PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR OTHERWISE INTERFACE WITH US.  BY USING OR ACCESSING OUR SITES, REGISTERING OR SUBMITTING YOUR INFORMATION, OR INTERACTING WITH TITAN, YOU CONSENT TO THIS POLICY AND TO OUR COLLECTION AND SHARING OF YOUR INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY AND WHERE APPLICABLE OUR WEBSITE TERMS OF USE.

For Non-US residents: If you are located outside of the United States, please be aware that information and data we collect may be processed and stored in the United States.  For more details, please refer to Section 10 (International Data Transfers) and Section 14 (International Addendum). BY VISITING OUR SITE OR OTHERWISE INTERACTING WITH OUR BUSINESS OPERATIONS FROM A COUNTRY OTHER THAN THE UNITED STATES, YOU UNDERSTAND AND CONSENT TO THE COLLECTION, STORAGE, PROCESSING, AND TRANSFER OF YOUR INFORMATION TO U.S.-BASED FACILITIES OPERATED BY US, OUR SERVICE PROVIDERS, SUPPLIERS, AND/OR OTHER RECIPIENTS AS DESCRIBED IN THIS POLICY. 

For California residents:  Additional information regarding our privacy practices under the California Privacy Laws, including “Notice at Collection” is available here.

For Texas or Nebraska residents:  Additional information regarding our privacy practices under these state-specific privacy laws is available here.

 

Scope of this Policy

At Titan International Inc. and its affiliate and subsidiary companies that manufacture and sell specialty tires and products under the Goodyear Farm Tire, Carlstar, ITP®, Cragar®, MarastarTM, Black Rock®, and Titan brands (together known as “Titan”, “we,” “us,” and “our”) is committed to protecting the privacy and security of the Personal Information we collect, use, share, and otherwise process as part of our business operations.  We also believe in transparency.  This Policy provides information about how we treat the data we collect and process, and your choices and rights under applicable laws. 

When does this Policy apply? This privacy policy (“Policy”) describes our practices for the Personal Information collected by and on our behalf as a core part of our business operations, including: 

• Our “Site”, which refers to our websites (including, without limitation, https://www.titan-intl.com/, https://www.itptires.com/, https://marastar.com/, and https://www.blackrockwheels.com/), mobile applications, platforms, and other online solutions, software applications, media, solutions, features, websites, webpages and subdomains, content, and/or functionality made available by Titan, which include a link to this Policy. 

• Your “General Interactions” with Titan, which refers to your interactions with Titan when you request information from or make general inquiries to Titan, receive products and services from Titan, conduct business-to-business engagements with Titan, provide services to Titan on behalf of their employers, attend in-person or virtual conferences hosted by Titan, request or receive our marketing information, and access Titan’s business premises as a visitor, among others. 

• Our “HR- or Personnel-related Operations”, which refers to how we may collect information (directly or in some cases through our HR systems or benefit enrollment systems) about (i) our current or former employees, dependents, and beneficiaries of a current or former employee, corporate officers, and temporary workers; (ii) independent contractors engaged by Titan, and (iii) current and potential job applicants (collectively, “Personnel”).

This Policy does not apply to:

• Third-Party Websites. Our Site may contain links to websites operated and maintained by third parties, over which we have no control. Privacy policies on such linked websites may be different from this Policy. You access such linked websites at your own risk. You should always read the privacy policy of a linked website before disclosing any of your information on such a website. 

1. INTRODUCTION

What is “Personal Information”?  “Personal Information” means information that can be used to identify you, directly or indirectly, alone or together with other information.  This includes, without limitation, your full name, contact information, email address, phone number, device IDs, certain cookie and network identifiers, and other categories described below.  

We may de-identify, aggregate and/or anonymize your Personal Information by excluding and removing data components (such as your name, email address, or linkable tracking ID) through obfuscation, or through other means so that the resulting dataset is no longer personally identifiable to you (such resulting dataset is known as “Aggregated Data”).  When we de-identify Personal Information to become Aggregated Data, we will not attempt to re-identify the data except for to confirm that it is de-identified.  Our use of Aggregated Data is not subject to this Policy.

2. INFORMATION WE MAY COLLECT

The information we collect depends upon the nature of our relationship, the method you communicate with us, and the purposes of your interaction with us, among others.  We may collect the following types of Personal Information for the purposes listed below.  

2.1 Categories of Personal Information We May Collect: 

Further, we may receive your Personal Information that you voluntarily share with us when you access, use, or interact with Titan, which is not specifically listed here.  We will use such data in accordance with this Policy, as otherwise disclosed at the time of collection, in accordance with our agreement, or to the extent necessary for providing the services or products.

2.2 Sources of Personal Information We May Collect

(a) Personal Information You Provide Directly to Us. We may collect information about you when you provide it to us directly, including account registration, completing surveys, questionnaires, or other webforms, or otherwise directly interacting with us with questions, feedback, or business transactions. 

(b) Personal Information We Obtain, Derive, or Generate. We may collect Personal Information about you through cookies and other similar tracking technologies when you access our Site.  Based on your interactions with our Site, and we may associate that information with your account or device IDs.  If you choose to disable such tracking technologies, some areas and features of our Site may not work properly.  The information we collect from you may also depend on the settings of your device(s) and/or browser(s).  We recommend checking the polices and instructions of your device manufacturer(s) or browser provider(s) to learn what information they make available to us.

(c) Personal Information We Collect from Third Parties.  We may collect your Personal Information from the following sources: 

• Public records;

• Service Providers, who collect data on our behalf;

• Advertising Partners, who assist us with marketing or promotional services related to how you interact with our Site;

• Dealers, who may provide us with Personal Information when we provide them with our products or services.  In most instances, we are limited in using the datasets from dealers to provide the products or services requested by the dealers. 

• Linked Social Media Platforms, if you choose to interact with us through your social media accounts.  We may include content, pixels, tags, buttons, or other tools that link to another company’s service(s) and/or platform(s) (“Plugins”). If you use a portion of our Site that contains Plugins, information can be transferred directly from your device to a third-party provider of service(s) and/or platform(s).  We may not control the data collected by Plugins. If you are logged in to a social network, the social network may be able to link your use of our Site to their service(s) and/or platform(s).

3. HOW WE MAY USE YOUR INFORMATION

Except as otherwise specified in the table above, we may use your Personal Information for the following purposes:

• Site and Business Operations, such as: 

• providing you with, maintain, and/or modify the Site, and/or complete the transaction for which we collect the Personal Information.

 

• maintaining accounting records, analyzing financial results, complying with internal audit requirements, maintaining our databases and back-ups, obtaining or maintaining insurance coverage; managing risks, or obtaining professional advice, and/or other activities in connection with our business operations. 

 

• Service Delivery, such as using your Personal Information to provide Titan’s services, products, and other offerings, and serving you the content and functionalities you request upon your request. 

 

• Customer Care, such as communications with you about your use of the Site or other interactions with Titan, retention of communication records, response to your comments and inquiries, managing our relationships with you as existing or potential customers, and for other customer care purposes. 

• General Marketing Initiatives, such as administration of promotions, contests, surveys, and other general customer engagement communications with you about the information that may interest you. 

• User Interests and Personalization, including communications via email, LinkedIn, mail, or other marketing channels, understand and analyze how you use the Site, or enhance your experience on the Site with a more personalized and interactive experience, including suggesting and offering you relevant content and recommendations.  

• Data Analytics, which helps improve our tools, surveys, benchmarking, or other related business purposes, including the creation of Aggregated Data and development of industry and sector-wide reports or white paper.

• Product and Services Improvement, such as evaluation, analysis, improvement, and development of our products and services, including the Site, performance of security and quality controls of the Site, research and development, offering location customization and personalized help and instructions. 

 

• Legal Requirements, including the enforcement of our terms and conditions or protecting our business or our customers, fulfillment of our contractual obligations, and compliance with our obligations under applicable laws and regulations, among others. 

 

• Security and Fraud Prevention, including using your Personal Information to: 

• Protect, investigate, mitigate, and deter against fraudulent, malicious, unauthorized, infringing, or illegal activities relating to our business operations, assets, or products or to monitor and ensure the safety and security of our premises, property, employees, and visitors; and/or

• Verify your identity and/or confirm that individuals are authorized to access, use, or share information related to our products or services.

• Corporate Activities.  We may use your Personal Information in connection with evaluating, conducting or implementing a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred. 

 

• Miscellaneous: 

• For other purposes for which we obtain your consent.

 

4. HOW WE MAY DISCLOSE OR SHARE YOUR PERSONAL INFORMATION 

We may disclose your Personal Information outlined above to the following categories of recipients: 

 

5. HOW LONG DO WE RETAIN YOUR INFORMATION?

We will keep your information for as long as it is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide the services or products, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements.

We take reasonable steps to delete the Personal Information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and/or (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legal, dispute resolution, contractual, or similar obligations.  We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We may retain and use Aggregated Data for as long as is permitted under applicable laws.

6. HOW TO PROTECT YOUR PERSONAL INFORMATION?

We endeavor to use and maintain commercially reasonable physical, technical, and organizational security measures designed to protect the Personal Information under our control. From time to time, we review our security procedures and consider new technologies and methods.

However, despite our efforts to store and protect Personal Information in a secure environment, no security system is perfect, and no data transmission is 100% secure.  We cannot guarantee or warrant the security of any information transmitted to or from the Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.  

The safety and security of your Personal Information also depends upon you.  When you use a password to access restricted parts of our Site, you are responsible for keeping your password confidential.  Do not share your password with anyone.

7. COOKIES AND SIMILAR TECHNOLOGIES

We also use cookies (small text files stored by your web browser when you use websites) as well as related technologies, such as pixels and beacons (collectively “Cookies”), to collect and store information when you use our applications. To learn more, see our Cookie Policy. 

8. YOUR CHOICES TO CONTROL YOUR INFORMATION

Cookie Opt-Out. To disable certain optional cookies, including advertising and analytics cookies or other tracking technologies, please review Cookie Policy, which provides options available to you, including adjusting the Cookie Banner’s settings.

Email Preferences. We may send you emails about our Site, products, and services. If you do not want to continue receiving emails from us, you may opt-out by clicking the “unsubscribe” button at the bottom of our emails.  Please note that certain Email Communications that are transactional in nature (for example, emails about your order, or a change in terms and features of your account) may not contain an unsubscribe link or opt-out instructions.

Accuracy and Updating Your Personal Information. Our goal is to keep your Personal Information accurate, current, and complete. If any of the Personal Information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

Complaints. If you believe your rights relating to your Personal Information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Nevada Residents. Nevada residents may submit a verified request to us at privacy@titan-intl.com (with “Nevada Data Subject Request” in the subject line) to request that we not make any sale (as defined under Nevada laws) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law. 

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide Personal Information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response.  As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at privacy@titan-intl.com.  

“Do Not Track” Signals. Some browsers transmit “Do-Not-Track” (“DNT”) signals, which inform websites that you do not want to be tracked.  We currently do not support or take actions in response to the DNT signals. 

9. THIRD-PARTY SITES OR TECHNOLOGIES

The Site may contain links to websites or mobile applications operated and maintained by third parties and subject to their own privacy policies.  If you follow any links that direct you away from the Site, including links to social media sites, this Policy will not apply to your activities on those external sites you visit.  Because of the dynamic media capabilities of the Site, it may not be clear to you whether certain webpages or applications are linked to the Site or connected to external, third-party websites.  If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website.  You can check the URL to confirm if you are no longer accessing our Site.

While these third-party websites and applications are selected with care, we are not responsible for the use and collection of your information by these third-party sites and cannot guarantee the adequacy of these third-party sites’ privacy and security practices.  A link to a third party’s website should not be construed as an endorsement.

10. INTERNATIONAL DATA TRANSFER

We may transfer, or otherwise make available, Personal Information that we collect from you to countries outside of your home jurisdiction, where we or our service providers and business partners operate.  Certain jurisdictions may not have the same data protection laws as your home jurisdiction.  

We will comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located.  If you are located in the EEA, UK, or Switzerland, we will transfer your Personal Information in accordance with adequacy decisions, standard contractual clauses, or other data transfer mechanisms compliant with applicable law.  When we transfer your Personal Information to other countries, we will protect your Personal Information in accordance with this Policy or as otherwise required under data privacy laws of the applicable jurisdiction.  By using the Site or otherwise interacting with Titan’s business operations, or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to data centers based in the United States. 

11. CHILDREN

Our Site, products, and services are not directed to children under the age of 16, and we do not knowingly collect information from children under the age of 16. No one under the age of 16 may access, browse, or use the Site or provide any information to us. If we learn that we have collected or received Personal Information from a child under the age of 16 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have received information from a child under the age of 16, please contact us using the “Contact Us” details provided below.

For more information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

12. UPDATES AND CHANGES

We may update this Policy from time to time. If we change this Policy, we will post the revised version on our Site. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes, we may also notify you through a notice on the Site’s homepage, and/or we may send you an email regarding the updates.

You are expected to, and you acknowledge and agree that it is your responsibility to carefully review (and monitor changes to) this Policy prior to accessing our Sites or using our products or services, so that you are aware of any changes.  Your continued use of the Site after the “Last Updated” date will constitute your acceptance of the changes and your continued consent to our processing of your Personal Information according to the terms of the then-current Policy.  If at any point you do not agree to any portion of this Policy (other than the information collected in connection with our HR operations based on our legitimate interests or for business purposes as defined under applicable state laws), then you should immediately stop using the Site.  Because this Policy contains legal obligations, we encourage you to review it carefully.

13. CONTACT US

If you wish to exercise your rights, submit a complaint, ask questions, or provide feedback, please contact us using the information below. 

When you email us, please place “Data Privacy/Personal Data” in the subject line. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone instead.

Mail: Titan International, Inc.

Attn: Data Protection Officer

1525 Kautz Rd., Ste 600

West Chicago, IL 60185

Email: privacy@titan-intl.com

Phone: 1-866-418-6658

 

14. INTERNATIONAL ADDENDUM

14.1 EU/UK/Switzerland Terms. 

This addendum applies only if you use the Site or otherwise interact with our business operations from a country that is a Member State of the European Union or European Economic Area (collectively, “EU”), the United Kingdom (“UK”), or Switzerland, and it supplements the information in the remainder of our Policy, above.  

1. Legal Basis for Data Processing: We may process your Personal Information in connection with any of the purposes and uses set out in this Policy based on one or more of the following legal grounds:

• Performance of a Contract: As necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us.

• Legal Obligations: As necessary to comply with our legal obligations as well as to keep records of our compliance processes (for example, to comply with applicable accounting rules, and to make mandatory disclosures to law enforcement). 

• Legitimate Interest: Because of our legitimate interests, or those of a third-party recipient of your Personal Information, to make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms, such as to ensure that we provide.  As set forth below, you have the right to object to our processing of your Personal Information on the basis of our legitimate interests, in which case, we must stop such processing unless we have a compelling interest in the continued processing that overrides yours. 

• Vital Interest: As necessary to protect your vital interests; 

• Public Interest: As necessary in the public interest; 

• Consent: Because you have expressly given us your consent to process your Personal Information in a particular manner.  

2. Data Subject Rights: If you are located in the EEA, the UK, Switzerland, you have the following rights under the applicable data privacy laws in EEA, the UK, or Switzerland.  All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.

• Right of Access. To the extent required by law, you have the right to (i) receive confirmation as to whether or not we process Personal Information about you, (ii) where that is the case, access to the Personal Information; and (iii) the following information: the purposes of the processing; the categories of Personal Information concerned; and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed.  We will provide a copy of your Personal Information in compliance with applicable law.

• Right of Rectification. We strive to keep your Personal Information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

• Right to Erasure. In some cases, you have a legal right to request that we delete your Personal Information when (1) it is no longer necessary for the purposes that we collect your information, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the Personal Information has been unlawfully processed, (5) the Personal Information must be erased for compliance with a legal obligation; and/or (6) the Personal Information were collected in relation to the offer of information society services.  However, the right is not absolute. When we delete Personal Information, it will be removed from our active servers and databases as well as the Platform; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your Personal Information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

• Right to Restrict Processing. You have the right to restrict the processing of your Personal Information when (1) the accuracy of the Personal Information is contested, for a period enabling the controller to verify the accuracy of the Personal Information; (2) you request a restriction in lieu of erasure for an unlawful processing activities involving your information; (3) we no longer need the Personal Information, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to the processing of your Personal Information, pending resolution of the objection.

• Right to Portability: You have the right to request that we make available your Personal Information in a portable form so that you can transfer to a third party. 

• Right to Object. In certain circumstances, you have the right to object to the processing of your Personal Information where the processing is necessary for perform certain task(s) carried out in the public interest, for our Legitimate Interests, or for the Legitimate Interests of others. You also have the right to object where Personal Information is processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

• Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your Personal Information, you may have the right to withdraw your consent in whole or in part. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights, and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of Personal Information for providing our products or services.

3. Data Retention. Please review Section 5 (How Long We Retain Your Information), above. 

4. Inquiries and Complaints. 

If you have questions or concerns regarding this addendum or would like to exercise your data subject rights regarding your Personal Information, please contact us by following the instructions in Section 13 (Contact Us).   

You also have the right to make a complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available in the table below (PLEASE NOTE: we provide these third-party links for your convenience, and may not actively monitor the content of these links):

14.2 Terms for Canadian Residents. 

Your Canadian Privacy Rights. The Canadian federal and provincial laws provide individuals residing in Canada certain rights to protect and control the use of their Personal Information.

Right to know. You have the right to know whether we have processed your Personal Information and to obtain access to your Personal Information that we process.

Right to correct. You have the right to request that we correct any inaccuracy in your Personal Information.  

Right to Delete. Subject to certain exceptions, you have the right to request that we delete the Personal Information we have about you. 

Right to Opt-Out. Subject to certain exceptions, you can opt out of targeted advertising (as defined by local law) and our use of cookies and similar technologies for non-essential reasons such as targeted advertising. 

Right to Withdraw consent. You may withdraw your consent to our use, disclosure, or collection of your Personal Information, subject to contractual and regulatory constraints and appropriate notice. 

Exercising Your Canadian Privacy Rights. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.  You may write to us to appeal our decision on one or more of your request(s) to exercise these rights.  Authorized agents can make a request on your behalf if you have granted them legal power of attorney or if we get proof of signed consent, verification of your identification, and, in some situations, confirmation that you gave your agent permission to submit these requests. 

15. U.S. STATE-SPECIFIC PRIVACY ADDENDUM

U.S. STATE-SPECIFIC PRIVACY ADDENDUM

This U.S. State-Specific Privacy Addendum (“U.S. Privacy Addendum”) supplements our Privacy Policy (“Policy”) and provides additional information regarding data protection and privacy rights provided under applicable U.S. state laws.  The information below applies if you are a resident of the state(s) specified below, and the relevant rights will be available from the date when the applicable U.S. state laws and regulations take effect.  For the purposes of this U.S. Privacy Addendum, “Personal Information” shall have the same meaning as the term “personal data”, “personal information”, or “personally identifiable information” as defined in the U.S. state privacy laws, as applicable.

We reserve the right to amend this U.S. State-Specific Privacy Addendum at our discretion and at any time.  When we update this U.S. Privacy addendum, we will post the updated version on our website and update the Effective Date for the applicable section. 

Table of Contents

I.  Notice to California Residents

II. Notice to Texas and Nebraska Residents 

NOTICE TO CALIFORNIA RESIDENTS

Last updated: July 15, 2025

The following provisions apply when we process Personal Information of one or more residents of California (“California Consumer(s)”).  Data privacy and protection laws and regulations in California (“California Privacy Laws”) provide California Consumers with specific rights regarding their Personal Information. If you are a California Consumer, you may rely on our Privacy Policy and this “Notice to California Residents”, which provide information required under the California Privacy Laws and explains how to exercise those rights. Specifically, Subsection A (i)-(iv) of this “Notice To California Resident” constitute “Notice at Collection” as defined under the California Privacy Laws. 

1. Personal Information collected

(i) Categories: Within the preceding 12 months, we may have collected the following categories of Personal Information: 

1. Identifiers, including name, contact information, account information, and other similar identifiers;

2. Demographic Information, including characteristics of protected classes or groups under state or federal law, such as sex, disability, citizenship, primary language, immigration status, and marital status, and other data collected for HR purposes. 

3. Commercial Information, as your purchase and transaction histories, in addition to contact information.

4. Biometric Information, such as fingerprints for HR attendance tracking purposes, fraud detection, or legal requirements. 

5. Internet or other electronic network activity information, including browsing history, information about interaction with our websites, applications, or advertisements.

6. Geolocation Data, such as device location or IP addresses.

7. Audio and Visual Information, such as call and video recording

8. Professional or employment-related information, such as your occupation, work history, resumes, reference, etc. 

9. Non-public education information, such as transcript

10. Inference drawn from the foregoing data, such as information about an individual to create a summary about his or her preferences and characteristics;

11. Sensitive Personal Information**, including: 

• Social Security Number, Driver’s License Number, State ID or Passport Number;

• Account log-in, financial account, or debit/credit card numbers in combination with security or access code, password, or credentials allowing access to an account;

• Racial or ethnic origin, religious or philosophical belief, or union membership (solely in connection with our HR operations);

• Contents of mail, email, and text messages unless we are the intended recipient of the communication Biometric Information; and

• Certain benefit-related and HR information (including employee health information). 

** We only collect Sensitive Personal Information for legitimate business purposes and will not otherwise use it to infer characteristics about you. Our use or disclosure of such data is reasonably necessary and proportionate for those legitimate business purposes as contemplated in the California Privacy Laws.

For more details, please refer to Section 2 (Information We May Collect) of our Policy. 

(ii) Purposes for Which We Collect Your Personal Information. 

Within the preceding 12 months, we may use the categories of Personal Information listed above for the specific business or commercial purpose(s) as further elaborated in Section 3 (How We may Use Your Information) of the Policy, such as (1) Site and business operations, (2) service delivery, (3) customer care, (4) general marketing initiatives, (5) user interests and personalization, (6) data analytics, (7) product and services improvement, (8) legal requirements to comply with laws and enforce contractual terms, (9) security and fraud prevention, (10) corporate activities.  One or more of the foregoing scenarios are classified as “business purposes” as defined under the California Privacy Laws:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.

• Debugging to identify and repair errors that impair existing intended functionality.

• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us.

• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.

• Providing advertising and marketing services to you, except for cross-context behavioral advertising.

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

• Other purposes as expressly authorized by the implementing regulations of the California Privacy Laws.

For more details, please refer to Section 3 (How We May Use Your Information) of our Policy. 

(iii) Categories of Personal Information Sold or Shared to Third Parties

We do not make data available to third parties in exchange for money – we don’t do that.  Instead, the California Privacy Laws broadly define “sale” as disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration.  The term “sharing” includes disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising, and constitute a form of “sale”.  Further, to our knowledge, we do not “sell” personal information of consumers under the age of 16 years old, as defined in applicable privacy laws.  You have the right to opt-out as described below by using the settings on the Cookie Banner or by broadcasting an opt-out preference signal. 

In the preceding 12 months, we may have exchanged with our advertising providers (as identified in Section 4 (How We May Disclose or Share Your Information) of the Policy) certain identifiers, “Internet and Other Similar Activity”, “Geolocation Data”, and “Inferences drawn from other PI” as defined in Section 2.1 of this Policy.  As broadly defined under California Privacy Laws, these data exchanges may constitute a “sale” or “sharing” of Personal Information.  For example, as a result of your interactions with our Site, we may collect technical device data and other identifiers for business or commercial purposes described in Section 3 (How We may Use Your Information) and Section 4 (How we may Disclose or Share Your Information) of the Policy, including general marketing initiatives, user interests and personalization, and assessment of our advertising and marketing campaigns.  While these datasets do not identify you directly, they can be attributed back to identify you by a third party for its own use and benefits, such as personalized advertising or cross-context behavioral advertising, whether for monetary or other valuable considerations.  We provide this disclosure as this is a core part of your rights as a California resident.  For the avoidance of doubt, we do not sell or share biometric information, demographic Information, or sensitive personal information that are collected for HR purposes. You have the right to opt-out by adjusting the settings on your Cookie Banner or by broadcasting an opt-out preference signal as described in the Cookie Policy.  

(iv) Data Retention 

We will retain your information for as long as it is necessary to fulfill the business or commercial purposes for which it was collected and will take reasonable steps to delete it.  For additional details, please refer to Section 5 (How Long We Retain Your Information) of the Policy. 

(v) Categories of Personal Information We Disclosed for a Business or Commercial Purpose

In the preceding 12 months, we may have disclosed Personal Information set forth in Section 2 for one or more purposes set forth in Section 3 (How We May Use Your Information) of our Policy. 

The categories of recipients, to whom we may disclose Personal Information for the foregoing purposes under, or as otherwise permitted by, the California Privacy Laws, include those recipients set forth in Section 4 (How We May Disclose or Share Your Information) of our Policy.  

2. Your California Privacy Rights.

This section describes Consumers’ rights under California Privacy Laws and explains how to exercise those rights, subject to certain exceptions:

1. Right to Know.  With respect to the Personal Information we have collected about you, you have the right to request information about our collection and use of your information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: 

• The categories of Personal Information we have collected about you;

• The categories of sources from which we collect the Personal Information about you;

• The business or commercial purpose(s) for which the Personal Information was collected, sold, or shared;

• The categories of third parties with whom we disclose that Personal Information for a business purpose; and 

• The specific pieces of Personal Information we collected about you in a format easily understandable to the average Consumer (also called a “Data Portability Request”). 

In addition, to the extent it is determined that our information exchanges constitute a sale or sharing of Personal Information under the California Privacy Laws, a Consumer shall have the right to request the business to identify, during the past 12 months: 

• The categories of Personal Information that we sold or shared, and the categories of third-party recipients; and 

• The categories of Personal Information that we disclosed for a business purpose and the categories of recipients. 

2. Right to Deletion.  Subject to several exceptions, you have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions and as permitted under California Privacy Laws. 

3. Right to Opt-out of “Sale” and Certain “Sharing” Practices. A California Consumer has the right to opt-out of the “sale” and “sharing” of your Personal Information with third parties, as those terms are defined under California Privacy Laws.  “Sell” in this case does not mean providing data in exchange for money – we don’t do that (and we do not have actual knowledge that we sell or share Personal Information of minors under 16 years of age).  You may opt out by using the settings on the Cookie Banner or by broadcasting an opt-out preference signal.

4. Right to Correct. Subject to certain restrictions, you have the right to request that we correct inaccurate Personal Information that we maintain about you.  We endeavor to keep your Personal Information accurate, current, and complete.  If you believe your Personal Information is not accurate, you may submit a request by following the instructions in the “How to Exercise Your California Privacy Rights” section below. 

5. Right to Limit Use and Disclosure of Sensitive Personal Information.  In certain circumstances, a California Consumer has the right to limit the use and disclosure of Sensitive Personal Information.  Our use of your Sensitive Personal Information is necessary to provide services or offerings reasonably expected by an average Consumer and not for those purposes for which you may exercise a right to limit the use or disclosure under California Privacy Laws.  While this Consumer right is not applicable to how we collect or use your Sensitive Personal Information, we provide this information as this is a core part of your rights as a California Consumer.

6. Right to Non-Discrimination. We do not discriminate against you for exercising any of your rights under California Privacy Laws.  Unless permitted by the California Privacy Laws, we will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services; or

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide Personal Information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response.  As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us by following the instructions in Section 13 (Contact Us).

3. How to Exercise Your California Privacy Rights

1. Methods to Submit California Consumer Requests

If you are a California Consumer and would like to exercise your rights under California Privacy Laws described above, you may do so via any of the methods described below: 

• Calling us at 1-866-418-6658; or 

• Sending an email to privacy@titan-intl.com (Please place “California Data Privacy/ Data Subject Request” in the subject line).

2. Authorized Agent. You may designate an authorized agent to make a request on your behalf.  Authorized agents will be required to provide proof of their authorization.  Individuals operating as an authorized agent on behalf of a California Consumer must provide a written authorization document, signed by the California Consumer, containing the California Consumer’s name, address, telephone number, and valid email address, and expressly authorizing the individual to act on behalf of the California Consumer.  We may also require that you directly verify your identity and the authority of your authorized agent.  We reserve the right to reject authorized agents who have not fulfilled the above requirements or automated requests under California Privacy Law where we have reason to believe the security of the requestor’s Personal Information may be at risk.

3. Verification Procedures.  We are required by California Privacy Laws to verify the identity of individuals who submit a Consumer request.  The verifiable Consumer request must provide sufficient information that allows us to reasonably verify your identity and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  The information we may need in order to verify your identity differs depending upon the request made and our relationship with you and might include (as applicable) your name, the email address you regularly use to interact with us, your telephone number, your date of birth, etc. We will take steps to verify your request by matching the information you provide with the information we have in our records.  In some cases, we may request additional information to verify your identity, or where necessary to process your request.  We can only respond to your request or provide you with relevant information if we can verify your identity or authority to make the request.  If we cannot verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

4. Response Timing:  Upon receiving a Request to Know, Request to Delete, or Request to Correct, we will confirm receipt of the request within 10 business days and respond to the request within 45 calendar days from the date we receive your request.  If necessary, we may take an additional 45 calendar days to respond to your request.  If this extension is needed, we will notify you of the extension and explain the reasons why responding to your request will take more than 45 days.  We are only required to respond to Requests to Know and Data Portability Rights twice in a 12-month rolling period.  

 

NOTICE TO OTHER STATE RESIDENTS

Last Updated Date: July 15, 2025

This Notice is applicable to Texas and Nebraska residents. 

Section 2 of the Policy sets forth the categories of Personal Information we may process, the purposes for processing Personal Information, the categories of Personal Information we may disclose (or where applicable, share), and the categories of data recipients.  

This “State-Specific Notice” applies if you are a resident of Texas and/or Nebraska and explains how to exercise your data privacy rights as a resident of these states. The applicable state privacy laws in Texas and Nebraska (“State Privacy Laws”) provide certain residents (“State Consumer(s)”) with specific rights regarding their Personal Information.

If you are a State Consumer from whom we control or process Personal Information that is within the scope of and subject to State Privacy Laws, the below provisions further apply: 

A. Your State Privacy Rights.  Subject to certain limitations and exceptions under the State Privacy Laws, State Consumers have the following rights:

1. Right to Access.  You have the right to know whether or not we are processing your Personal Information as a controller and to access such Personal Information.

2. Right to Correct.  You have the right to request that we correct any inaccurate Personal Information that we have collected about you.

3. Right to Delete.  You have the right to request that we delete the Personal Information provided by or obtained about you.

4. Right to Portability.  You have the right to obtain a copy of your Personal Information (if such data is available in a digital format) that you previously provided to us in a portable and to the extent technically feasible, readily usable format to you to transmit the data to another controller without hindrance.

5. Right to Opt-Out.  You have the right to opt out of the processing of your Personal Information for purposes of: (a) targeted advertising; (b) the sale of your Personal Information; or (c) profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you as a State Consumer (as these processing activities are defined under State Privacy Laws).  To the extent State Privacy Laws determine that information exchange involving Device ID or Interaction Information, or other information automatically collected by Cookies constitutes a “Sale” of Personal Information or other data processing activities for which you are eligible to exercise your “Right to Opt-Out”, please refer to the settings in the Cookie Banner. 

6. Right to Appeal.  You have the right to appeal our decision not to act on your request to exercise your rights under the State Privacy Laws.   Under the applicable State Privacy Laws, we will respond in writing of any action taken or not taken within 60 days after receipt of the appeal. 

7. Right to Non-Discrimination.  You have the right not to be discriminated against for exercising your rights under the State Privacy Laws. 

B. Our Processes to Respond to State Consumer Request(s): As a controller, we shall:

• Respond to your request to exercise State Consumer rights within 45 days after receiving your request.  Where reasonably necessary, we may extend the response deadline by an additional 45 days as long as we notify you within the initial 45-day response window; or

• Decline to take action regarding your request to exercise your State Consumer rights.  In this case, we will inform you of the reasons for which we decline within the initial 45-day response window and provide instructions on how to appeal our decision. 

C. Exercising Your State Privacy Rights.

If you are a State Consumer and would like to exercise your rights under State Privacy Laws as described above, you may do so via any of the methods described below: 

• 1-866-418-6658; or 

• privacy@titan-intl.com (Please place “STATE Data Privacy/Personal Data” in the subject line).