Privacy Policy

1. Introduction

Pinto Technologies, Inc. (“Commos,” “we,” “us,” or “our”) provides software that automates administrative and back-office work for automotive dealerships. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our services, website, or products. Please read this policy carefully. If you disagree with its terms, please discontinue use of our services.

2. Two Roles, Two Sets of Rules

This policy covers two different kinds of information, and our obligations differ for each.

Information we control. This is information about our dealership clients, their personnel, and visitors to our website. We decide how it is used. Sections 3 through 9 apply to it.

Customer Data we process for a client. This is dealership and consumer information that we access or receive to perform the Services, such as records from a dealer management system (“DMS”). Our dealership client controls this information. We act as its service provider and process the information only on the client’s instructions. Section 10 applies to it.

3. Information We Collect

We may collect the following categories of information that we control:

• Account information: name, email address, phone number, job title, company name, billing details, and other registration data you provide when creating an account.
• Usage data: information about how you interact with our platform, including feature usage, job and report activity, log records, and session metadata.
• Technical data: IP addresses, browser type, device identifiers, operating system, and referring URLs collected automatically via cookies and similar technologies.
• Integration configuration: connection settings, endpoints, and credentials you provide so that we can access your systems. We store credentials in encrypted form and use them only to perform the Services.
• Communications: messages you send us directly, including support requests and feedback.

4. How We Use Your Information

We use the information we collect to:

• Provide, operate, secure, and improve the Commos platform and its features.
• Process transactions and send related billing and account information.
• Respond to customer support requests and communicate service updates.
• Monitor platform performance, detect fraud, and investigate misuse.
• Comply with legal obligations.

We use aggregated or de-identified data, which cannot reasonably be used to identify a person or a dealership, to measure and improve our systems.

5. Sharing of Information

We do not sell personal data, and we do not share it for cross-context behavioral advertising. We may share information with:

• Service providers: third-party vendors who help us operate our infrastructure, process payments, or provide analytics, each bound by confidentiality obligations and permitted to use the information only to perform services for us.
• Business transfers: in connection with a merger, acquisition, or sale of assets, information may be transferred as a business asset.
• Legal requirements: where required by law, regulation, or valid legal process, or to protect the rights, property, or safety of Pinto Technologies, Inc., our users, or others.

6. Data Retention

We retain information we control for as long as your account is active, and afterward as needed to meet legal, tax, audit, and security obligations. Retention of Customer Data is described in Section 10. You may request deletion of your data at any time by contacting us at founders@commos.co.

7. Cookies and Tracking

We use cookies and similar tracking technologies on our website to analyze usage patterns and improve our platform. You may configure your browser to refuse cookies, though some features may not function properly as a result. We do not use these technologies inside the Services to track individual consumers.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect information, including encryption in transit and at rest, role-based access controls, credential isolation, logging, and periodic security assessments. Our program is designed to meet the requirements of the Gramm-Leach-Bliley Act and the FTC Safeguards Rule where they apply to the information we handle. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

If we learn of a security event affecting Customer Data, we will notify the affected dealership client without unreasonable delay and will cooperate with that client’s own notification obligations.

9. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal data, to restrict or object to certain processing, or to opt out of profiling. Residents of Colorado, California, and other states with comprehensive privacy laws have these rights under those laws. We do not sell personal data or use it for targeted advertising, so no opt-out is needed for those activities.

To exercise these rights, contact us at founders@commos.co. We will verify your request before we act on it, and we will not discriminate against you for making one. You may appeal a denial by replying to our response.

10. Information We Process for Dealership Clients

When we perform the Services, we access records that our dealership client controls. These records may include deal and sales records, service and repair orders, parts and inventory data, accounting and reconciliation data, payroll and staff records, vendor records, and documents. They may include nonpublic personal information about the dealership’s customers, such as names, contact details, vehicle data, and financial account or transaction information.

For this information:

• The dealership is the controller. We are its service provider or processor.
• We process the information only to perform the Services and only on the client’s documented instructions.
• We do not sell it, we do not use it for our own marketing, and we do not use consumer-identifying data to train general-purpose AI models.
• We require our subcontractors to maintain comparable protections.
• We return or delete the information after the client’s agreement ends, as described in our Terms of Service, except for copies we must keep by law or that exist in routine backups.

If you are a customer of a dealership and you want to access, correct, or delete your information, please contact that dealership directly. It controls the records and can act on your request. If you contact us, we will refer you to the dealership, or we will assist that dealership in responding.

A signed data protection agreement between us and a client controls over this section to the extent of any conflict.

11. Children’s Privacy

Our services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page with an updated effective date. Your continued use of our services after any changes constitutes your acceptance of the revised policy.

13. Contact Us

For questions or concerns about this Privacy Policy, please contact:

Pinto Technologies, Inc.

Operating as Commos

founders@commos.co