5 Response Timing and Format

We will acknowledge receipt of your request within ten (10) business days and provide information about how we will process your request.

We will respond to a verifiable consumer request within forty-five (45) calendar days of receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

If we cannot fulfill your request, our response will explain the reasons why. For data portability requests, we will provide your personal information in a readily usable format that allows you to transmit the information to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6. FINANCIAL INCENTIVES

We do not currently offer any financial incentives in exchange for the retention, sale, or sharing of your personal information. If we offer financial incentives in the future, we will provide you with a notice describing the material terms of the financial incentive program and obtain your opt-in consent before enrolling you in the program.

7. RETENTION OF PERSONAL INFORMATION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you
Whether there is a legal obligation to which we are subject (e.g., tax, accounting, or legal requirements)
Whether retention is advisable in light of our legal position (e.g., statute of limitations, litigation, or regulatory investigations)

8. SHINE THE LIGHT LAW

California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please contact us at privacy@asburyworldwide.com with 'California Shine the Light Request' in the subject line. Please include your mailing address, state of residence, and email address. We will respond to one request per California customer per year.

9. MINORS UNDER 16

We do not knowingly sell or share the personal information of consumers under 16 years of age. Our website is not directed to minors, and we do not knowingly collect personal information from minors under 16 years of age. If we learn that we have collected personal information from a minor under 16, we will delete that information as quickly as possible.

10. CHANGES TO THIS NOTICE

We reserve the right to amend this CCPA notice at our discretion and at any time. When we make material changes to this notice, we will post the updated notice on our website and update the 'Last Updated' date at the top of this notice.

Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

11. CONTACT INFORMATION

If you have any questions or comments about this CCPA notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us:

Asbury World Wide LLC
Emailing us at: info@asburyworldwide.com Calling us at: 954-292-7171 Mailing us at: Asbury World Wide LLC, 2941 Paddock Lane, Weston, FL, 33331