ALL 160 DRIVING ACADEMY LOCATIONS ARE CERTIFIED BY THE FEDERAL DEPARTMENT OF TRANSPORTATION’S ENTRY LEVEL DRIVER TRAINING REQUIREMENT THAT WENT INTO EFFECT 2/7/22.

Rock Gate Capital, LLC (d/b/a 160 Driving Academy) (“Company,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices; all only in the context of a Visitor’s use of the 160 Driving Academy website. We provide this service to you (as described in the applicable Terms of Service), including through our website located at www.160drivingacademy.com (the “Site”), and through related services (collectively, such services and Site, and any new features thereof the “Service(s)”). Capitalized terms used herein but not defined shall have the meanings ascribed to them in the applicable Terms of Service.

This Privacy Policy is incorporated into and forms part of the Terms of Service available at www.160drivingacademy.com/terms that are applicable to you.

This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices.

Before using the applicable Services or submitting any Personal Data to Company, please review this Privacy Policy carefully and contact us if you have any questions. By using the applicable Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Services.

PERSONAL DATA WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

Personal Data You Provide: We collect Personal Data when you visit the Site or use the Services (including submitting a contact form). The Personal Data collected during these interactions may include:

Identification Information: your name, email address, telephone number, your zip code, and other information you share via the Service, in each case only to the extent permitted by applicable law.

Personal Data We Receive Automatically From Your Use of the Service: When you visit, use and interact with the Service, we may receive and store certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:

Anonymized and Aggregated Information. We may anonymize Personal Data, and separate your Score or other results from your Assessment from information that could be used to identify you (as a Visitor), aggregate such data with other similar data and use the anonymized and/or aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other business purposes, and we may share such anonymized and/or aggregated information. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect anonymized information, including system information, through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact usinfo@160drivingacademy.com. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding other administrative matters and to respond to your requests.

SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is the longer.

UPDATE YOUR INFORMATION

Please contact us at privacy@160drivingacademy.com if you need to change or correct your Personal Data.

AGE RESTRICTIONS

Our Service is not directed to individuals who are under the age of 18. Company does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Company through the Service please contact us at privacy@160drivingacademy.com and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES

The Service may contain links to other websites not operated or controlled by Company, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

YOUR CHOICES REGARDING PERSONAL DATA

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us at privacy@160drivingacademy.com to ask us to update or correct your Personal Data.

CHANGES TO THE PRIVACY POLICY

The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use the Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

CALIFORNIA PRIVACY RIGHTS

Collection, Disclosure, and Use of Personal Data: The categories of Personal Data we have collected in the preceding twelve months are described above in the “ Personal Data We Collect ” section. In the preceding twelve months, we have disclosed for business purposes each of the categories identified in that section to the third parties identified in the “ Sharing And Disclosure Of Personal Data ” section. The business and commercial purposes for collecting Personal Data are described in the “How We Use Personal Data” section. We collect Personal Data directly from you and from your use of the Service.

Privacy Rights: If you are a California resident, you may have the following rights, where applicable and subject to any applicable exceptions:

We do not sell your Personal Data.

Exercising Your Rights: California residents can exercise the above privacy rights by emailing us at privacy@160drivingacademy.com or calling us at (877) 350-0884.

Verification: In order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your login credentials (to the extent you have created an account to use the Services) or by other means before you can submit a request to know or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification. If we cannot verify your identity, we will not provide or delete your Personal Data.

Authorized Agents: You may submit a request to know or a request to delete your Personal Data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

CONTACT US

If you have any questions about our Privacy Policy or information practices, or need to access this Privacy Policy in a different format, please feel free to contact us at our designated request address:

privacy@160drivingacademy.com 500 Davis Street Evanston, Illinois 60201