Effective December 4, 2018
1. What This Policy Covers.
2. Information We Collect.
a. Information You Provide. You may provide information to us in various ways, such as through forms, features or other means offered through the AutoGravity Services such as when you register an account, express interest in purchasing a car, or fill out a credit inquiry. Information that you provide to us generally falls into one of two categories:
i. Personally Identifiable Information. This is information that identifies you personally. Examples of Personally Identifiable Information that you may provide to us are: (1) user names; (2) addresses; (3) phone numbers; (4) email addresses; and (5) social security numbers. Information that cannot identify you personally, but that can be used to identify your household, is also treated as Personally Identifiable Information.
ii. Non-Personally Identifiable Information. This is information that does not identify you personally. Examples of Non-Personally Identifiable Information that you may provide to us are: (1) gender; (2) age or birth date; (3) income information; (4) employer; and (5) demographic information. When Non-Personally Identifiable Information is combined with other information that allows you to be personally identified, that information is treated as Personally Identifiable Information for as long as the information is combined.
b. Information We Automatically Collect. In addition to information that you provide to us, we may automatically collect certain information about how you access and interact with the AutoGravity Services. This information may be collected using various technologies including, but not limited to, cookies, browser web storage, and web beacons, and may be collected directly by us on the AutoGravity Services, by a third party on our behalf, or by a third party in accordance with their own privacy policies. Information that we collect generally falls into one of three categories:
i. Device Information. This is information about how you access the AutoGravity Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device.
ii. Usage Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with the AutoGravity Services, such as which features you use and your search and shopping behavior. This Usage Information may also include things like your IP address, browser or device configuration, date and time of access, cookie information, and the addresses of website or applications that you use to link to and from the from the AutoGravity Services.
iii. Location Information. We may use certain information like your IP address or other Device Information or Usage Information to estimate your physical location. We may also request to use location-enabled services on your device which will provide sufficiently precise location information for us to specifically locate you or your device. We only collect your precise location information with your permission, which may be given when you initially download the AutoGravity mobile application or visit the AutoGravity Services on the web.
c. Information Third Parties Provide About You. Some of the AutoGravity Services’ features rely on information about you that we collect from third parties, such as credit reports or credit scores. We may also combine information that you provide us and the information we automatically collect together with information from third parties to provide us with insight about your use of the AutoGravity services, your use of other websites, devices, mobile applications, and information from our partners, affiliates, and other sources.
3. How We Use Your Information. We use the information we collect from you and third parties to provide the AutoGravity Services to you, communicate with you, improve our services, and promote our services and products, in the following ways:
a. To Provide Our Services to You. We use the information we collect for our regular business purposes, such as establishing and managing your user account, offering and providing services and products you request or that may be suitable to you, and providing customer support. You may opt out of providing us your information, but this may affect our services to you.
b. To Communicate with You. We use the information we collect to contact you via telephone, text, chat, or email. We will obtain your consent to contact you when and in the manner required by law.
c. To Improve Our Services. We use the information we collect to improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications and websites. We also use the information to diagnose and address technical and service problems.
d. To Promote Our Services. We use the information we collect to promote our services, including marketing products and features directly to you. We will obtain your consent to contact you when and in the manner required by law. We may also use the information to perform data analyses, including market and consumer research, trend analysis, demographic analysis and financial analysis.
e. For Legal Reasons. We may access, use, preserve, transfer or disclose information, at any time without notice to you, any information, including personal information as reasonably necessary to: (1) protect or defend our interests and the legal rights or property of AutoGravity and our affiliates; (2) protect the rights, interest, safety and security of users of the AutoGravity Services, its partners, or members of the public; (3) protect against fraud or for risk management purposes; (4) or comply with prudent legal practice as we may determine, and applicable law or legal process.
4. When We Share Information About You. We do not sell or otherwise share information about you that we collect or receive, except as described below.
a. When you shop for a vehicle. We may share information about you, including personally identifiable information, to dealers and manufacturers, and their agents and third-party service providers such as auto brokers, when you shop for a vehicle using the AutoGravity Services. We require such third-party parties to maintain information about you as confidential when the information is used for purposes of carrying out their agreements with AutoGravity, but they may also use the information in connection with their own activities to the extent allowed under their own privacy policies and applicable law. For example:
i. If you have indicated interest in purchasing or leasing a specific unit of vehicle inventory found on the AutoGravity Services, information about you may be shared with the seller of that particular vehicle or similar vehicles and to other dealers who may have similar vehicles available.
ii. We may provide manufacturers, their agents or third-party service providers such as auto brokers, with information about you that we provided to their franchised dealers.
iii. We may provide dealers, manufacturers, their agents or third-party service providers, with information about you when you access the AutoGravity Services via AutoGravity functionality or advertising that is integrated into their websites or applications.
b. When you obtain finance offers. We may share information about you, including personally identifiable information, to our Lenders and their agents and third-party service providers, when you express interest in obtaining finance offers from our Lenders. We require such third-party parties to maintain information about you as confidential when the information is used for purposes of carrying out their agreements with AutoGravity, but they may use the information in connection with their own activities to the extent allowed under their own privacy policies and applicable law. For example:
i. If you are interested in obtaining finance offers, we may share information about you to our Lenders so that they may provide you with finance offers.
ii. If you are interested in obtaining financing, we may share your information about you to our Lenders so that they may complete a credit application.
iii. We may provide dealers with information about you provided by our Lenders, including your Credit Decision.
iv. We may provide Lenders with information about you provided to us by dealers, including your vehicle purchase or lease information.
v. We may provide Lenders, their agents or third-party service providers, with information about you when you access the AutoGravity Services via AutoGravity advertising or functionality integrated into their websites or applications.
d. When We Collaborate with Third Parties to Provide or Improve Our Services. We may sometimes share information about you with third parties we collaborate with to provide the AutoGravity Services or to improve it. This may occur, for example, when we’re providing an integrated or co-branded feature with a partner. We require such third-party collaborators to maintain information about you as confidential when the information is used for the collaboration’s purposes, but they may also use the information in connection with their own activities to the extent allowed under their own privacy policies and applicable law.
e. As Part of a Corporate Transaction. If we are involved in a merger or transfer of our business, we may transfer all information that we have collected and stored, including personal information, to the parties involved as part of that transaction.
f. When the Data is Anonymized or Aggregated. We may share information about you when the data is anonymized or aggregated in such a manner that the information about you cannot be traced back to you specifically.
g. For Legal Reasons. As discussed above, we may access, use, preserve, transfer or disclose information, at any time without notice to you, any information, including personal information as reasonably necessary to: (1) protect or defend our interests and the legal rights or property of AutoGravity and our affiliates; (2) protect the rights, interest, safety and security of users of the AutoGravity Services, its partners, or members of the public; (3) protect against fraud or for risk management purposes; (4) or comply with prudent legal practice as we may determine, and applicable law or legal process.
h. With your consent. We may share information about you in other limited circumstances with your express consent.
5. Communications and Privacy Preferences. You can make certain choices about how we use your information to communicate with you.
a. You may choose not to provide personal information. However, not providing us with personal information, including your contact information, may impact or limit the products and services you receive from us. Providing contact information to us, such as an email address, telephone number, mobile phone number, or mailing address is also giving us express consent to contact you using those means of communications. We may obtain additional consent when and in the manner required by law.
b. If you do not want to receive marketing email from us, you can follow the unsubscribe link provided in those emails.
c. Some communications and privacy preferences can be accessed by logging into your account on the AutoGravity Services and editing the preferences in your member profile.
d. If you do not want to receive interest-based advertisements displayed by third parties on the AutoGravity Services, you can opt out by contacting the Advertising Provider (discussed below) using the links found in or around the third-party advertisement.
e. You may also have the ability to adjust app or browser specific communications settings within the settings screen of your mobile app or browser, which may affect how technologies like cookies and push notifications are handled.
f. If you do not want us to use Location Information, you can opt out by changing the location services settings on your mobile device. Certain features of the AutoGravity service may be limited if you opt out.
8. International Users. The AutoGravity Services are exclusively hosted in the United States. If you are accessing the AutoGravity Services from outside of the United States, information collected through the AutoGravity Services may be transferred to, processed, and stored within the United States, which may have laws and regulations that differ from your region.
9. Notice to California Residents. Under California Civil Code Section 1798.83, AutoGravity Services users who are also California residents may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. You may make such a request by contacting us as indicated in Section 14.
10. Data Security. We use commercially reasonable administrative, technical, personnel, procedural and physical security measures intended to protect information about you in our possession against loss, theft and unauthorized use, disclosure or modification. Despite these measures, we cannot guarantee perfect security of the networks, servers and databases we operate or that are operated on our behalf. Additionally, we cannot guarantee the confidentiality of information that is carried on an open network, such as on a Wi-Fi network that may be shared with the public.
11. Records Retention. Due to our recordkeeping and information retention requirements, we do not delete information about you upon deactivation of your account. Upon your request, your account will be disabled and you will not receive further communications in connection with your account. Except to the extent necessary for legal or regulatory recordkeeping purposes, we may, at some point in time and at our sole discretion, anonymize the data in your Member Profile after you deactivate your account.
12. Access and Correction. In some circumstances, you will have access to information that we collect and maintain about you. If you have created a password-protected account to access the AutoGravity Services, you can access that account to update the information you previously provided. If you believe that other information we maintain about you is inaccurate, subject to applicable law, you may request that we correct, amend, or remove the information by contacting us as indicated in Section 14.
13. Equal Credit Opportunity Act. The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant's income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal agency that administers compliance with this law concerning the AutoGravity Services is the Federal Trade Commission, Equal Credit Opportunity, Washington, DC 20580.