PRIVACY POLICY

LAST UPDATED: JULY 18, 2023

EFFECTIVE DATE: FEBRUARY 3, 2020

Your privacy is important, so we created this privacy policy to help you understand how we collect, store, use, or disclose your personal information. Unless stated otherwise, this Privacy Policy applies when we interact with you through our online services, including but not limited to our web sites, application and contact forms, email correspondence, and any other services that link to this Privacy Policy.

If you are in the United States and submitted an application through the Driving With Steve Web Site, the FCRA Consumer Notice also applies to you.

WHO ARE WE?

Our web sites and all pages thereof, including the web site through which you accessed this Privacy Policy (collectively, the “Web Sites” or “Sites”, and each a “Web Site” or “Site”) are each operated by Dealer Media Inc. and/or one or more of its affiliates and/or agents (“Dealer Media” or “we” or “We” or “our” or “Our”). Dealer Media operates a number of Web Sites to advertise, promote, and offer its services to the public, including Driving With Steve. This Privacy Policy, and the personal information handling practices described below, apply to all of our Web Sites and the collection, use, and disclosure of your personal information by us through all of our Web Sites, including the Web Site through which you accessed this Privacy Policy.

We may have to change this Privacy Policy to reflect new regulations, new technologies or changes to how we collect, use or disclose your personal information. We reserve the right to change this Privacy Policy at any time at our sole discretion. To the extent that our privacy policy changes in a material way, the privacy policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. The date of the most recent revisions will appear at the top of this page.

If you do not agree with this Privacy Policy, please do not use or access any of our Web Sites, and if you do not agree to any changes to this Privacy Policy that we make in the future, you must end your use of our Web Sites and the services available through our Web Sites.

WHAT IS PERSONAL INFORMATION?

Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider personal information to include information that has been de-identified so that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer. Your name, e-mail address, and IP address are all examples of data that may be personal information. Information collected by “cookies” may or may not be considered personal information, depending on the law applicable in your jurisdiction and the nature of the cookie. Please see our Cookie Policy below to review detailed information about our use of cookies and similar technology.

WHAT PERSONAL INFORMATION DO YOU COLLECT?

We collect and store personal information directly from you when you interact with us or when you submit personal information to us. For example, when you submit information to us online by or through our Web Sites, by phone, by email, through our application forms on one or more of our Web Sites, via social media, or when you provide us with personal information through the “Contact” or “Contact Us” form on one or more of our Web Sites. Categories of personal information that we collect about you when you interact with us online or offline may include the following:
  • Identification data you share with us, including name, address, and gender;
  • Contact information you share with us, including e-mail address, phone number, and mailing address;
  • Where we make available account functionality on a Web Site, information you provide to create an account, including password and username, contact information, and data such as contact preferences;
  • If you send us a query by email or via a contact form on one of our Web Sites, we may collect your name, contact details and details of the query, which we will use to respond to you;
  • If you send us an application form in connection with our services through one of our Web Sites, we may collect your contact information including your name and address, credit information including your actual or approximate credit score and such information as is necessary to send to generate a credit report, income and salary information, home ownership and payment information, employer name and job title, age and date of birth, financial data, contact details, and other information that you share with us and that is required to allow you to use our services. If you submit our application form in connection with our services through one of our Web Sites, Dealer Media, car dealerships, and other person(s) or organization(s), will conduct independent searches in relation to your Personal Information;
  • Contact information and address information associated with social media accounts that you provide to us, including web address, profile and related information associated with your social media accounts; and
  • Information part of your credit application that a dealership or third party may send back to us,
  • Information you submit to us directly via email or other communication methods including, but not limited to, general inquiries, media inquiries, and customer support.
  • Information you provide when applying for a job with us, including name, email address, and resume information.
As part of the provision of our services, we may collect your social security number. We use this information to confirm your identity and match you with local dealerships. Where account functionality is available we may also collect your account username and password. This allows you to access some portions of our services. Both types of information may be considered sensitive information under certain laws. We do not “sell” or “share” your sensitive personal information as those terms are defined by Cal. Civ. Code 1798.100 et seq. In addition to information you provide to us, we may also collect your personal information from other sources such as:
  1. Our partners and affiliates, and through automatic collection through our Web Sites and emails;
  2. Our service providers, who may assist us with performing aspects of our services or may handle your personal information on our behalf, as set out in this Privacy Policy;
  3. Your computer or device, from which we may obtain information about your location; and
  4. Internet activity and other electronic data, such as your IP address, device ID, and information collected from cookies and similar technology when you open our emails and visit our Web Sites (for more information about cookies, how we use them, and your related choices, please see our Cookie Policy below).
We may make available a linked ‘Careers’ panel and functionality through one or more of the Web Sites, where you can view career opportunities with Dealer Media and submit an application for an open career opportunity. These functionalities are provided by a third party service provider, who provides services to Dealer Media. Our service provider is responsible for the handling of your personal information that you provide to them. The collection and use of your personal information for employment purposes by Dealer Media’s third party service provider may be subject to the privacy policy of that service provider. If you use the ‘Careers’ panel and functionality through one of our Web Sites, please review and consider the privacy policy of our service provider, before you provide them with your personal information.

HOW DO YOU USE PERSONAL INFORMATION?

We use the above categories of personal information to support our typical business activities, and to provide services to our customers, in particular for the following purposes:
  1. Respond to your requests, for instance, if you contact us by email, by our contact form(s) on our Web Sites, and/or through our application forms on our Web Sites, or when you provide us with personal information through the “Contact” or “Contact Us” form on one or more of our Web Sites;
  2. Offer you a tailored version of one or more of our Web Sites;
  3. Manage and administer our Web Sites;
  4. Improve our services;
  5. Notify you about changes to our legal terms or business practices, or the terms of this Privacy Policy;
  6. Get in touch with you after you submit an inquiry to us;
  7. Where we make available account functionality on a Web Site, setting up, administering, and managing your account, and your preferences on our Web Site(s);
  8. Display advertisements related to products and services that we think may interest you, on one or more of our Web Sites, in e-mail communications you consent to receive, and/or on social media platforms;
  9. Personalizing the version of the Web Site displayed to you, and displaying where our products or services may be obtained from locations near you;
  10. Review and use your personal information for compliance with our legal obligations, for the security of us and our employees and customers, and to protect against fraud; and
  11. Use and disclose your contact and personal information to our affiliates and advertising partners, for use in cross-promotional advertising and lookalike ad targeting (including to develop advertising profiles and look-alike audience profiles).
If you are in the United States and submitted an application through the Driving With Steve Web Site the FCRA Consumer Notice also applies to you. If you send us an application form in connection with our services through one of our Web Sites application, we may use your applicable personal information to:
  1. Obtain any and all credit information concerning your application from any sources which Dealer Media deems appropriate;
  2. Obtain consumer credit reports from one or more credit reporting agencies in connection with the administration of your application;
  3. Communicate with you in-person, by telephone, mail, email, text or any social media platforms;
  4. Disclose information concerning your application, including your personal information, to one or more persons or organizations, affiliates, credit reporting agencies, or wholesale lead providers, any or all of whom may conduct independent searches using the information disclosed in your application for the purpose of processing and facilitating your application,
  5. Correspond with third parties to obtain or estimate your credit score or credit reports, process your application and your request for our services to determine what vehicle(s) or other product(s) may be suitable for you, and to refer and send your personal information to others including wholesale lead providers or motor vehicle dealerships who may be able to assist you in financing and purchasing a vehicle;
When you voluntarily submit an application to us we use technology and the personal information you provide us to create a profile assessing your economic situation that we then use to provide you with the services.

HOW CAN I OPT-OUT OF RECEIVING MARKETING E-MAILS?

We may communicate with you through e-mail for marketing and promotional purposes. When you receive such communications from Dealer Media, you can always unsubscribe using the link in the e-mail. Alternatively, you can reach out to us directly: [email protected].

HOW DO YOU PROTECT PERSONAL INFORMATION?

We strive to implement reasonable measures to protect your personal information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and any other unauthorized access or use. We aim to ensure that the level of security and the measures adopted to protect your personal information are appropriate for the risks presented by the nature and use of your personal information. Additionally, we maintain internal governance policies designed to protect your information. These governance policies include, but are not limited to, Internal Privacy Policies, Written Information Security Protocols, Incident Response Plans, Data Subject Request Protocols, and Record Retention and Destruction Policies. However, we cannot guarantee that your personal information will be secure from theft, loss, alteration, misuse, or unauthorized access, nor do we make any representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such information.

Please immediately contact [email protected] in the event that you feel the security of your personal information has been compromised. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

DO YOU SHARE PERSONAL INFORMATION WITH OTHERS?

We share your personal information with car dealers in order to assist you with the purchase of a vehicle. If you are in the United States and submitted an application through the Driving With Steve Web Site the FCRA Consumer Notice also applies to you.

We may share personal information with service providers that we partner with to assist us in various functions, including (but not limited to) providing technological support and performing security and anti-fraud services, providing you with our services where applicable, and providing you with communications and marketing information on our behalf.

These service providers include the following:

  1. Credit partners, who process your credit information to conduct credit checks and provider one or more reports on your creditworthiness;
  2. Marketing partners, who we may use to display advertisements, to send you promotional communications, and for the purposes of cross-promotional advertising among and between different entities within the Dealer Media Group of Companies, and lookalike ad targeting (including developing advertising profiles and look-alike audience profiles);
  3. Recruitment service providers, who will hold information provided to the third party web site and ‘Careers’ functionality;
  4. IT service providers, such as our web and data hosting providers; and
  5. Other service providers, who we may engage to provide services to us or on our behalf.

These service providers may process your personal information as part of the services they offer to us. We take steps to ensure that our service providers process your personal information in accordance with applicable privacy laws and regulations, only use it in accordance with our contract with them, and keep it secure. If you would like more information about our service providers, including the identities of those service providers, please contact us by e-mail at [email protected].

We may have to share your personal information if necessary, in our judgment, to comply with laws or regulations or in response to a subpoena, warrant, or legal order, or to protect our rights or the rights of others.

We reserve the right to transfer your personal information to a successor entity (or potential buyer) if we sell or transfer our business operation. We reserve the same right in case of merger, acquisition, bankruptcy, reorganization or sale of assets. In addition, in the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court.

Our Web Sites may contain links to other sites on the Internet that are owned and operated by third parties, including social media (the “External Sites”). Even if the third party is affiliated with Dealer Media, Dealer Media has no control over these External Sites, all of which have separate privacy policies, data collection practices and terms and conditions independent of Dealer Media. If you click on these links, you are leaving our Web Site and the collection, use and disclosure of your personal information will be subject to these third parties’ privacy practices, terms of use, and other contractual documentation listed on such External Sites. Dealer Media has no responsibility or liability for these independent policies or actions and is not responsible for the privacy practices, the terms and conditions or the content of such External Sites.

In addition to the disclosures described above, we may share your personal information in other situations with your consent.

WHERE WILL PERSONAL INFORMATION BE STORED?

We may store your personal information in any jurisdiction where we operate, including in Canada (including provinces outside of Quebec) or the United States. When we share your personal information with our trusted partners, they may store some of your personal information in their databases in Canada, the United States, or elsewhere in the world. Please be advised that by transmitting or sending personal information to us, you are transferring your personal information to us in Canada and/or the United States, as applicable, where data protection and privacy laws may be less stringent than the laws of your country.

We will retain your information for as long as needed to provide you with our services, which may include our services through the applicable Web Site, for our valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements. You can request that we delete personal information about you in our possession. If you would like us to delete some or all of your personal information, or delete your account (if applicable), you can reach us directly at [email protected]. For questions regarding your account (if applicable) on a particular Web Site, you can also contact us through the applicable contact information made available on the ‘Contact’ page on each of our Web Sites.

WHAT RIGHTS ARE PROVIDED FOR PERSONAL INFORMATION?

If you are in the United States and submitted an application through the Driving With Steve Web Site the FCRA Consumer Notice also applies to you and describes your rights in personal information submitted via an application.

Different laws allow you to exercise rights relating to your personal information in our possession. Depending on where you are located, these rights can vary. Your rights usually include the right to:

  1. confirm whether we collect, use, or disclose your personal information;
  2. access copies of the personal information that we collect, use and disclose about you, as long as such data remain available in our databases; and
  3. ask for the deletion of your personal information in certain circumstances provided by applicable law.

Depending on where you are located and subject to applicable law, you may have additional rights with respect to your personal information in our possession, including:

  1. “Right to rectification” – the right to ask for the rectification of your personal information in case it is incorrect, incomplete, invalid or ambiguous;
  2. “Right to be forgotten” – the right to request that we erase your personal information in certain circumstances provided by applicable law;
  3. “Data portability” – the right to request that we send to another company, where technically feasible, your personal information; and
  4. The right to request that we restrict the processing of your personal information in certain circumstances; for example, if you contest the accuracy of the personal information while we are verifying the accuracy thereof; and
  5. The right to object to processing of your personal information where it is processed on the grounds of legitimate business interests.
  6. “Right to opt-out of targeted advertising” – the right to request that we no longer use your personal information for purposes of targeted advertising.
  7. “Right to revoke consent” – where we process your personal information based upon consent, you may have a right to revoke such consent. Note, however, that if you revoke your consent for the processing of personal information then we may no longer be able to provide you services.

We will not discriminate against individuals who exercise their privacy rights under applicable law. If you have any questions about your rights or if you want to exercise any of these rights, please contact us at [email protected]. We will take reasonable steps to enable you to access your personal information, or to update or correct personal information in our possession that you have previously submitted.

As required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, your birthdate, or information you provided through your application. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to honor your request.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must provide a copy of the written and signed permission authorizing you to make a request on the individual’s behalf.

If you request a transcription, reproduction, or transmission of your personal information, we may charge a reasonable fee to process your request, subject to applicable laws. In this case, we will contact you about these charges before addressing your request.

Additionally, in some cases, your ability to access or control your personal information will be limited, as required or permitted under the applicable laws. If your request is denied, we will notify you in writing, with the reasons for our refusal and information on how to appeal our decision.

California Residents

The table below describes the categories of personal information we collect and disclose for a business purpose. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information. We may “share” Identifiers, Commercial Information, Internet or other electronic network activity, and Inferences with behavioral advertising networks. You may request more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing.

Category of Personal Information

Disclosures for a Business Purpose

Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks

Professional or employment-related information

  • Affiliates or subsidiaries
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms

Inferences drawn from any of the information listed above

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks

HOW DO WE PROTECT CHILDREN'S PROVACY ONLINE?

Our Web Sites are restricted and limited only to users that are above the legal age in their jurisdiction and we do not knowingly collect or store personal information from children. If you believe that we have personal information from or about a child, please notify us at [email protected].

HOW CAN YOU BE REACHED FOR QUESTIONS, CONCERNS, OR INQUIRIES?

Dealer Media welcomes your comments regarding this Privacy Policy. If you would like more information on this Privacy Policy or Dealer Media’s organizational privacy policies, if you believe that Dealer Media has not adhered to the terms of this Privacy Policy, or if you need access to this privacy policy in an alternative format due to having a disability, you can always reach out to us by e-mail at [email protected], and our privacy officer will get back to you as soon as possible.

WHY DO WE USE COOKIES?

Dealer Media uses cookies for the following purposes:

  1. To improve your experience when navigating our Web Sites;
  2. To serve you with more personalized advertising;
  3. To remember some of your preferences, or save some of your credentials for your next visit to our Web Sites;
  4. To perform analytics and understand the pages and advertisements that you like, how you ended up on our Web Site or Web Sites and from what type of devices;
  5. To provide functionalities and features of our Web Sites;
  6. To provide information as to where and how visitors to our Web Sites navigated to our Web Sites (i.e., whether or not you accessed our Web Site or Web Sites via an advertisement, and to identify the web site that you visited before our Web Site or Web Sites); and
  7. If you subscribe to our mailing list or newsletter, we can use cookies to know if you opened your e-mail and if so, from what device. If you click on an offer that we sent you by e-mail, you will be redirected to the applicable Web Site for the relevant product or service, and we will know that you visited our applicable Web Site through this communication. This will help us understand which promotions work better than others for you, and will enable us to send you more personalized offers.

WHAT TYPE OF COOKIES DO WE USE?

When you browse our Web Sites, different types of cookies are set on your device’s storage space. Cookies can be installed by us or can be installed by third parties.
  1. First Party Cookies – First party cookies are those that are issued by our Web Site domains, and they can only be set or retrieved by us. They are used for purposes specific to us, such as to personalize our Web Sites.
  2. Third Party Cookies – Third party cookies are usually placed on a web site via scripts or tags added to a web page. Sometimes, these scripts will also bring additional functionality to our Web Sites.
We use different categories of cookies, including:
  1. Strictly Necessary – These cookies are essential to enable you to navigate our Web Sites and use the features of our Web Sites.
  2. Performance Cookies – Performance cookies collect information about how visitors use a web site, such as the pages that visitors go most often, and whether they get an error messages from our web pages. Most performance cookies are persistent. For example, on many of our Web Sites, we use a cookie called _ga, which allows Google Analytics to generate aggregated statistical data on how a visitor uses our Web Site. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page at https://support.google.com/analytics/answer/6004245?hl=en. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics at https://tools.google.com/dlpage/gaoptout.
  3. Functionality Cookies – These cookies are used to allow specific functionalities that are useful to you.
  4. Third Party and Personalization Cookies – These cookies are used to deliver advertising that is relevant to you and your interests. For example, these cookies can remember that you visited a web site and share this information with third parties for ad personalization purposes.

HOW LONG DO COOKIES STAY INSTALLED ON A DEVICE?

We use both session cookies and persistent cookies as described below:

  1. Session cookies – Those are files set temporarily on your device and deleted once you close your browser. They are not stored nor transmitted to third parties. We use this type of cookie to ensure you have a user-friendly experience. As an example, we may use a cookie to store a session ID, which allows us to preserve users’ states across page requests. Most of our cookies are session cookies.
  2. Persistent cookies – Those remain active on your device for some time, which may vary from a few days to two years after your visit on our applicable Web Site. As an example, we may use a cookie to save your language preference on our applicable Web Site.

CAN THIRD PARTIES HAVE ACCESS TO COOKIES?

We use Google Analytics Demographics and Interest Reporting to conduct some analytics on performance of our Web Sites. However, we cannot and do not use these cookies or the information tracked by these cookies to track you individually. This service gives us an idea of the overall traffic on our different pages, to help us optimize the Web Sites for visitors.

Dealer Media may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google and Facebook) to display unique offers on third party websites and social media sites visited by users of the Dealer Media Web Site. You may always opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page.

Advertising vendors (such as Google and Facebook) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses Dealer Media website – to display ads based on the computer’s past access to Dealer Media Web Sites.

HOW CAN I MANAGE COOKIE PREFERENCES?

You may click on “Cookies” or, if applicable, “Do Not Share My Personal Information” in our Web Site footer to manage your cookie preferences.

Browsers and devices have tools that allow you to control cookies; you can block them, ensure that you are notified when you are subject to cookies and control the cookies already stored on your device. Adjustments to your cookie preferences can be made in your browser settings. However, if you block all the cookies used by one or more of our Web Sites, you may not be able to access all functionalities of the applicable Web Site. We do not honor “Do Not Track” signals.

If you want to opt-out from Google Analytics Demographics and Interest Reporting, you can do so by installing the Google Analytics Opt-out Browser Add-on made available by Google.

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