Table
Categories of personal data processedShared with third parties?
Identifiers, such as: name, postal address, email address, IP address, identification numbers (e.g., social security number, driver’s license number, state identification number, military identification number or passport number)Yes
Personal information categories contained in customer records, such as: phone number; insurance information; bank account number, credit card number, debit card number, or other financial information, including information relating to consumers’ vehicle financing or lease terms, along with vehicle information; and/or signature(s).Yes
Commercial information, such as: vehicle information, vehicle ownership information, vehicle transaction information relating to purchase or lease of vehicles (including finance or lease terms), purchase of parts, service repairs, maintenance or vehicle inspectionsYes
Biometric information - consumers who finance/lease vehicles may be asked to complete a “Thumbprint form.”No
Internet or other similar network activity information, such as: IP address, browsing history, and search history.Yes
Geolocation information, such as: IP address and vehicle location.
Yes
Sensory data, such as audio information from voicemail messages and/or recorded phone calls (with consumers’ consent)Yes
Professional or employment-related information, such as: information regarding current occupation; information regarding whether a consumer is or will soon be a college graduate.Yes
Inferences drawn from personal information to create a profile, such as: information regarding consumers’ vehicle preferences and needsYes
Table
Purposes for processing personal data
  • To send informational and marketing communications, respond to requests and inquiries, and communicate with consumers regarding our products or services
  • Enter into transactions with consumers, obtain authorization to collect payment from consumers, collect payment from consumers, confirm acknowledgement of receipt of documents we provide to consumers, process transaction(s), process insurance or service contract claims; to effectuate, or in anticipation of effectuating, a vehicle repair covered by a vehicle warranty or a recall; provide copies of documents as required by law, and retain records of transactions as required by law
  • Complete government forms
  • To confirm consumers’ identity, confirm consumers are at least 18 years old, confirm consumers are licensed to drive our vehicles or take delivery of a vehicle they have purchased or leased from us, and confirm insurance coverage
  • Confirm eligibility for a manufacturer/lender rebate and to apply for and process any applicable rebate, and confirm eligibility for employee price discounts, if applicable
  • Appraise consumers’ vehicles, improve user experiences by making our website easier to use and navigate, and more personalized based on the profile we create about an individual consumer
  • Vehicle tracking as permitted by law
  • Some phone calls are recorded and video/audio recordings are made in the finance office (with your consent) for security purposes, training our staff and for compliance/quality assurance purposes
Table
Categories of third parties with whom personal data is shared
  • Operating system providers, internet service providers and analytics providers
  • Banks and payment processors
  • Warranty, insurance or service contract administrators
  • Advertising service providers
  • Vehicle manufacturer, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
  • State or federal agencies, when required by law
  • Delivery services 

FOR CALIFORNIA RESIDENTS

NOTICE AT COLLECTION  FOR CALIFORNIA RESIDENTS

The purpose of this Notice at Collection is to provide California residents with the categories of personal information that our Dealerships collect about them and the purposes for which the personal information is used. We retain the below information for as long as required to provide you with the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you are an employee of a Dealership, please refer to your specific Employee Privacy Policy for an explanation of how we collect, use, and retain employee personal information. More detailed disclosures for California residents are located in the section “PRIVACY NOTICE FOR CALIFORNIA RESIDENTS.” We may collect the following categories of personal information from you: Identifiers, Personal information categories contained in customer records, Protected classification characteristics, Commercial information, Biometric information, Internet or other similar network activity information, Geolocation information, Sensory data, Professional or employment-related information, Inferences drawn from personal information to create a profile, and Sensitive Personal Information. We use the categories of personal information listed above for one or more of the following “business purposes”: to provide our sites and services, advertising and marketing, contextual and behavioral targeting, to understand website interactions, to provide customer service, to defend against claims and litigation, fraud prevention, processing transactions, and providing financing.   

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Below is a table regarding the personal information we have collected about California consumers (excluding job applicants and employees) during the last 12 months. We retain the below information for as long as required to provide you with the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you are an employee of Dealership, please refer to the specific Employee Privacy Policy for an explanation of how we collect, use, and retain employee personal information.

Table
Category of Personal InformationSharing/Sale of Information  Disclosures to Third Parties for a Business Purpose

Identifiers, such as:
Name, postal address, email address, IP address, identification numbers (e.g., social security number, driver’s license number, state identification number, military identification number or passport number)

•    To vehicle manufacturer for marketing and analytical purposes, if customer visits a dealership website, or purchased/leased a new or certified vehicle, or if their vehicle was serviced at our dealership  
•    To state or federal agencies, when required by law
•    To service providers for administrative and operational assistance 

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as:


Phone number; insurance information; bank account number, credit card number, debit card number, or other financial information, including information relating to consumers’ vehicle financing or lease terms, along with vehicle information; and/or signature(s).

•    To vehicle manufacturer for marketing and analytical purposes, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
•    To state or federal agencies, when required by law
•    To banks to confirm availability of funds
•    To service providers for administrative and operational assistance

Protected classification characteristics, such as:

A photocopy/scan of government issued identification reveals personal information.  For example:
•    Driver’s license/state identification card - includes image, date of birth, physical description and gender
•    Permanent resident card - includes  image, date and place of birth; 
•    Social security card - includes  social security number
•    Passport - includes  image, date and place of birth and nationality
•    Military ID - includes image and rank
Completion of a Translated Contract Acknowledgement or signing of translated documents reveals a consumer’s primary language

•    To vehicle manufacturer if customer purchased or leased a new or certified vehicle or if their vehicle was serviced at our dealership 
•    To manufacturer or lender for processing rebate, if applicable
•    To state or federal agencies, when required by law
•    To service providers for administrative and operational assistance

Commercial information, such as:

Vehicle information, vehicle ownership information, vehicle transaction information relating to purchase or lease of vehicles (including finance or lease terms), purchase of parts, service repairs, maintenance or vehicle inspections

•    To vehicle manufacturer of some of the listed personal information, if customer purchased or leased a new or certified vehicle or if their vehicle was serviced at our dealership 
•    To state or federal agencies, when required by law
•    To service providers for administrative and operational assistance

Biometric information

Consumers who finance/lease vehicles may be asked to complete a “Thumbprint form”

N/AN/A

Internet or other similar network activity information, such as:

IP address, browsing history, and search history

To vehicle manufacturer for marketing and analytical purposes, if customer visits a dealership websiteTo service providers for administrative and operational assistance

Geolocation information, such as:

IP address and vehicle location 

N/A•    To service providers for administrative and operational assistance

Sensory data, such as

Audio information from voicemail messages and/or recorded phone calls (with consumers’ consent)

N/A•    To service providers for administrative and operational assistance

Professional or employment-related information, such as:

Information regarding current occupation

•    To manufacturer or lender for processing rebate or employee discount, if applicable
•    To state or federal agencies, when required by law
N/A

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such as:

Information regarding whether a consumer is or will soon be a college graduate

•    To manufacturer or lender for processing rebate, if applicableN/A

Inferences drawn from personal information to create a profile, such as: 

Information regarding consumers’ vehicle preferences and needs

N/A•    To service providers for administrative and operational assistance

Sensitive Personal information, such as:

Social Security number, driver’s license number, state identification number, passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation information; contents of mail, email, and text messages unless the business is the intended recipient of the communication;  genetic data; biometric data for the purposes of uniquely identifying a consumer.

•    To state or federal agencies, when required by law
•    Personal information may be shared with banks to confirm availability of funds
•    To service providers for administrative and operational assistance
Table
Categories of sources from which the personal information is collected
  • Directly from consumers
  • Indirectly from consumers (e.g., from observing consumers’ actions on our Services)
  • Third-parties, including advertising companies, analytics providers, vehicle manufacturer, and websites or companies that provide information regarding vehicles or provide listings of vehicles available for sale/lease, that forward identifiers provided by consumers
  • From vehicles equipped with GPS tracking (as permitted by law)
Table
 Business or commercial purpose for collecting, selling, or sharing personal information
  • To send informational and marketing communications, respond to requests and inquiries, and communicate with consumers regarding our products or services
  • Enter into transactions with consumers, obtain authorization to collect payment from consumers, collect payment from consumers, confirm acknowledgement of receipt of documents we provide to consumers, process transaction(s), process insurance or service contract claims; to effectuate, or in anticipation of effectuating, a vehicle repair covered by a vehicle warranty or a recall; provide copies of certain documents written in the language in which a transaction was primarily negotiated as required by law, and retain records of transactions as required by law
  • Complete government forms
  • To confirm consumers’ identity, confirm consumers are at least 18 years old, confirm consumers are licensed to drive our vehicles or take delivery of a vehicle they have purchased or leased from us, and confirm insurance coverage
  • Confirm eligibility for a manufacturer/lender rebate and to apply for and process any applicable rebate, and confirm eligibility for employee price discounts, if applicable
  • Appraise consumers’ vehicles, improve user experiences by making our website easier to use and navigate, and more personalized based on the profile we create about an individual consumer
  • Vehicle tracking as permitted by law
  • Some phone calls are recorded and video/audio recordings are made in the finance office (with your consent) for security purposes, training our staff and for compliance/quality assurance purposes
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