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Privacy Notice to California Residents

PRIVACY NOTICE TO CALIFORNIA RESIDENTS

This Privacy Notice to California Residents (this “CCPA Notice”) supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). DriveCentric, Inc. (“DriveCentric” or We”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. 

Information We Collect

DriveCentric collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (for purposes of this CCPA Notice, “personal information”). In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

 

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements.  NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.  NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

DriveCentric obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you when you when you speak to a customer or sales representative or visit our website; 
  • Indirectly from you; 
  • Our Chat Tool on our website, DriveCentric.com; and
  • From third parties, for example, our business partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  1. To present our website and its contents to you;
  2. To communicate with you, including providing you with information, products, or services that you request from us;
  3. To transact business with you;
  4. To process your requests, purchases, transactions, and payments;
  5. To operate our business, including use in our organizational and strategic planning, accounting and auditing, procurement, sales and marketing planning, public relations, materials management, information technology, security, database administration, research, legal compliance, and administration purposes;
  6. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  7. To perform relevant administrative services requested by you or needed to facilitate our relationship;
  8. To fulfill the purpose for which you provide the personal information;
  9. To provide you with notices about your account;
  10. To notify you about changes to any products or services we offer or provide though it.
  11. To help maintain the safety, security, and integrity of our Online Services, products and services, databases and other technology assets, and business;
  12. For product testing, development, analysis, engineering, and performance development and enhancement, including to develop, enhance and improve our website, other products, and services;
  13. To respond to customer complaints or reports of business concerns;
  14. To make suggestions of our products and services which may be of interest for you and other marketing communications;
  15. To process your employment application;
  16. To protect our information technology, system, network and data and to otherwise provide cyber security;
  17. To allow you to participate in interactive features on our website;
  18. To evaluate or conduct 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 about users of our website is among the assets transferred; 
  19. In any other way we may describe when you provide the information or as otherwise set forth in the CCPA;
  20. For any other purpose with your consent; or
  21. If we believe that disclosure is required by law (including to meet national security or law enforcement requirements), or in response to a lawful request by public authorities.

DriveCentric will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

DriveCentric may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

We share your personal information with the following categories of third parties: 

  • To our affiliates and subsidiaries.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.  These service providers include, but are not limited to,
    • Dealership Management Systems
    • Credit Approval Systems
    • Dealer Marketing Companies
    • Appraisal Software Companies
    • Automotive OEM’s 
    • Social Media Companies
  • With advertisers, advertising- and marketing-related services providers and partners as well as companies that help us learn how you and others interact with our content.
  • To a buyer or other successor in the event of 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 about users of our website is among the assets transferred.
  • To third parties (other than our affiliates and subsidiaries) to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, DriveCentric has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category B: California Customer Records personal information categories. 

Category F:  Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties: 

  • To our affiliates and subsidiaries.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.  These service providers include, but are not limited to,
    • Dealership Management Systems
    • Credit Approval Systems
    • Dealer Marketing Companies
    • Appraisal Software Companies
    • Automotive OEM’s and
    • Social Media Companies
  • With advertisers, advertising- and marketing-related services providers and partners as well as companies that help us learn how you and others interact with our content.
  • To a buyer or other successor in the event of 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 about users of our website is among the assets transferred.
  • To third parties (other than our affiliates and subsidiaries) to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

Sales of Personal Information 

In the preceding twelve (12) months, we have not sold personal information 

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose the categories and specific pieces of information we have collected, and certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and 
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  • Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us: 

By visiting https://www.DriveCentric.com and Click the “?” in the lower right hand corner to submit a request 

In writing at DriveCentric, Inc.

Attn: Privacy

12900 Maurer Industrial Dr. 

St. Louis, MO 63127

By phone Toll-free at 1-844-474-0050.

Only you, a person authorized by you to act on your behalf, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, 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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value to us of your personal information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. 

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@drivecentric.com or write us at: DriveCentric, Inc., Attn: Privacy, 12900 Maurer Industrial Dr., St. Louis, MO 63127.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and uses your information described above and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:

By visiting https://www.DriveCentric.com and Click the “?” in the lower right hand corner to submit a request 

In writing at DriveCentric, Inc.

Attn: Privacy

12900 Maurer Industrial Dr. 

St. Louis, MO 63127

By phone Toll-free at 1-844-474-0050.

 

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