Online Privacy Policy / Your Privacy Rights

(Effective October 15, 2010)

Welcome to Klaben Automotive Group, Inc.'s website, www.klaben.com (the "Site"). The protection of your personal information is important to our Dealerships. Because we recognize that keeping your personal information private is also important to you, we would like to take this opportunity to explain our Online Privacy Policy ("Policy" or "Privacy Policy"). Klaben Automotive Group, Inc. and its family of companies is sometimes referred to in this Policy as "Klaben," "we," "us," or "our."

Our Online Privacy Policy is set forth in detail below. However, we would like to take this opportunity to notify you that Klaben does not sell, rent or lease personal information to any third parties for their marketing use, or otherwise disclose personal information submitted via our Site except as set forth in our Policy below. We hope that this Policy will provide you with a level of comfort regarding our privacy practices and instill confidence in using our Site and conducting business with Klaben. We value our customers, and through the disclosure of our online privacy practices, we hope to facilitate and maintain a long-lasting relationship with you.

Please note that our Site integrates other websites and may be integrated into other websites, which may or may not be owned or operated by Klaben. Therefore, we urge you to review the privacy policy posted on each website before providing any personal information via that site. For more information, please see "About our Online Privacy Policy" and "Links to Other Websites" below.

If you are a California resident, please see "California Privacy Rights" below for a statement regarding your right to obtain a list of third parties with whom we have shared your personal information.

About Our Online Privacy Policy

The goal of our Site is to provide you with information regarding our products and services and to enable us to respond to your inquiries and requests for information and services. This Online Privacy Policy explains:

- The type of information we may collect about you via our Site
- How we may use that information
- With whom that information may be shared
- How we protect the information we collect about you
- What choices are available to you regarding your information
- How you can contact us regarding this Online Privacy Policy and your personal information

Please note that this Online Privacy Policy applies to personally and non-personally identifiable information collected only online within the United States via our Site, and does not apply to information collected by Klaben through any other means. When this Policy uses the term "personally identifiable information" or "personal information," we mean information that identifies a particular individual, such as the individual's name, postal address, e-mail address or telephone number. When other information is directly associated with personally identifiable information, this other information also becomes personally identifiable information for purposes of this Policy.

In addition, Ford Motor Company (Ford/Lincoln) and Chrysler Group LLC (Chrysler/Jeep/Dodge/Ram) design, provide and operate websites for various dealers, including Klaben (e.g., http://klabenfordonline.dealerconnection.com; http://klabenscrown.dealerconnection.com; http://www.klabenchryslerjeepdodge.com), and you may voluntarily submit personal information via these sites. Auto classifieds marketplace websites such as AutoTrader.com may also allow you to voluntarily submit personal information in order to communicate with us. To the extent that Klaben controls the collection, use and disclosure of personal information submitted via any such website, or receives or has access to personal information collected via such site, this Policy shall apply and that website shall be included as a "Site." In the event of any inconsistency between this Policy, the Ford Motor Company Dealer Connection On-Line Privacy Statement, and/or the privacy statement posted on our Chrysler Digital Dealer website, this Online Privacy Policy shall govern and control our policies concerning the collection, use and disclosure of your information.

Users located outside the United States should not provide any personal information via our Site. By providing personal information via our Site and/or by using our Site, all users, including, but not limited to, users in the European Union, fully understand and consent to the collection and processing of such information in the United States and to Klaben's use and disclosure of user information in accordance with this Policy.

Your Consent

PLEASE BE SURE TO READ THIS ENTIRE ONLINE PRIVACY POLICY BEFORE USING OR SUBMITTING PERSONAL INFORMATION VIA OUR SITE. WHEN YOU ACCESS OR USE OUR SITE, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

The Type Of Information We May Collect About You

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Personal Information

In general, you can visit our Site without telling us who you are or revealing any personal information about yourself. Klaben does, however, offer visitors the opportunity to contact our company directly via our Site and voluntarily provide us with personal information. In addition, access to and/or utilization of certain portions of our Site may require registration or submission of customer or employee information.

We may collect personal information from you when you voluntarily provide it to us via our Site by:

- Completing and submitting any of the electronic forms made available to you via our Site. These include, but are not limited to, forms to make inquiries, request information, products or services from us, or schedule appointments.
- Sending us email through any of the email addresses provided via our Site.
- Registering via our Site.
- Accessing and/or utilizing any password-protected portions of our Site or any customer or employee-specific portions of our Site.

In connection with these activities, we may collect various types of personal information from you, including, but not limited to, your name, physical address, e-mail address, telephone number, fax number, other demographic information, vehicle information, username, password, social security number, financial information and any other personal information you provide. If you request e-mail contact from us, send us e-mail or submit an electronic form, we may also retain the messages and completed forms themselves. If you do not wish to submit personal information to us via our Site, we encourage you not to engage in any of the activities listed above.

Also, please note that we and our affiliates may have access to or obtain personal information submitted by you via websites owned and/or operated by third parties, but with whom we have a business relationship (e.g. information submitted in connection with the Loyalty Link Plus Program, information submitted via a manufacturer-related website such as Ford.com or Chrysler.com, information submitted via a credit-related website owned and/or operated by Chrysler Financial, Ally Financial or Ford Motor Credit Company, information submitted through online auto classifieds marketplaces such as AutoTrader.com).

Non-Personal Information:

As part of the standard operation of our Site, we may collect, obtain and/or access certain non-personal information from you including, but not limited to, your browser type (e.g., Netscape or Internet Explorer), operating system (e.g., Windows or Macintosh), Internet Service Provider ("ISP"), IP address, Web sites visited, and the domain name from which you accessed our Site (e.g., google.com). In addition, we may collect, obtain and/or access information about your browsing behavior, such as the date and time you visited our Site, the areas or pages of our Site that you visit, the amount of time spent viewing our Site, the number of times you return to our Site, and other click-stream data.

We may also utilize "cookies" in connection with our Site (as many companies do). A "cookie" is an online device used to track traffic patterns and usage and to provide you with more customized service by identifying you as a user, which may prevent you from having to enter information repeatedly. Cookies are often used online and do not harm your computer, nor do they identify you by name or address unless you have provided the information or set up your computer to do so. You have the option of programming your computer to prevent a cookie from being accepted. The "help" segment of the toolbar on most browsers explains how to configure a browser to not accept new cookies, how to have the browser inform a user when they receive a new cookie, and how to erase cookies from a computer's hard drive.

Children's Privacy

Our Site and any products or services provided via our Site are not intended to target, and are not structured to attract, children under the age of 13. We do not knowingly solicit or collect personal information from or about children under the age of 13 and we do not knowingly market our products and services to children under the age of 13. If Klaben discovers personal information submitted via our Site from a child under the age of 13, we will eliminate that information. If a parent or guardian notifies us that we have unknowingly collected via our Site personal information from a child under the age of 13, we will eliminate that information at the parent or guardian's request.

How We Use Your Information

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Personal Information

The personal information that you provide to Klaben via our Site, and any personal information we obtain or have access to, which was submitted by you via websites owned and/or operated by third parties with whom we have a business relationship, may be stored, processed, and used by us (including our affiliated companies -- companies that are related by common ownership or corporate control) for the following purposes:

- To address and respond to your inquiries, comments and requests/orders for information, products and/or services.
- To schedule and follow-up on appointments requested by you.
- To send you service-related surveys.
- To contact you via phone, email or direct mail for marketing/promotional purposes related to Klaben, its affiliates and their respective products and/or services.
- For internal marketing and research purposes and to learn about customer needs and interests.
- To compile, generate and/or analyze information for trends and statistics.
- To improve products and services offered by Klaben and/or our affiliates, and to develop new products and services.
- To help administer, address problems with and improve our Site.
- To protect the security and/or integrity of our Site.
- To help conduct internal reviews of our Site.
- To make our Site easier to use by eliminating the need for you to repeatedly enter the same information or by customizing our Site to your particular interests or preferences.
- To match personal information collected via our Site with information about you collected offline.
- Any other purposes authorized by you.

If you provide personal information to Klaben via our site, you agree that we may try to contact you in writing, by e-mail, or using prerecorded/artificial voice messages, text messages, and automatic telephone dialing systems, as the law allows. You also agree that we may try to contact you in these and other ways at any address or telephone number that you provide, even if the telephone number is a cell phone number or the contact results in a charge to you.

Like most organizations, we and our affiliates hire third parties such as agents and contractors to provide certain administrative and other services on our behalf. Such agents and contractors may have access to and may need to use certain of your personal information to the extent necessary to perform the services for which they have been hired.

A list of our affiliates is provided below under "Our Affiliates / Family of Companies."

Non-Personal Information

Non-personal information that we may collect from you via our Site (e.g., browser type, IP address, etc.) is not used by us to personally identify you. Instead this information may be compiled and/or analyzed by us and our affiliates on an aggregated basis to measure our users' habits. This helps us to measure the use of our Site, improve the content, functionality and operation of our Site and to better understand and serve our users.

With Whom Your Information May Be Shared

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It is common for companies like ours to share your information with our family of companies, including affiliated third parties. We may disclose personal and non-personal information to our affiliates for marketing, promotional and business purposes.

We may also disclose personal and non-personal information to third parties such as agents and contractors that perform services on our behalf, to third parties as necessary to provide you with any products, services or information you request, and to manufacturers (e.g. Ford Motor Company, Chrysler Group LLC) and financial sources (e.g. Chrysler Financial, Ally Financial, Ford Motor Credit Company) with whom our Dealerships conduct business.

Also, as stated above, Ford Motor Company (Ford/Lincoln), Chrysler Group LLC (Chrysler/Jeep/Dodge/Ram) design, provide and operate websites for Klaben (e.g., http://klabenfordonline.dealerconnection.com; http://klabenscrown.dealerconnection.com; http://www.klabenchryslerjeepdodge.com). Auto classifieds marketplace websites such as AutoTrader.com may allow you to voluntarily submit personal information in order to communicate with us. Information submitted by you via these websites may be accessed and used by Ford Motor Company, Chrysler Group LLC, AutoTrader.com, Inc. and/or their respective affiliates and business partners for business and marketing purposes and/or otherwise. Because Klaben does not control the use of your information by these third parties, we encourage you to contact them directly if you have any questions or concerns regarding their privacy practices.

In addition, we may disclose personal information outside of our company if you direct us to do so, or if we are required to do so as specified in more detail in "Disclosure Exceptions" below.

We do not sell, rent or lease personal information to any third parties for their marketing use. We also do not disclose any personal information submitted via cssisurvey.com outside of our company.

Disclosure Exceptions

Notwithstanding the above policies, we reserve the right to disclose, without notice to you, your personal information to appropriate third parties if we are required to do so by law or we believe that such action is necessary:

- To comply with legal process such as a search warrant, subpoena or court order.
- To protect the Klaben's or our affiliates' rights and property or defend against legal claims.
- To protect any other party's rights, property, and safety.
- To report to any law enforcement agency any activities that we, in good faith, believe to be unlawful.
- To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving harassment, abusive messages or potential threats to the physical safety of any persons.
- To protect against misuse or unauthorized use of our Site.
- During emergencies, such as when we believe someone's physical safety is at risk.
- In the event that Klaben and/or its affiliates are ever sold, acquired, merged, liquidated, reorganized, or otherwise transferred, we reserve the right to transfer our user databases, together with any personal and non-personal information contained therein, to the third party acquiring the company and/or its affiliates.

Under the United States Patriot Act, Klaben may be restricted from notifying individuals that such information has been disclosed.

How We Protect The Information We Collect About You

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We take our responsibility to protect your personal information seriously. To protect the privacy of personal information, we employ various security measures including physical access controls, Internet firewalls, software security patches, and network monitoring and intrusion detection. In addition, our company's network is PCI (Payment Card Industry) compliant. Unfortunately, no electronic communication over the Internet can be guaranteed to be 100% secure. WHILE WE STRIVE TO TAKE GREAT CARE TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT WARRANT THE SECURITY OF ANY INFORMATION THAT YOU SUBMIT TO US, AND YOU DO SO AT YOUR OWN RISK. We urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.

In addition, we restrict (as commercially practical) access to your personal information to our and our affiliates' employees and the third parties referenced above on a need-to-know basis. We explain the importance of protecting your personal information to our employees and take measures to enforce employee responsibilities regarding our Online Privacy Policy. We also maintain internal physical and procedural safeguards to protect the confidentiality and security of the personal information we collect via our Site. When dealing with third parties as set forth above, we may request that those third parties keep your personal information confidential and use that information only as expressly authorized by us.

Links To Other Websites

Our Site integrates other websites and may be integrated into other websites, which may or may not be owned or operated by Klaben. In addition, our Site may contain links to third-party websites (including, but not limited to, manufacturer-related, credit-related and service-provider websites). While we try to link to or integrate with only those third-party websites that share our standards and respect for privacy, Klaben's Policy and privacy practices do not extend to and may differ from third-party websites that can be accessed through our Site. WE ARE NOT RESPONSIBLE FOR THE CONTENT, SECURITY OR PRIVACY PRACTICES EMPLOYED BY THIRD-PARTY WEBSITES. If you are concerned, we encourage you to review and consider the privacy policies posted on third-party websites before navigating, using and/or registering with those sites.

Our Affiliates / Family Of Companies

The Klaben family of companies includes the following affiliated companies: Klaben Ford Lincoln, Inc., 1089 W. Main St., Kent, OH 44240; Klaben Ford Lincoln of Warren, Inc., 3853 Youngstown Rd., Warren, OH 44484; Klaben Chrysler Jeep Dodge, Inc., 1106 W. Main St., Kent, OH 44240; Customer Service Systems, Inc. (CSSI) (customer service & follow-up call center), 1250 W. Main St., Kent, OH 44240; and Auto Loan, Inc. (finance company), 1250 W Main St., Kent, OH 44240.

How To Contact Us; What Choices Are Available To You Regarding Your Information

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If you have any questions or concerns regarding our Privacy Policy, please feel free to contact us. In addition, you may request to review, update, correct and/or delete any personal information you have submitted to us via our Site by contacting us as follows:

E-mail: privacy@klaben.com
Mail: Klaben Automotive Group, Inc.
Attn: Administrative Office
1089 W. Main Street
Kent, OH 44240

We will take commercially reasonable steps to promptly attend to your request.

California Privacy Rights

Under California's "Shine the Light" law, California residents who have an established business relationship with us and provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us (once per calendar year) information about the customer information we shared, if any, with third parties for their own direct marketing use. If applicable, this information would include the categories of customer information shared and the names and addresses of those third parties with whom we shared customer information for the immediately preceding calendar year. For example, if you make a request during the 2009 calendar year that is covered under the law, we will provide you with information regarding any sharing activities covered under this law during the 2008 calendar year.

Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

To obtain this information please contact us as set forth above under "How To Contact Us," and include "Request for California Privacy Information" in the subject line of your correspondence. If your request is covered under the law, we will provide the requested information to you in writing or at the e-mail address you provide.

Changes To This Policy

We reserve the right to change this Online Privacy Policy at any time in our sole discretion without prior notice to you. The most current Online Privacy Policy (with the effective date) will be posted on this Site as soon as it takes effect, so that you are always aware of our privacy practices with respect to our Site. We encourage you to review our Online Privacy Policy regularly for any changes and contact us if you have any concerns regarding any such changes.

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