VEHICLE ACQUISITION NETWORK, INC.
Attention: Privacy Office
220 N Green St
Chicago, IL 60607
PROTECTING THE PRIVACY OF CHILDREN
Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else. Our website is not directed at children under 13 and we won’t knowingly allow anyone under 13 to provide us any personally identifying information; if you’re under 13, please don’t provide any information about yourself on this website.
TABLE OF CONTENTS
- Types of Personal Information We Collect
- How We Collect Personal Information
- How We Use Personal Information
- When and Why We Disclose Personal Information
- Cookies and Related Technologies
- Controlling Your Personal Information
- Security of Personal Information
- Privacy Practices of Third Parties
- California Privacy Rights
- Notice to Residents of Countries outside the United States of America
- Types of Personal Information We Collect.
Personal Information is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. In some cases, Personal Information is used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. We collect the following types of Personal Information:
- Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, telephone numbers, or other addresses at which you receive communications from or on behalf of Company.
- Relationship Information that helps us to understand who you are and what types of services may interest you. This includes lifestyle information; location information related to your state/province, city, or neighborhood; demographic information (e.g., birth date, age, gender); and information about friends who refer you or whom you have referred.
- Transaction Information about how you interact with Company, such as the items you view and purchase; other information about how you use our Site, email, other communications, and applications; and how you interact with Company’s merchants, business partners, and service providers.
- Mobile Location Information to help us offer information that we believe you may find relevant or useful, if you have activated one of our mobile applications and permitted your mobile or other location-aware device to transmit location data. We gather mobile location information by using your mobile device’s GPS settings, interactions with WIFI network access points, cellular telecommunications access points, your IP address, and information combined with third party sources of such information.
- How We Collect Personal Information.
We ask you for Personal Information (including Contact Information, Relationship Information, and Financial Account Information) when you register, subscribe, create an account, make a purchase, or otherwise interact with the Site or contact Company.
We also collect Transaction Information if you contact us via telephone, email, text, postal mail, social media interaction, or other methods of communication, such as for customer support purposes.
We may receive additional Personal Information from third parties. We may use this Personal Information to enhance other information we have about you to help us better understand you and to otherwise enhance the Site or Company services.
- How Company Uses Personal Information.
Company uses Personal Information to:
- Operate and improve our Site;
- Facilitate transactions;
- Evaluate the types of offers, products or services that may be of interest to customers;
- Track transactions and perform other analytics;
- Provide customer support, including to our merchants or business partners;
- Fulfill requests for Company services;
- Communicate and provide additional information that may be of interest to you about Company and our merchants and business partners, such as Company news, special offers and coupons, announcements, and marketing materials;
- Send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins, or marketing;
- Provide advertisements to you through the Site, email messages, text messages, applications, or other methods of communication;
- Administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
- Allow you to apply for a job, post a video or sign up for special offers from third parties through the Site.
Do-Not-Track & Self-Regulatory Principles for Online Behavioral Advertising.
- Consumers can get enhanced notice and control over the collection and use of Web-viewing data for online behavioral advertising purposes. The program provides specific implementation practices in support of the Self-Regulatory Principles for Online Behavioral Advertising, – See more at: https://www.iab.com/news/self-regulation-2/
- Consumers who wish to opt-out of behavioral advertising tracking by participating advertisers are encouraged to visit the Digital Advertising Alliance’s consumer choice page: http://www.aboutads.info.
- We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. We have no control over, and shall have no liability for, any third-party compliance or non-compliance with DNT signals.
- When and Why Company Discloses Personal Information.
We will not disclose your Personal Information to third parties except to:
- Affiliated companies (e.g., subsidiaries and other companies owned by or controlled by Company) who may only use the Personal Information for the purposes described in Section 3 above.
- Our service providers that provide services for us such as sending emails on our behalf and processing payments. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them.
- Merchants, but only to the extent you have contacted the merchant, or participated in an offer, contest or other activity sponsored or offered through Company on behalf of the merchant. We may also provide merchants with Personal Information about the individuals who have purchased from the merchants, to send customized offers, to validate the purchases, to combat fraud, as part of legal proceedings affecting Company and the merchant, and to facilitate a direct relationship between merchants and customers and enable merchants to communicate electronically with customers.
- Company business partners or advertisers, as part of an offer, contest, or other activity that is provided by or in conjunction with Company and its business partners and in which you have elected to participate. For example, if you are referred to Company from a business partner’s website or through an invitation facilitated by or in conjunction with a Company business partner, Company may provide that business partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between Company and the business partner, which may allow such business partner to contact you directly and to advertise to you.
- Effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate. If Company is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
- We encourage Company’s merchant and business partners to adopt and post privacy policies. However, the use of your Personal Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
- We may also disclose information about you that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.
- Cookies and Related Technologies.
When you use our Site, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Site and applications, your browser and devices communicate with servers operated by us, our business partners and services providers to coordinate and record the interactivity and fill your requests for services and information.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Site by your computers or mobile devices. These servers are operated and the cookies managed by us, our business partners or our service providers.
For example, when you visit our Site, we may, and/or our service providers may, place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return, track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Site. Some cookies contain serial numbers that allow us to connect your web site activity with other information we store about you in your profile or as related to your interactions with the Site.
Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user ID if you asked to be remembered), and storing your preferences.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Site, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Site. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Site and the website you visit after you leave the Site, if this information is supplied to us by your browser.
Company uses certain analytics software tools, including Google Analytics, and optimization services for our websites. If you would like more information on how to remove yourself from the tracking and reporting functions performed for this website by a third party, please contact email@example.com.
- Controlling Your Personal Information.
We think that you benefit from a more personalized experience when we know more about you and how you use our Site and our services. However, you can limit the information you provide to Company, and you can limit the communications that Company sends to you.
You can manage your subscriptions by following subscription management instructions contained in the commercial messages that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may update your subscription preferences from time to time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your transactions.
You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.
You may manage how your mobile device and mobile browser share Location Information with Company, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
You may also manage the sharing of certain Personal Information with us when you connect with us through a social media platform or application, such as Facebook. Please refer to the privacy settings of the social media website or application to determine how you may adjust our permissions and manage the interactivity between Company and your social media account or your mobile device.
If you wish to opt out of receiving offers directly from Company merchants or business partners, you can follow the opt-out instructions in the emails that they send you.
Accessing and Correcting Personal Information.
You can do several things to help keep Personal Information about you current. You can access, update and delete your Contact Information, Financial Account Information, and the other information you provided to use in your profile by logging into your account and accessing the “My Account” section of the Site or sending us an email at firstname.lastname@example.org.
If you want to close your account or have other questions or requests, please contact us at email@example.com. While we are ready to assist you in managing your subscriptions, closing your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on the Site for financial reporting and compliance reasons.
We will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to cancel your account or request that we no longer use your information to provide you services contact us here. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Security of Personal Information.
Company uses commercially reasonable controls that are designed to reasonably safeguard Personal Information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.
- Privacy Practices of Third Parties.
- California Privacy Rights.
Residents of California can control how businesses use and maintain their Personal Information pursuant to the California Consumer Privacy Act [include hypertext link https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=201720180AB375]. Upon receipt of a verifiable consumer request, Company shall disclose to the consumer the following:
(1) The categories of Personal Information it has collected about that consumer.
(2) The categories of sources from which the Personal Information is collected.
(3) The business or commercial purpose for collecting or selling Personal Information.
(4) The categories of third parties with whom the business shares Personal Information.
(5) The specific pieces of Personal Information it has collected about that consumer.
Residents of California have the right to request that a business delete any Personal Information about the consumer collected from the consumer.
Residents of California have the right to request that a business not sell the consumer’s Personal Information.
Company has the right to verify that the individual submitting the request for access to data is the individual to whom the data belongs.
To request a copy of the information disclosure provided by Company or direct company with respect to Company’s use of your Personal Information, please contact us via email to firstname.lastname@example.org, or by writing us at the following address:
VEHICLE ACQUISITION NETWORK, INC.
Attention: Privacy Office
220 N Green St
Chicago, IL 60607
Please allow 30 days for a response.
- Notice to Residents of Countries outside the United States of America.
Residents of Australia
Adoption of the Australian Privacy Principles.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorized by law.
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia). We will deal with complaints as follows:
Step 1: let us know: If you would like to make a complaint, you should let us know by contacting our Privacy Officer (see above for contact details).
Step 2: investigation of complaint: Your complaint will be investigated by our Privacy Officer. A response to your complaint will be provided in writing within a reasonable period.
Step 3: contact OAIC
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing.
1300 363 992
Director of Compliance
Office of the Australian
GPO Box 5218
Sydney NSW 2001
www.oaic.gov.au with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).