This Agreement is entered into between CARTRIGO Advanced LLC ("CARTRIGO" or "Platform") and the individual or entity accessing the platform as an authorized broker ("Broker").
The purpose of this Agreement is to establish the terms under which Broker may access, use, and handle client data; to protect the privacy and security of consumers; and to define Broker's compliance obligations under applicable federal and Florida state law.
Broker is authorized to access and use client data exclusively for the following purposes:
- Active inquiry management: Managing vehicle purchase inquiries within the CARTRIGO platform for clients who have provided consent.
- OTD scenario generation: Using CARTRIGO calculator tools to model purchase scenarios for the specific client whose data is entered.
- Dealer coordination: Coordinating with participating dealers as authorized by the client and within CARTRIGO operational procedures.
- Client communication: Communicating with clients about their active inquiry through channels they have consented to.
- Lead summary transmission: Transmitting prepared lead summaries to CARTRIGO administrators or participating dealers, strictly within the scope of the client's authorized inquiry.
Before entering any client data, you must:
- Explain the purpose: Tell the client their information will be used for vehicle purchase preparation and advisory services only.
- Explain the sharing: Tell the client their information may be shared with CARTRIGO administrators, authorized dealers, and platform partners within the defined scope.
- Explain the limitations: Tell the client that any results are preliminary estimates — not credit approvals or binding financing offers.
- Obtain affirmative consent: Get a clear "yes" — not silence, not assumed agreement.
- Document the consent: Record how, when, and by what method consent was obtained. Enter this in the consent field when creating the lead.
Acceptable consent methods — Exhibit A:
| Method | Acceptability | Evidence Required |
|---|---|---|
| CARTRIGO web intake form | ✓ ACCEPTED | IP address, timestamp, and session ID logged automatically by platform. |
| CARTRIGO consumer authorization PDF — signed | ✓ ACCEPTED | Signed document uploaded to the lead file. |
| Recorded telephone consent | ✓ ACCEPTED | Recording retained for 5 years minimum. Date and time noted in lead record. |
| WhatsApp written confirmation | ✓ ACCEPTED | Screenshot of client's explicit written "I accept" message saved to lead file. |
| Verbal consent without recording | ✗ NOT ACCEPTED | Cannot be verified. Does not meet FCRA/GLBA documentation requirements. |
| Dealer authorization as substitute | ✗ NOT ACCEPTED | Dealer authorization does not replace direct consumer consent. |
| Prior consent from unrelated transaction | ✗ NOT ACCEPTED | Consent must be specific to the current CARTRIGO inquiry. |
Broker agrees to maintain the following minimum security practices when accessing the CARTRIGO platform:
You are required to report the following events to CARTRIGO at compliance@cartrigoadvanced.com within 24 hours of discovery:
Broker represents that all client communications will comply with CARTRIGO's Manual de Lenguaje Permitido. Key rules:
- Ownership: Client data accessed through the platform is owned by CARTRIGO and the consumers it belongs to. Broker acquires no ownership rights over client data.
- Upon termination: Immediately cease all use of client data and destroy or return to CARTRIGO any client data in your possession, including copies, extracts, or notes.
- No retention beyond active inquiry: Do not retain client data beyond the active period of an inquiry unless specifically authorized by CARTRIGO policy.
- Consent records: Consent records, regardless of format, must be preserved for a minimum of 5 years and made available to CARTRIGO upon request.
| Topic | Terms |
|---|---|
| Effective date | This Agreement is effective upon your electronic acceptance in the CARTRIGO broker activation flow. |
| Termination by CARTRIGO | CARTRIGO may terminate your access immediately, with or without notice, for: violation of this Agreement, misuse of client data, consumer complaints, failure to maintain compliance practices, or inactivity for more than 90 days. |
| Termination by Broker | Broker may terminate by providing 30 days written notice. Upon notice, immediately cease use of client data and comply with destruction obligations. |
| Survival | Sections 3, 4, 5, 6, 8, 10, and 11 survive termination of this Agreement. |
- FCRA: You will not obtain or use any consumer report without a permissible purpose and documented consumer consent.
- GLBA: You will protect nonpublic personal financial information and will not disclose it to unauthorized third parties.
- TCPA: You will obtain required consent before contacting consumers via automated calls, text messages, or prerecorded messages.
- Florida Consumer Protection Laws: You will not engage in unfair, deceptive, or misleading practices in connection with vehicle purchase or financing advisory services.
- Florida Breach Notification Law: You will immediately notify CARTRIGO of any actual or suspected data breach involving client data.
You agree to indemnify, defend, and hold harmless CARTRIGO Advanced LLC and its members, officers, and partners from and against any claims, liabilities, damages, losses, and attorneys' fees arising out of:
- Your breach of any provision of this Agreement.
- Your misuse of client data or violation of consumer privacy rights.
- Your failure to obtain valid consumer consent prior to data entry.
- Any claim by a consumer arising from your representations, conduct, or omissions.
- Your violation of any applicable law including FCRA, GLBA, or Florida consumer protection statutes.
The date, time, IP address, and user identifier associated with your acceptance are recorded automatically by the CARTRIGO system and constitute evidence of execution. By accepting, you confirm that you have read, understood, and agree to all terms of this Agreement.
For brokers who execute this Agreement via physical signature rather than electronic activation flow:
Coral Springs, FL 33067
compliance@cartrigoadvanced.com
cartrigoadvanced.com/en