Our dealership takes your privacy seriously and is committed to safeguarding your privacy online. Because we do gather certain types of information from visitors to our sites, we have developed a privacy statement to help you understand the terms and conditions surrounding the collection and use of that information. This statement discloses the types of information we gather, how it is used, and how you can gain access to and edit any data that we’ve collected about you at any time.
Our dealership respects the privacy of individuals who visit our Web sites, send us e-mail, or participate in features/services we offer online. Accordingly, our policy regarding online privacy has been developed using the following guiding principles:
Our dealership maintains a strict “no-spam” policy. Subscribers to our e-mail services (or any other feature/service found on our Web site) will not receive unsolicited e-mail messages from us. Our dealership collects information online primarily to provide our visitors with a more relevant experience on our sites. When doing so, we will make every reasonable effort to avoid excessive or irrelevant collection of data. Our dealership will take reasonable physical, electronic and managerial measures to safeguard and secure any information you provide to us (e.g. data will be stored in protected databases on secured servers with restricted access). Our dealership will not share any information you’ve provided to us with anyone without your consent other than to provide the service you’ve requested. At the time you register for any such service, you will be notified of, and asked to consent to, the sharing of your information with any particular third party necessary to the provision of the requested service.
Anytime you visit our Web site, we may gather certain non-personally identifiable information regarding the means you use to access our site. This information may include the type and version of your browser, your service provider, 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 the Web site, and compile broad statistical data. In addition, we gather certain navigational information about where you go on our Web sites. This information enables us to determine which areas of the Web sites 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 will not be associated with a specific individual without that individual’s consent.
Any information you provide to us (i.e. name, e-mail address, etc.) when you enroll in one of our E-Mail Reminder Services, request information, or use any of the other interactive portions of our Web sites, is securely maintained on our Web server and internal systems. This information may be used to provide you with information you’ve requested about our company, our products and our services, or to provide you with special notices. You may opt out of receiving future communications at any time (see opt-out Procedures below). This data may also be used to tailor your experience on our sites by providing content that is relevant to your interests and geographic region.
To help us better understand and respond to your needs and interests, we may in the future receive information about you from other sources. We will ask any provider of such information to represent and warrant that the information has been gathered and maintained in accordance with all state and federal laws. Any such information will be maintained by us in accordance with the standards set forth in this privacy policy along with other personal information you’ve provided.
Our dealership understands the importance of your privacy. We collect and maintain the personal information of our consumers for our use and our subsidiaries. We do not sell, rent, or trade consumer information to third parties, other than as described below, and never without your consent. Third parties may collect personally identifiable information about your online activities over time and across different websites when you use this website.
Our dealership may partner with select retailers and other companies at various times to provide expanded services to our site visitors. As part of such a relationship, we may share with these companies the use of certain interactive Web site functions (i.e. the E-Mail Reminder Service). Information provided by site visitors through the use of such interactive functions may be available to both our dealership and our partners.
Our dealership may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from agents working on our behalf.
In the event that our dealership sells or transfers a particular portion of its business assets, consumer information may be one of the business assets transferred as part of the transaction. If substantially all of the assets of our dealership are acquired, consumer information may be transferred as part of the acquisition.
Our dealership may disclose specific personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect the users of our Web sites, the sites themselves, or the public.
Other than as set forth in this Privacy Policy, you will be notified when any personally-identifiable information about you may be shared with third parties, and you will be given the opportunity to decline to share that information.
Our dealership may use a browser feature known as a “cookie.” Cookies are small files placed on your hard drive that assist us in providing you with a customized browsing experience. Our dealership uses cookies to provide you with the convenience of not having to reenter information, such as user IDs and passwords, multiple times during your visits to our Web sites. Cookies can also be utilized to help us provide you with information targeted to your interests, based upon your prior browsing on our Web sites. The “help” section of the toolbar on most browsers will inform you on how to prevent your browser from accepting new cookies, how to have the browser notify you upon the receipt of a new cookie, or how to disable the use of cookies completely. As our Web sites have been designed to take advantage of the use of cookies. Should you configure your browser to decline their use, certain features of our Web sites may not function correctly and you may be required to renter any user IDs and passwords more frequently.
If you are visiting our Web site from a location outside of the U.S., your connection will be through and to servers located in the U.S. Any information you provide during your visit will be processed and maintained on our Web server and other internal systems located within the U.S.
Our Web sites contain links to other sites. Our dealership is not responsible for the privacy practices or the content of such Web sites. To help ensure the protection of your privacy, we recommend that you review the privacy policy of any site you visit via a link from one of our Web sites.
The personal data record created through your registration with our Web site can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.
Our Web sites may make chat rooms, forums, message boards, and/or news groups available to its users at various times. Please remember that, unless otherwise stated, any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information in these areas.
You may always opt-out of receiving future communications from our dealership. Our sites allow users to opt-out of receiving such communications at the point where personal information is requested, or through other means as identified.
Some browsers incorporate a “Do Not Track” (DNT) feature that, when turned on, signals to websites and online services that you do not want to be tracked. Because there is not yet an accepted standard for how to respond to a DNT signal, we do not currently respond to DNT signals on this website or on websites where we provide advertisements, content, or other services.
If you have questions concerning this Privacy Policy or the practices of these sites, you may contact us.
The dealer is committed to accessibility, diversity, and inclusion for all of its guests. We believe everyone should be able to visit our site, use our mobile apps, and access our service easily. We welcome feedback. If you notice any content, feature or functionality of the Site that you believe is not fully accessible to people with disabilities, please contact us and provide a description of the specific feature you feel is not fully accessible or a suggestion for improvement. We take your input seriously and will consider all feedback received as we evaluate ways to accommodate our customers and continuously improve our overall accessibility polices.
If you are a California or Nevada resident, state law may provide you with additional rights regarding our use of your personal information. This information is intended to comply with the California Consumer Privacy Act of 2018 and Nevada Senate Bill 220 (an Act relating to Internet privacy) and other California and other state privacy laws (all such laws are collectively referred to for purposes of this Privacy Policy as the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
(Including, but not limited to) or (non-exhaustive list) 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 (including language use and possession of a driver’s license issued to persons unable to provide their presence in the United States as authorized under federal law), citizenship, religion or creed (including religious dress and grooming practices), marital status, medical condition (including cancer or a record or history of cancer), AIDS/HIV, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, childbirth, breastfeeding and related medical conditions), sexual orientation, veteran or military status, Political affiliations or activities, status as a victim of domestic violence, assault, or stalking, genetic information (including familial genetic information), request for family care leave, request for leave for an employee’s own serious health condition, request for Pregnancy Disability Leave, retaliation for reporting patient abuse in tax-supported institutions. YES
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. NO
F. Internet or 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. YES
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 personal information Profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes YES
Publicly available information from government records.
De-identified 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;
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.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our users when they submit a lead form or other web form on the site.
Directly and indirectly from interaction with our website (or an affiliated site). For example, from submissions through our website portal or website usage details (including without limitation IP address, device ID, geolocation data collected automatically).
Directly and indirectly from our service providers or their agents.
From data aggregators/providers and similar vendors.
From third parties that interact with us in connection with the services we perform. For example, we may receive aggregated vehicle sales records for analytics and other purposes.
From anti-fraud and other crime prevention partners.
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order to indicate interest in a particular vehicle, promotion or offering.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you including the powering of products and features used throughout the site.
To power and maintain saved user accounts.
For attribution purposes.
To send promotional materials.
To provide custom and/or individually-tailored website experiences.
For ad serving, targeting and retargeting, creation of audience segments, and related OBA (online behavioral advertising) purposes.
To create inferred search preferences and inclination/intent to purchase certain vehicles or makes/models for improved ad targeting and custom experience implantation.
For internal operations and site optimization including product development.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To enable anti-fraud and crime prevention efforts.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
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 is among the assets transferred.
For additional purposes more fully described in this Privacy Policy.
We 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.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
A. Identifiers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
C. Protected classification characteristics under California or federal law
D. Commercial information
F. Internet or similar network activity
G. Geolocation data
K. Inferences drawn from personal information
In the preceding twelve (12) months we have not sold personal information.
Categories of Parties to which we may Disclose Personal Information:
We may disclose your personal information for a business purpose to the following categories of third parties:
Our subsidiaries, parent(s) and affiliates
Service providers (including, without limitation, website and internal operations platform providers)
Automotive OEMs
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months we have not sold personal information.
The CCPA provides consumers 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 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, 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.
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, 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 providers to:
Complete the transaction for which we collected the personal information, 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 and/or 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 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.
We will not discriminate against you for exercising any of your CCPA rights. 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.
Changes to this Privacy Policy:
We reserve the right to update and periodically amend this Privacy Policy at our discretion and at any time. If we make changes to this Privacy Notice, amendments will be posted online, and the date of update will be included. Your continued use of this site and affiliated sites after any such update indicates your agreement to the same.
If you have questions concerning this Privacy Policy or the practices of these sites, you may contact us at privacy@sullivanbrothers.com