Effective September 18, 2020
III. The Information That We Collect
We collect information to provide our services, which include selling and servicing vehicles and vehicle parts, and to perform other functions related to those services (collectively, the “Dealership Services”).
Personally Identifiable Information
The information we collect includes the following: personal identifiers, such as name, address, date of birth, gender, and contact information; financial information in connection with a transaction, such as credit card number and bank account information; commercial information such as your purchase history; and professional or employment-related information.
Non-Personally Identifiable Information
We may collect information that is related to you but that does not personally identify you (“non-personally identifiable information”). For example, any time you visit our website, we may gather certain information regarding the means you use to access our site. This information may include the type and version of your browser, your service providers, your IP address, and any search engine you may have used to locate the site. We use this information to help diagnose problems with our server, administer our website, and compile broad statistical data. In addition, we gather certain navigational information about where you go on our website. This information enables us to determine which areas of our website are most frequently visited and helps us to tailor the sites to the needs and interests of our online visitors. Such information is gathered by us in the aggregate and is not associated with a specific individual.
Non-personally identifiable information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information).
IV. How We Collect Information
Information Voluntarily Provided
Holman Auto also collects information you provide to us (i.e., name, e-mail address, etc.) when you interact with our business either online or in person. You provide some of this information directly, and we get some of it by collecting information about your interactions and experiences with the Dealership Services. The information we collect depends on the context of your interactions with Holman and the choices you make, including your browser privacy settings and the products and features you use.
Information Automatically Collected
Email Communication: We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that are embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.
Mobile Communication: When you download or use our mobile-device applications, or access our mobile-optimized website, we may receive information about your mobile device, including a unique identifier for your device.
In addition, Holman Auto uses Google Analytics, which utilizes cookies to track performance, which enables us to enhance the customer experience on our website. For more information on how Google users your data when you visit our website, go here.
Information from Third Parties
We may collect information about you from third parties to provide or enhance the Dealership Services. For example, we collect demographic and other information to improve the accuracy and relevance of our marketing efforts. We also collect information from third parties to help us correct or supplement our records, improve the quality or personalization of our services to you, and to prevent or detect fraud.
V. How We Use and Maintain Your Information.
We use your information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we use personal and non-personally identifiable information, collected online and offline, including information from third party sources.
We understand the importance of your privacy and take the confidentiality, integrity, and availability of your information seriously. To ensure the security of your information, we take reasonable physical, electronic, and managerial measures to safeguard and secure your information.
While we strive to ensure that your data is always protected, no data transmission can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. By using the Dealership Services or providing your information to us, you agree that we can communicate with you regarding security, privacy, and administrative issues relating to your use of the Dealership Services.
VI. How We Share Your Information.
We understand the importance of your privacy. We collect and maintain your information for our use in connection with providing the Dealership Services, and we do not disseminate your information to third parties other than as described below.
Business Partners: We may partner with select retailers and other companies at various times to provide expanded services to our customers, including, for example, vendors, marketing companies, financial institutions, and government entities.
Agents: We may use other companies and individuals to perform certain functions and Dealership Services on our behalf. Examples include administering e-mail services and running special promotions. Those parties only have our permission to access and use the information needed to perform these functions, and may not use or store the information for any other purpose.
Business Transfers: If we sell or transfer all or a portion of our business assets, consumer information may be one of the assets that is transferred as part of the transaction.
Compliance with Law/Safety: We may disclose your information in order to protect the legal rights of Holman Auto, its affiliates, or their employees, agents, and contractors; to protect the safety and security of Holman Auto’s customers; to protect the rights, property, and safety of Holman Auto; or when legally required to do so, at the request of governmental authorities conducting an investigation, or to verify or enforce compliance with the policies governing the Dealership Services and applicable laws.
VII. Notification of Changes
VIII. Special Notice Regarding Minors
We respect the privacy of children of all ages and in particular recognizes the sensitivity of the information of children under the age of 13 (“Minors”). Therefore, we provide this special notice to parents and legal guardians regarding the collection and use of the information of Minors. The Dealership Services are not directed toward Minors. We do not knowingly collect information from Minors. In the event that we learn that a Minor has provided their information to us, we will delete such information as soon as possible.
IX. Contact Information
The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their information. This California Addendum (“Addendum”) provides detailed information to California residents about our information collection and sharing practices, and describes how California residents may exercise their specific data privacy rights under CCPA. This Addendum applies only to individuals who are, or at relevant times have been, residents of the State of California.
I. Information Collection and Sharing Practices
A. Information That We Regularly Collect
The following are categories of information that we regularly collect in the operation of our business:
Categories of Information Collected
|Examples of Information in Each Category|
|· Identifiers||A real name, alias, postal address, unique personal identifier, IP address, email address, account name, Social Security number, driver’s license number, or other similar identifiers.
|· 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, 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 other financial information.
|· Protected classification characteristics under California or federal law||Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status.
|· Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|· Biometric information
· Internet or other similar network activity
|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.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|· Geolocation data||Physical location or movements.
|· Professional or employment-related information||Current or past job history or performance evaluations.
|· Inferences drawn from other information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
B. Sources Where We Collect Information
We collect information from many sources, including through our website, in person at our dealership, and from various third parties. The following is a non-exclusive list of categories of sources from which we collect information:
· Information that you provide to us directly. For example, we collect information from forms you complete online or in person at our dealership. Forms are often completed to inquire about a product or service that we sell, to test drive one or more of the vehicles we sell, to complete a credit application, or in connection with a product or service that you purchase from us.
· Information that we collect from interactions with you. For example, from observing browsing behavior on our website, recording phone conversations for quality control and training purposes, video footage captured by security cameras when you visit our facility, or telematics data from a service vehicle that you borrow from us.
· Information that we receive from Audi of America. We may receive information about you from Audi of America, which is the vehicle manufacturer with whom we have a franchise relationship. Audi of America shares information with its dealers for many reasons, including for marketing purposes, in connection with sales and service transactions that you initiate, for warranty and recall purposes, and where we act as a service provider to Audi of America (e.g. lease surrender and roadside assist).
· Information that we receive in connection with a credit or lease transaction. Many customers request our assistance with arranging financing or desire to enter into a lease transaction. When our transaction with you involves an extension of credit, we receive information about you from credit bureaus and financial institutions.
· Information that we receive from third parties that advertise our products and services, or that otherwise refer you to us. We engage independent third parties to advertise our inventory on their websites, and when you submit an inquiry about our products and services, they share those inquiries with us. We also have relationships with third parties that refer customers to us, and that identify product and service offerings relevant to individual customers’ interests.
· Information that you post online. We may collect information that you post online regarding our dealership, such as reviews on third party websites like Google Reviews and Yelp.
C. Our Commercial or Business Purposes for Using Your Information
We may use your information for one or more purposes. The following is a non-exclusive list of the purposes:
· To answer questions, respond to requests or provide support. For example, if you share your information to request a price quote, or ask a question about our products or services, we will use that information to answer your questions.
· To complete a transaction that you initiate. If you provide your information in connection with the purchase of products or services from us, we will use that information to complete the transaction you requested. A non-exclusive list of uses in this category include:
o To request information about you from credit bureaus and financial institutions so that we can confirm with third parties what financing terms may be available to you. Information from credit bureaus is also used for our underwriting and security purposes in some cash transactions.
o To complete transaction paperwork, process your payment and facilitate delivery of the products and services you have purchased.
o Submit registration and other documents to government agencies (e.g. DMV) and third parties from whom you have purchased products and services (e.g. a service contract).
o To facilitate new product orders or process returns.
· To communicate Information about your vehicle to Audi of America. When you purchase a new Audi vehicle from us, we will report your information to Audi for purposes of reporting the vehicle as sold, confirming or activating the manufacturer’s warranty coverage, and soliciting feedback about your experience with us. When you service your Audi vehicle with us, we communicate your information to Audi to confirm and update the status of open recalls, and to report the repairs performed to your vehicle for warranty and other purposes.
· To provide a personalized marketing experience. We may use your information to personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third party websites, and via direct marketing.
· For investigation, quality control and training purposes. We may use your information to investigate and address your concerns, to monitor and improve our responses and processes, and for training purposes.
· For legal and compliance reasons. We may use your information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. We may also use your information for compliance purposes, such as conducting internal investigations, asserting our rights in a legal dispute, responding to and defending litigation or governmental investigations, or to otherwise ensure compliance with applicable law, court order, or governmental regulations.
· To maintain the security and integrity or our systems, people and operations. To help maintain the safety, security, and integrity of our website, databases, and other technology assets, our employees and customers, and our operations.
· In connection with a corporate reorganization. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of our business or our affiliates’ businesses, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your information is transferred.
· For internal research for technological development. To assist in the development of products and features that in turn allow us to provide new offerings and a better experience.
· To maintain or improve the quality of services that we offer. We may provide your information to service providers to assist them in maintaining or improving the services that they allow us to offer our customers.
· As otherwise described to you when collecting your information.
D. Categories of Third Parties with whom we Share Your Information
In the ordinary course of operating our business, we disclose your information to third parties for a number of business purposes. The following is a non-exclusive list of categories of third parties with whom we share your information:
· Service providers, such as providers of our customer relationship management software, e-mail and other software platforms, providers of payment processing systems, and providers of our telephone and internet systems
· Business partners, such as marketing companies, lead generators, and other entities with whom we partner to offer our products and services
· Audi of America
· Financial institutions, for purposes of obtaining financial products that our customers may purchase
· Governmental entities, such as the Department of Motor Vehicles to register vehicles and the United States Department of Defense to ensure compliance with the Military Lending Act
· Credit bureaus, to obtain credit information needed to offer financial products and services to our customers
· Our affiliated companies
· As otherwise described to you when collecting your information.
E. Disclosures and Sales of Information in the Past Twelve Months
In the past twelve months, we have disclosed the following categories of information for a business or commercial purpose:
· California Customer Records personal information categories
· Protected classification characteristics
· Commercial information
· Internet or other similar network activity
· Geolocation data
· Professional or employment-related information
The specific pieces of information included in these categories are discussed in more detail in Section 1.A. of this California Addendum, above.
We are not a data broker, and do not consider ourselves to otherwise be in the business of selling your information. While CCPA includes a broad definition of what it means for a business to “sell” your information, we have determined that we do not currently sell your information.
We do not collect information about minors under the age of 16. Therefore, we do not sell the information of minors under 16 years of age, with or without your affirmative authorization.
II. Right to Request Your Information.
Under CCPA, you have the right to request access to your information. You may request to know the categories of information that we have collected from you including, the business or commercial purpose for the collection of that information, the categories of third parties with which we share your information, the categories information that we sell or disclose for business purposes, or you may request to know the specific pieces of we have collected from you. If we sold or disclosed your information for a business purpose, we will also provide you with two separate lists disclosing:
· Disclosures for a business purpose, identifying the information categories that each category of recipient obtained; and
· Sales, identifying the information categories that each category of recipient purchased.
Before responding to this type of request, we must verify your identity. Once we have done so, we will comply with this request, except when another law or regulation prohibits us from doing so, or where another exception under CCPA applies. You may only make a request for access to your information twice within a 12-month period.
You may submit requests for your information here. See Section 5 below (“How to Submit Requests“) for more information.
III. Right to Deletion of Your Information.
You also have the right to request that we delete the information that we have collected from you. Before complying with your request to delete your information, we must verify your identity. Once we have done so, we will comply with this request, except when another law or regulation prohibits us from doing so, or where another exception under CCPA applies. See Section 5 (“How to Submit Requests“) below for more information about how to submit a request to delete your information.
IV. Right to Opt Out of the Sale of Your Information.
You also have the right to opt-out of the sale of your information. However, because we do not currently sell consumers’ information, we do not offer an opt-out function.
V. How to Submit Requests.
You may submit requests for your information and deletion requests in the following ways:
II. By calling our toll-free number: 833-399-0094
Only you, or someone legally authorized to act on your behalf, may make a request related to your information. You may also make a request on behalf of your minor child. You may use an Authorized Agent to submit your request. The Authorized Agent must be registered with the California Secretary of State and be authorized to submit requests on behalf of a consumer. If you are an Authorized Agent and a consumer has given you signed permission to submit a request on their behalf, Holman Auto requires that you send a copy of your signed permission to Holman Auto. Failure to submit proof of signed permission may result in Holman Auto denying the consumer’s request. Holman Auto will require the consumer to verify their identity and directly confirm with Holman Auto that the consumer has provided you with permission to submit the request.
We endeavor to respond to all requests within 45 days of receipt. If we require additional time, we will inform you of the reason and extension period.
VI. Verifying Requests.
Holman Auto provides California consumers with the ability to submit requests through our request website or our telephone number. Holman Auto must verify that the person requesting information or deletion is the California resident about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three (3) pieces of personal information about you when you make a request to compare against our records. We cannot respond to your request or provide you with personal information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in your request to verify your identity. Holman Auto reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.
We will not discriminate against you based on your decision to exercise your right to request information or your right to request deletion, as described above. That means we will not deny you any of the products or services we offer, nor will we charge you a different price for those products and services, based on your decision to exercise your data privacy rights.