Legal

Privacy Policy

Effective October 25, 2026. Test Drive Growth is a DBA of Ilardi and Associates LLC, a New York limited liability company ("we", "us").

1. Who this policy covers

This policy explains how we handle (a) information that visitors and prospective clients give us through this website, and (b) customer information that our clients (dealerships and other businesses) let us access so we can provide our services. For client customer data, the client remains the owner and decides how it may be used; we act on the client's instructions as its service provider.

2. Information we collect

• From website visitors: what you choose to send us, such as your name, business name, email, phone number and message when you request an audit.
• From clients: business contact details, billing details and the account access the client grants us.
• Client customer data: customer records we can see inside the client's own CRM, DMS or review and listing accounts, such as names, contact details, vehicle and service history and message history, limited to what is needed for the services the client purchased.

3. How we use information

• To respond to inquiries and provide the services a client has purchased.
• To send a client's customers messages on that client's behalf, only as the client directs and only within opt-in and contact rules.
• To prepare reports for the client about the work we did.
• To bill clients and run our business.

We use a client's customer data only for that client. We never use one client's data for another client or for our own marketing.

4. We do not sell or share customer data

We do not sell, rent or trade personal information. We do not share client customer data with anyone except (a) the client, (b) the software providers the client already uses or that we need to deliver the service (for example the client's CRM, email and texting tools), and (c) when the law requires it.

5. Texts, calls and emails

• We text a client's customers only when the records show the customer's consent, or we send a one-time opt-in request where the client's system allows it. Clients are responsible for obtaining and keeping consent records under the Telephone Consumer Protection Act (TCPA).
• Marketing emails follow the CAN-SPAM Act, identify the sender and include a way to unsubscribe.
• STOP replies, unsubscribes and do-not-contact requests are honored immediately, and we check for them before each message.

6. Data handling and security practices

• We work inside the client's systems. We use user access the client grants and controls inside its own CRM and accounts. The client can remove our access at any time.
• Minimum necessary. We access and keep only the data needed for the services purchased. Working copies, such as send lists and logs, are kept only as long as needed for the work and reporting.
• Limited access. Only authorized personnel who work on the client's account can access its data.
• Credentials. Logins are stored in an encrypted password vault and are never sent or stored in email or chat.
• End of contract. When a contract ends, we return or delete client customer data we hold, at the client's choice, and the client's own systems remain the system of record.
• Agreements. We will sign a non-disclosure agreement or a data processing agreement on request.
• Incidents. If we learn of unauthorized access to client data we hold, we will notify the affected client promptly so it can meet its own notice obligations.

7. New York SHIELD Act and the FTC Safeguards Rule

We follow reasonable administrative, technical and physical safeguards for private information, as New York's SHIELD Act requires of businesses that handle New York residents' data. For dealership clients, which are financial institutions under the Gramm-Leach-Bliley Act, we support the dealer's FTC Safeguards Rule compliance program as a service provider, for example by following the dealer's access rules, using only the access the dealer grants, and agreeing to contract terms the dealer needs for service-provider oversight. Each dealer remains responsible for its own information security program.

8. Website data

This website does not sell visitor data. Our hosting provider may keep standard server logs, such as IP addresses and browser type, for security and operation.

9. Your choices

If you are a customer of one of our clients, please contact that business directly to update your information or your contact preferences; you can also reply STOP to any text or use the unsubscribe link in any email. Website visitors can ask us to delete information they sent us.

10. Changes and contact

We may update this policy and will post the new version here with its effective date. Questions: hello@testdrivegrowth.com (coming soon).

This Privacy Policy is provided for information and is not legal advice.