The notice explains the following:
- Protecting the Confidentiality and Security of Consumer Information
- The Types of Information We Have About You and Where it Comes From
- Sharing Information with Affiliated Companies
- Sharing Information for Legal, Business, and Joint Marketing Purposes
PROTECTING CONFIDENTIALITY AND SECURITY OF CONSUMER INFORMATION
We take seriously our responsibility to respect the confidentiality and security of nonpublic personal information – called “Consumer Information” in this notice. Our policy calls for safeguards to protect Consumer Information only by those who need access to do their work. The same holds true for our affiliated companies, which are companies that, now or in the future, we own (or control), or are owned (or controlled) by, or are under common ownership (or control) with. We also may maintain, as required by applicable federal regulations, physical, electronic, and procedural safeguards to guard your nonpublic personal information.
INFORMATION WE COLLECT
We collect and use information about you from various sources. The amount and nature of the information collected and used varies from transaction to transaction, but the information described in the following five types:
- Information from you. Information you provide to us on applications, other forms, and by other means, such as your name, address, social security number, assets, income, and debt;
- Information from our experience and our affiliated companies’ experiences. Information about your transactions and account experience with us or our affiliated companies, such as parties to transactions, contract or lease balances, payment history, and communications and correspondence;
- Information from the experience of other parties. Information from other outside sources regarding their employment, credit or other relationships, account experience, or transactions with you, or verifying representations made by you, such as your employment history, credit balances, or your property or liability insurance coverage.
- Information from credit reports. Information supplied by consumer reporting agencies, such as information regarding your creditworthiness or credit history;
- Other general information. Other general information we obtain about you (such as demographic information) that is not assembled for the purpose of determining your eligibility for credit, insurance, employment or other products or services.
SHARING INFORMATION WITH AFFILIATED COMPANIES
We may disclose to our affiliated companies all of the information we collect about you as described in each of the five categories above. Our affiliated companies can be financial service providers such as leasing companies, insurance companies and payment processing companies and non-financial companies such as automotive repair facilities and data processing companies. This sharing permits us to give you superior service, make a wider range of products available, and operate our business more effectively. We do not share information with nonaffiliated third parties, other than described below under “Sharing Information for Legal and Routine Business Reasons and for Joint Marketing.” Where they apply, we reserve limits and restrictions set by law as to sharing certain kinds of information with our affiliates. For example, unless you authorize the sharing, we do not disclosure credit worthiness information about you from credit reports.
SHARING INFORMATION FOR LEGAL AND GENERAL BUSINESS REASONS AND FOR JOINT MARKETING
We may disclose any of the above five types of Consumer Information to credit bureaus and similar organizations, and otherwise when permitted by law. For example, this may include a disclosure in connection with a subpoena of similar legal process, a fraud investigation, recording motor vehicle registration and other documents in public records, an audit or examination, or the sale of your account to another financial institution. We may also share any of the above five types of Consumer Information outside of our affiliated companies if we have your consent, such as when you’re requested to be contacted by other companies we work with.
We may also share all five types of Consumer Information above with companies that work for us, possibly including some of our own affiliated companies, to perform services or functions on our behalf. These companies may include financial service providers such as banks, finance companies, and non-financial companies such as automobile manufacturers and data processing companies, and other organizations, such as nonprofit organizations that might provide educational, training, or certification services to businesses such as ours. We may also share the five types of Consumer Information above with companies that work for us to provide marketing and other services of with financial institutions with whom we have joint marketing agreements, such as banks or financing divisions of motor vehicle manufacturers. These companies act on our behalf and, within the time required by law, will be required by law, will be required by our policy to be contractually obligated to keep the information that we provide to them confidential and to use the information that we provide to them confidential and to use the information only to provide the services we’ve asked them to perform for us.
Our Website collects two different types of information through our website: anonymous information and personally identifiable information.
Anonymous Information. We collect and store anonymous, aggregate information (such as internet protocol (IP) addresses, browser types, search engines, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) from all visitors to our website. You may search our website for car models, prices and other information provided through our website without ever submitting your name, email address or any other personally identifiable information. The anonymous information that we do collect from your visit is never linked to any of your personally identifiable information until you voluntarily submit that personal information, in which case some otherwise anonymous information may be connected to your website activity and personal account. Otherwise, the anonymous information is only used in the aggregate to analyze trends, administer the website, diagnose any problems, track a visitor’s movement in the aggregate, and gather broad demographic information for aggregate use. We may provide this anonymous information in aggregate form to other parties or use it for our own insight or marketing purposes. Our ability to use this information is not restricted in any way.
We also use “cookies” and “image tags” to collect certain usage information from all customers and visitors to our website. A “cookie” is a small text file that a website can place on your computer’s hard drive or on your mobile device’s memory in order to collect information about your activities on our website. An “image tag,” also known as a clear GIF or web beacon, works together with cookies and is a small image file that may be located in various areas of our website. Most browsers automatically accept cookies, but you have the option to change your browser setting to decline them.
Accepting cookies in no way gives us access to your computer or any personal information about you, since cookies are not used to identify anonymous website visitors. Our cookies enable you to proceed smoothly through our website and know whether you’ve used it before, so as to eliminate some steps that apply to new visitors. Cookies also give us usage data like how often you visit, where you go on our website, and what you do while here.
Similarly, a cookie may be placed by our third-party advertising companies. These companies may use aggregated statistics about your use of our website and third party media in order to provide you with advertisements about goods and services that you may be interested in. The information they collect does not include your personal information.
The third-party advertising companies may also employ technology that is used to measure the effectiveness of ads. Any such information is anonymous. They may use this anonymous information about your visits to this and other sites in order to provide advertisements about goods and services of potential interest to you. No personal information about you is collected during this process. The information is anonymous and does not link online actions to an identifiable person.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.
Personally Identifiable Information. We require the submission of certain personally identifiable information when you use some services available on our website. For example, your use of your user name and password allows us to identify you as our customer who is seeking information in connection with our services. Our website uses a variety of contact forms and tracking phone numbers for visitors to request information, products, and services. We collect a visitor’s contact information (like his or her email address or phone number) and in some cases, demographic information (like his or her zip code). In limited circumstances, such as when a visitor fills out an online credit application, we collect unique identifiers (like a social security number), and/or financial information (like age, income level, bank account or credit card numbers). We use this information to get in touch with our prospective customers about their requests, and to send them additional information about our products and services.
Any financial information we collect is used to check the qualifications of our prospective customers and bill for products and services ordered. If you apply for financing or wish to purchase or lease a car through our online system, we may collect personal information such as your name, address, driver’s license number and state, social security number and other credit information. This information goes into a secure database and is used solely to provide the service you requested. The collection, use and storage of your financial information for credit checks, for arranging credit and loans or for purchasing products and services may be subject to additional privacy policies and if so, you will be notified of them at the time of any such collection, use or storage of your financial information as required by law.
Our online surveys may ask visitors for contact information (like an email address or phone number) which they may voluntarily provide. We also may run contests on our website in which we ask visitors for similar contact information in order to participate. We use contact information from our surveys and contests to send information about products and services to these participating visitors.