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Privacy Policy

Version 2.0 · Effective April 2026

1. Introduction and Scope

Dealer Intelligence Group, LLC (“Company,” “we,” “us,” or “our”) operates Skillbase (the “Platform”), a pre-employment assessment platform designed for automotive dealerships and related employers. This Privacy Policy governs the collection, use, retention, disclosure, and protection of all personal information processed through the Platform, including information submitted by employer clients (“Employers”), hiring managers (“Hiring Managers”), and job candidates who complete assessments (“Candidates”).

This Policy applies to all users of the Platform regardless of their state of residence and is designed to comply with applicable federal and state privacy laws across all fifty (50) states. Because the Platform is available nationwide, we have adopted the standards of the most stringent applicable state laws as a baseline. This Policy is incorporated by reference into the Platform’s Terms of Service and Candidate Disclosure Form.

2. Definitions

• “Candidate” means any individual who completes or is invited to complete an assessment on the Platform.
• “Employer” or “Hiring Manager” means any organization or individual who registers an account, purchases a subscription, and uses the Platform to administer assessments to Candidates.
• “Assessment Data” means all data generated by or collected from a Candidate in connection with a Platform assessment, including responses, scores, fit indices, trait profiles, competency ratings, and completion metadata.
• “Employer Account Data” means all information associated with an Employer’s account, including contact details, billing records, subscription information, and usage data.
• “De-Identified Data” means data from which all personal identifiers have been removed such that it cannot reasonably be used to identify any individual or organization.
• “Platform” means the Skillbase web application, associated APIs, reports, and all related services operated by the Company.

3. Information We Collect

3.1 From Employers and Hiring Managers

• Name, business email address, job title, and dealership or organization name
• Account credentials (passwords stored as bcrypt hashes — we never store plaintext passwords)
• Billing and payment information (processed and stored by Stripe; we do not store card numbers or full payment details)
• Usage data: login timestamps, assessments administered, reports accessed, feature interactions, and session metadata
• Communications: emails, support requests, and correspondence with the Company

3.2 From Candidates

• Name and email address (provided by the Hiring Manager at the time of invitation)
• Assessment responses, including answers to behavioral, situational judgment, and knowledge-based questions
• Computed scores, fit indices, personality trait profiles, competency ratings, and narrative report content
• Completion timestamps, session duration, and assessment integrity metadata
• Consent records: timestamp, IP address, and version of terms accepted at the time of assessment
• Browser type, device type, and session identifiers for assessment integrity purposes

Candidate data is collected on behalf of and at the direction of the inviting Employer. The Employer is responsible for ensuring Candidates have received appropriate notice and provided any required consents prior to receiving an assessment invitation.

3.3 Automatically Collected Technical Data

• IP addresses and general geographic region derived therefrom
• Browser type and version, device type and operating system
• Pages accessed, time and duration of sessions, and navigation paths
• Error logs and performance data used to maintain Platform integrity

4. How We Use Your Information

4.1 Employer and Hiring Manager Data

• To provision, operate, and maintain Platform accounts and subscriptions
• To process payments and manage billing through Stripe
• To communicate regarding account activity, subscription renewal, product updates, and support
• To market additional Platform features and services to active and former Employers
• To analyze aggregate usage patterns to improve Platform features and user experience
• To comply with legal obligations and defend against legal claims

4.2 Candidate Data

• To administer assessments and generate scoring reports for the inviting Employer
• To deliver completed assessment reports to the Hiring Manager who initiated the assessment
• To maintain assessment integrity and detect anomalous or invalid response patterns
• To improve the Platform’s assessment instruments, scoring algorithms, and psychometric models using de-identified and aggregated data
• To develop industry benchmarks and normative datasets using de-identified and aggregated data
• To comply with legal obligations and defend against legal claims

4.3 De-Identified and Aggregated Data

We may use, publish, license, or commercialize De-Identified Data derived from Assessment Data — including industry benchmark statistics, role-specific competency norms, performance prediction correlations, and platform-wide scoring distributions — for any lawful business purpose without restriction. Such data will not identify any individual Candidate, Employer, or dealership.

5. Legal Basis for Processing

• Consent: Candidates provide consent to assessment data collection through the Candidate Disclosure process prior to assessment. Employers provide consent through account registration and acceptance of the Terms of Service.
• Contractual Performance: Processing Employer account data and delivering assessment results are necessary to fulfill the Platform subscription agreement.
• Legitimate Interests: We process data to improve assessment validity, develop benchmarks, maintain Platform security, and grow our business.
• Legal Obligation: We process data as required by applicable federal and state law.

6. Data Retention

6.1 Candidate Assessment Data

Candidate Assessment Data is retained for five (5) years from the date of assessment completion. This retention period is supported by the following documented legitimate business purposes:

• Psychometric validation: longitudinal tracking of assessment scores against real-world job performance outcomes is necessary to establish and maintain the statistical validity of the Platform’s assessment instruments
• Industry benchmarking: accumulation of role-specific, region-specific, and dealership-type-specific normative data over time is necessary to generate accurate comparative benchmarks
• Legal defense: retention supports the Company’s ability to defend against claims that assessments were discriminatory or invalid
• Regulatory compliance: certain state employment laws require employers and their vendors to retain hiring-related records for specified periods

After five (5) years, Assessment Data will be de-identified and may be retained indefinitely in de-identified form for benchmarking and model improvement purposes. Individually identifiable Assessment Data will be deleted.

6.2 Employer Account Data

• Active account data: retained for the duration of the subscription
• Post-termination account data: retained for five (5) years after account closure
• Billing and financial records: retained for seven (7) years as required by applicable tax and accounting law
• Support and communication records: retained for three (3) years

6.3 Technical and Analytics Data

Automatically collected technical and analytics data is retained for up to two (2) years in identifiable form, then purged or de-identified.

6.4 Deletion Requests

Candidates and Employers may request deletion of their personal data as described in Section 9. Deletion requests are subject to the limitations set forth therein, including the Company’s right to retain data for legal defense, regulatory compliance, and de-identified benchmarking purposes.

7. Disclosure and Sharing of Information

7.1 Employers

Completed Candidate Assessment Data — including scores, fit indices, trait profiles, and narrative reports — is shared with the Hiring Manager who sent the assessment invitation. The Employer is responsible for the lawful use of this information within their hiring process and organization.

7.2 Service Providers

• Stripe — payment processing. Stripe processes billing information subject to Stripe’s own privacy policy and PCI DSS compliance standards.
• Resend — transactional email delivery for assessment invitations and report notifications.
• Cloud infrastructure providers — secure database hosting, storage, and application infrastructure. These providers operate under data processing agreements and are prohibited from independent use of Company data.

All service providers are contractually required to process data only as directed by the Company, maintain appropriate security standards, and not disclose data to third parties.

7.3 Legal and Regulatory Disclosure

We may disclose information without prior notice when required by law, court order, valid legal process, or governmental authority, or when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of the Company, our users, or others.

7.4 Business Transfers

In connection with any merger, acquisition, reorganization, sale of assets, bankruptcy, or similar transaction, personal information may be transferred to a successor entity without separate notice or consent. Any successor will be bound by this Policy as in effect at the time of transfer unless it provides notice of a new policy.

8. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect personal information, including:

• Encryption of data in transit using TLS/HTTPS
• Bcrypt hashing of all passwords — plaintext passwords are never stored
• JWT-based session management with automatic expiration
• Row-level database security and restricted access controls
• Secure cloud infrastructure with access logging and monitoring

9. Your Privacy Rights

9.1 Employer and Hiring Manager Rights

Employers may access, update, export, or request deletion of their account data by contacting us at legal@dealerintelgroup.com.

9.2 Candidate Rights

Candidates have the following rights with respect to their personal data, exercisable by contacting us at legal@dealerintelgroup.com:

• Access: request a copy of the Assessment Data we hold about you
• Correction: request correction of inaccurate personal information
• Deletion: request deletion of your Assessment Data, subject to the limitations in Section 9.4
• Portability: request your Assessment Data in a structured, machine-readable format
• Objection: object to processing of your data on grounds relating to your particular situation

We will respond to verifiable Candidate requests within thirty (30) days, or such shorter period as required by applicable law.

9.3 Verification

We will verify the identity of any individual submitting a privacy rights request before taking action. Requests that cannot be reasonably verified may be denied.

9.4 Limitations on Deletion Rights

The Company may retain data notwithstanding a deletion request where retention is necessary to: (a) comply with a legal obligation; (b) defend against pending or reasonably anticipated legal claims; (c) complete an active assessment engagement; (d) maintain de-identified benchmarking data; or (e) exercise rights under applicable law.

9.5 No Retaliation

We will not retaliate against any individual for exercising their privacy rights. Candidates who exercise deletion rights will not have their request reported to the Employer who invited them.

10. Cookies

The Platform uses only functional cookies and session storage necessary for authentication and session management. We do not use advertising cookies, behavioral tracking pixels, or third-party analytics cookies on the Platform.

11. Children’s Privacy

The Platform is directed solely to adult professionals (18 years of age or older) in a business context. We do not knowingly collect personal information from individuals under 18. If we learn we have done so, we will delete it promptly. Employers are prohibited from inviting individuals under 18 to complete Platform assessments.

12. State-Specific Privacy Disclosures

The following disclosures are made in compliance with applicable state privacy laws. Where a state-specific right is more protective than the general rights in Section 9, the state-specific provision controls for residents of that state.

12.1 California Residents (CCPA/CPRA)

California residents have the right to know, delete, correct, and opt out of the sale or sharing of personal information. We do not sell personal information. We do not share personal information for cross-context behavioral advertising. California residents may submit requests through an authorized agent with written authorization.

12.2 Illinois Residents — Assessment-Specific Notice (BIIPA)

Illinois residents are entitled to specific protections under the Artificial Intelligence Video Interview Act and related assessment regulations:

• The Company does not use facial recognition technology or video analysis in its assessments.
• Assessment instruments are designed and validated to assess job-relevant competencies and are not intended to assess protected characteristics.
• Employers are prohibited from using Platform assessment results as the sole basis for disqualifying a Candidate from consideration.
• Illinois Candidates may request deletion of their assessment data by contacting legal@dealerintelgroup.com.

12.3 New York Residents

New York City’s Local Law 144 regulates the use of automated employment decision tools (“AEDTs”). Employers using the Platform in New York City are responsible for ensuring compliance with Local Law 144 requirements applicable to them, including required bias audits and candidate notifications.

12.4 Virginia, Colorado, Connecticut, Texas, Florida, Utah, Oregon, Montana, and Other Comprehensive Privacy Law States

Residents of these states have rights under their respective state comprehensive privacy laws to access, correct, delete, and obtain portable copies of personal data, and to opt out of the sale of personal data and targeted advertising. We honor these rights as described in Section 9.

Appeal Process: If we deny your privacy rights request, you may appeal by submitting a written appeal to legal@dealerintelgroup.com within forty-five (45) days of our response. We will respond to appeals within sixty (60) days.

12.5 Washington State — My Health My Data Act

To the extent the Washington My Health My Data Act applies to any data collected through the Platform, we will comply with its requirements. Personality trait data and behavioral assessment data collected for employment purposes is not consumer health data as defined under the Act; however, we will evaluate applicability on a case-by-case basis.

12.6 Nevada Residents

Nevada residents may opt out of the sale of covered information under Nevada Revised Statutes Chapter 603A. We do not sell covered information for monetary consideration. To submit an opt-out request, contact legal@dealerintelgroup.com.

12.7 All Other States

Residents of all other states are subject to this Policy as written and have such rights as are mandated by applicable law.

13. Employer Compliance Obligations

Employers using the Platform bear independent legal obligations with respect to their use of assessment data in hiring decisions. By using the Platform, each Employer represents, warrants, and agrees that:

• It will use Platform assessment results only as one factor among many in a lawful, non-discriminatory hiring process
• It will not use assessment results as the sole basis for disqualifying any Candidate from consideration
• It has provided all required disclosures to Candidates under applicable federal and state employment law
• It will comply with all applicable state-specific requirements for automated employment decision tools
• It will not use Platform assessment results to discriminate against Candidates on the basis of any legally protected characteristic
• It will maintain appropriate internal records of its hiring process as required by applicable equal employment opportunity law

The Company bears no liability for an Employer’s failure to comply with applicable employment law in connection with its use of Platform assessment results.

14. Changes to This Policy

We reserve the right to modify this Privacy Policy at any time. Material changes will be communicated to registered Employers via email at least fourteen (14) days before the changes take effect. Changes to address new legal requirements may take effect immediately upon posting. Continued use of the Platform following the effective date of any change constitutes acceptance of the modified Policy.

15. Dispute Resolution — Mandatory Arbitration and Class Action Waiver

15.1 Agreement to Arbitrate

ANY DISPUTE, CLAIM, OR CONTROVERSY ARISING OUT OF OR RELATING TO THIS PRIVACY POLICY, THE PLATFORM, OR THE COLLECTION, USE, OR DISCLOSURE OF PERSONAL INFORMATION SHALL BE RESOLVED EXCLUSIVELY BY BINDING INDIVIDUAL ARBITRATION ADMINISTERED BY THE AMERICAN ARBITRATION ASSOCIATION UNDER ITS CONSUMER ARBITRATION RULES THEN IN EFFECT.

15.2 Class Action Waiver

15.3 Limitation of Actions

Any claim arising from this Privacy Policy must be brought within one (1) year of the date on which the claimant knew or reasonably should have known of the claim, or it is permanently barred.

15.4 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY’S TOTAL LIABILITY TO ANY EMPLOYER, HIRING MANAGER, OR CANDIDATE FOR ANY CLAIM ARISING OUT OF OR RELATED TO THIS PRIVACY POLICY OR THE PLATFORM SHALL NOT EXCEED THE GREATER OF: (A) THE TOTAL FEES PAID BY THE APPLICABLE EMPLOYER IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM; OR (B) ONE HUNDRED DOLLARS ($100.00). IN NO EVENT SHALL THE COMPANY BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES.

16. Governing Law

This Privacy Policy is governed by the laws of the State of Alabama, without regard to its conflict of laws principles. Any dispute not subject to arbitration under Section 15 shall be resolved exclusively in the state or federal courts of Jefferson County, Alabama.

17. General Provisions

• Severability: If any provision is found invalid or unenforceable, the remaining provisions remain in full force and effect.
• No Waiver: Failure to enforce any provision at any time does not constitute a waiver of the right to enforce it in the future.
• Assignment: The Company may assign its rights and obligations under this Policy without restriction. Users may not assign their rights without prior written consent of the Company.
• No Third-Party Beneficiaries: This Policy does not create rights in any third party, except as expressly stated herein.
• Entire Agreement: This Policy, together with the Terms of Service and Candidate Disclosure Form, constitutes the complete agreement between the parties regarding the privacy and data practices of the Platform.

18. Contact

For privacy requests, questions, or concerns:

Dealer Intelligence Group, LLC — Skillbase
Email: legal@dealerintelgroup.com
Attn: Privacy — Skillbase Platform
Birmingham, Alabama 35242