2025 Crown Team Member Handbook

POLICIES

Safeguards: Customer Information Security Policy Financial Customer Information Must Be Secure When visiting the dealership, our guests may provide personal and non-public financial information called “Customer Information, often found on the following: • Credit bureau report • Credit application • Risk based pricing notice • Driver license or other government identification • Social security number, dates of birth • Bank account number • Credit card number Our company policy and federal and state laws are clear: you are required to secure our customers’ personal and nonpublic financial information. By “safeguarding” this type of information, we are helping to prevent the spread of identity theft and security breaches. Nonfina cial Customer Information Must Also Be Secure Nonfinancial Customer Information is personal information which is not subject to federal safeguard laws either because it is not financial in nature, or because it is publicly available. This information may still be subject to protection under federal and state laws and is protected under Company policy. Examples of Nonfinancial Customer Information includes personal information such as name, addresses, phone numbers, IP addresses, family, employment, demographic and other identifying information. Some examples of materials containing Nonfinancial Customer Information at our dealerships are: • Guest intake sheet • Work sheet • Repair order and estimate • Customer order • Loaner, test drive and BVA agreement • Customer information with nonpublic personally identifiable information partially redacted or masked • Digital files containing non-financial information, such appointment logs with guest contact information Every Team Member Is Responsible For Customer Information Security All Customer Information must be securely stored in locations where only authorized personnel can access it. Digital Customer Information may only be stored on Company servers. Customer Information may not be removed from the dealership in any format. Authorized Use Of Customer Information, Only • Do not access, use or reproduce Customer Information, whether digital or paper, for your own personal use or for any use not authorized by the Company and Guest. • Bank balance • Insurance card • W2s, tax returns, pay stubs and income history • Other stipulations • Digital files containing the above information

60 No policy should be construed to confer any express or implied contractual relationship or rights to any Team Member. The Company reserves the right to modify any policy as necessary, in its sole discretion, to the extent permitted by law. Violation of any Company policies or procedures can result in disciplinary action up to and including termination of employment. If you have any questions about this handbook or Company policies, please feel free to discuss with your Manager or HR.

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