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Privacy notice

COWBOY CREDIT PRIVACY NOTICE AND FINANCIAL PRIVACY DISCLOSURE Effective Date: October 18, 2026 Version: 1.5 1. WHO WE ARE AND RESPONSIBLE LEGAL ENTITY Cowboy Credit (https://cowboy.credit and https://apply.cowboy.credit) is an automotive shopping and online credit-application division of Fremont Motor Company, doing business as Fremont Motor Companies and Cowboy Credit ("Cowboy Credit," "Fremont," "we," "us," or "our"). Cowboy Credit is not a separate legal entity, bank, or direct lender. Responsible Legal Entity and Mailing Address: Fremont Motor Company (d/b/a Fremont Motor Companies and Cowboy Credit) Attn: Privacy & Compliance Office 906 Main St Lander, WY 82520 Privacy Email: [email protected] Customer Support Email: [email protected] Telephone: (307) 202-9096 Hours: Monday–Friday, 8:00 AM – 6:00 PM Mountain Time 2. SCOPE OF THIS PRIVACY NOTICE (GLBA AND WEBSITE PRIVACY) Because automobile dealerships that arrange retail vehicle financing are financial institutions under the federal Gramm-Leach-Bliley Act ("GLBA"), the Federal Trade Commission ("FTC") Privacy Rule (16 CFR Part 313), and the FTC Safeguards Rule (16 CFR Part 314), this notice describes both our general website privacy practices and our federal financial privacy disclosures for consumers who apply for credit or request vehicle financing assistance. 3. FACTS: WHAT DOES COWBOY CREDIT (A DIVISION OF FREMONT MOTOR COMPANIES) DO WITH YOUR PERSONAL INFORMATION? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on whether you are browsing inventory, submitting a general vehicle-help request, or completing a secure credit application. This information can include: - Contact and Identity Information: Full legal name, residential and mailing address, email address, mobile telephone number, date of birth, Social Security Number ("SSN"), and driver's license or state identification details. - Financial, Employment, and Housing Information: Current and prior employer names, job title, employment tenure, gross income, additional income sources you choose to rely on for repayment, residential status (own/rent), time at address, and monthly housing payment. - Vehicle and Application Context: Selected vehicle (VIN, stock number, year, make, model, trim, and advertised price), down payment or trade-in estimates you discuss with a dealership, individual or joint application status, and co-applicant contact and credit application details. - Authentication, Consent, and Technical Records: Email verification tokens, recipient-requested SMS verification records, timestamps and cryptographic digests of the disclosures and consents you accept, opaque session references, IP-derived abuse-prevention signals (Google reCAPTCHA Enterprise), and first-party public website analytics events. How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information, the reasons Cowboy Credit / Fremont Motor Companies chooses to share, and whether you can limit this sharing: - For our everyday business purposes (such as to process your credit application, route your application to a participating dealership and prospective lenders through RouteOne, verify your identity and contact details, service your request, respond to court orders and legal investigations, or report to credit bureaus): Does Cowboy Credit / Fremont share? YES. Can you limit this sharing? NO. - For our marketing purposes (to offer our automotive products and services to you): Does Cowboy Credit / Fremont share? YES. Can you limit this sharing? NO (except that you may opt out of promotional emails, calls, or texts at any time as explained in Section 8). - For joint marketing with other financial companies: Does Cowboy Credit / Fremont share? NO. Can you limit this sharing? We do not share. - For our affiliates' everyday business purposes—information about your transactions and experiences (such as routing your vehicle inquiry or application among participating Fremont Motor Companies dealerships): Does Cowboy Credit / Fremont share? YES. Can you limit this sharing? NO. - For our affiliates' everyday business purposes—information about your creditworthiness: Does Cowboy Credit / Fremont share? YES (solely among participating Fremont Motor Companies dealerships as needed to process and fulfill your requested vehicle financing transaction). Can you limit this sharing? YES (for any use unrelated to fulfilling your requested transaction; contact [email protected] or (307) 202-9096). - For our affiliates to market to you: Does Cowboy Credit / Fremont share? YES (only if you provide separate communication consent). Can you limit this sharing? YES (by contacting [email protected], calling (307) 202-9096, or using the opt-out instructions in any communication). - For nonaffiliates to market to you: Does Cowboy Credit / Fremont share? NO. We do not sell your personal information and we do not share your personal information with nonaffiliated third parties for their own marketing purposes. Can you limit this sharing? We do not share. 4. HOW WE COLLECT INFORMATION We collect personal information directly from you when you: - Request a general vehicle callback or availability check ("Help Request") on cowboy.credit; - Start, verify, save, resume, or submit an individual or joint credit application on apply.cowboy.credit; or - Request an email verification link or a 6-digit SMS verification code to authenticate your session. When you authorize a credit application, participating Fremont Motor Companies dealerships and the prospective finance sources (banks, credit unions, and automotive lenders) to which your application is submitted via RouteOne also collect information about you from consumer reporting agencies (credit bureaus such as Equifax, Experian, and TransUnion) and may verify your employment, income, and identity. If you use the optional "Find Nearby" location helper on the public site, your browser's geolocation coordinates are used transiently to suggest a nearby region or dealership and are discarded immediately; we never store or log your raw GPS coordinates. 5. WHO RECEIVES YOUR INFORMATION AND WHY Depending on the path you choose, your information is shared only with the following categories of recipients: - Participating Fremont Motor Companies Dealerships: Thirteen or fewer participating dealerships in the Fremont Motor Companies group supply the used-vehicle catalog. Initial application intake, customer follow-up, and dealer financing workflow are operated by our centralized team at Fremont Motors Casper (6101 E 2nd St, Casper, WY 82609) and participating Fremont dealerships. A vehicle's physical storage location is not automatically the selling dealership; any participating Fremont dealership may assist you and complete your purchase. If your intended selling dealership changes before further dealer-specific credit action, we will present a new seller disclosure. - RouteOne LLC ("RouteOne"): When you submit a completed credit application on apply.cowboy.credit, our system transmits your encrypted application data and selected vehicle details to RouteOne to create a retail Deal Jacket and Credit Application for the participating Fremont dealership. Dealership finance staff then use RouteOne to structure transaction terms, select prospective third-party finance sources/lenders, and obtain consumer credit reports. - Prospective Third-Party Finance Sources / Lenders: Banks, credit unions, and finance companies selected by the participating dealership in RouteOne receive your credit application to evaluate your creditworthiness and determine whether to extend retail financing offers. Those lenders process your data under their own federal financial privacy notices and regulatory obligations. - Customer Relationship Management ("CRM") System (Elead / Fortellis via Google Workspace): For general Help Requests and submitted application follow-up, we send CRM-safe contact, vehicle-interest, and routing status details (never your SSN, full date of birth, income, or credit bureau data) via our authenticated Google Workspace relay ([email protected]) to our dealership CRM (Elead) so dealership staff can contact you. - Authentication, Security, and Infrastructure Service Providers: We use Google Cloud Platform (encrypted hosting, Cloud SQL, Key Management Service, and reCAPTCHA Enterprise), Google Workspace (transactional verification and invitation emails), and business messaging providers (CallRevu for recipient-requested SMS verification codes when that service is enabled) strictly as service providers bound to protect your information. 6. PUBLIC ANALYTICS, COOKIES, AND SECURE APPLICATION ISOLATION - Secure Application Origin (apply.cowboy.credit): We do not load third-party advertising pixels, remarketing tags, session replay or Google Tag Manager. We use necessary authentication/security cookies and reCAPTCHA Enterprise. If first-party measurement is enabled under the applicable collection policy, the Apply host also uses a separate Secure, HttpOnly analytics cookie for a limited measurement grant and controlled application-progress events. That cookie is separate from your credit-application authentication. Applicant field values, names, email addresses, telephone numbers, SSNs, dates of birth, income and credit-report information are excluded from analytics. - Public Website Origin (cowboy.credit): When enabled under the applicable collection policy, our first-party GA4 relay uses ASC page, inventory and interaction events to measure website performance. Measurement may use cookie, client and session identifiers; these are pseudonymous identifiers, not anonymous information. We apply the consent and opt-out choices required for the applicable visitor and configuration. You may manage cookies through your browser and contact [email protected] about measurement, Global Privacy Control or other privacy choices. The effect of blocking or deleting a cookie depends on the browser and the measurement configuration. 7. DATA SECURITY, RETENTION SCHEDULE, AND BACKUP DISPOSITION We protect your personal information using administrative, technical, and physical safeguards designed to comply with the FTC Safeguards Rule, including TLS encryption in transit, Google Cloud KMS envelope encryption for sensitive credit payloads, separate email-link and recipient-requested SMS authentication for each applicant, and strict role separation so Cowboy Credit website staff cannot view or export plaintext SSNs or credit payloads. Our operational retention limits in the Cowboy Credit system are: - Incomplete Credit Application Drafts: Draft access expires 72 hours after initial session creation. Saving, resuming or inviting a co-applicant does not extend that deadline. Expired sensitive draft data is scheduled for automated cleanup; expiry and physical deletion are separate events. - Submitted Sensitive Credit Payloads: Sensitive payloads are scheduled for deletion after confirmed RouteOne acknowledgment, or when the separate 24-hour processing retention limit expires, whichever occurs first. Automated cleanup timing is distinct from that retention deadline. - CRM-Safe Contact Copies and Vehicle-Help Requests: Personal contact copies in Cowboy Credit have a separate 24-hour retention limit from acceptance and are scheduled for automated cleanup. This limit does not govern independent provider or dealership copies. - Compliance Evidence, Routing Metadata, and Audit Logs: We retain minimized consent, disclosure, routing, delivery and security records for the applicable legal, security, dispute-resolution and accountability purposes under our approved record-class schedule. Such records may contain references linkable to an application or participant and are protected accordingly. We do not retain the full sensitive application merely to establish consent. Legal holds and provider-held records may have separate requirements. - Encrypted Database Backups: Encrypted data removed from active systems may remain in backups until the containing backup expires under the configured backup schedule. Before a restored system serves customers, previously deleted records must be reconciled against the deletion ledger. Backup restore-point counts do not guarantee deletion by a particular calendar day. - Independent Provider and Dealership Records: Deletion of temporary intake records from Cowboy Credit's database does NOT delete records already delivered to RouteOne, participating Fremont Motor Companies dealerships, Elead CRM, Google Workspace sent-mail logs, or telecom carrier logs. Dealerships and finance sources are required by federal law (including Regulation B, 12 CFR 1002.12) to retain credit application records and adverse action evidence for at least 25 months. 8. YOUR CHOICES, RIGHTS, AND HOW TO CONTACT US - Withdrawing Optional Communication Consent: You may opt out of optional marketing or follow-up text messages at any time by replying STOP to any message, or opt out of calls, texts, or emails by contacting [email protected] or (307) 202-9096. - Discarding an Incomplete Application: You may stop before final submission. Unsubmitted draft access expires 72 hours after creation, followed by scheduled cleanup. Closing your browser or logging out pauses access and does not itself withdraw previously recorded E-SIGN consent. On a joint application, the primary applicant may switch to an individual application or revoke a pending invitation before submission. - Privacy Inquiries, Affiliate Sharing Limits, and Access/Correction Requests: To ask questions about this Privacy Notice, limit affiliate creditworthiness/marketing sharing, or submit a privacy request, contact us at: Email: [email protected] Phone: (307) 202-9096 (Monday–Friday, 8:00 AM – 6:00 PM MT) Mail: Fremont Motor Company (d/b/a Fremont Motor Companies and Cowboy Credit), Attn: Privacy & Compliance Office, 906 Main St, Lander, WY 82520 9. CHANGES TO THIS PRIVACY NOTICE When we make material changes to this Privacy Notice, we publish a new versioned record with an updated effective date and revision number. Any active credit application draft will require review and acceptance of the current effective notice before further sensitive data collection or submission.