CCPA - Freedom Auto Financing

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California Privacy Statement (California Residents Only)

In accordance with AB 375 (California Consumer Protection Act of 2018), you have the right to:

  • Know what personal information is being collected;
  • Know whether your personal information has been sold and to whom— including the categories and specific pieces of personal information the business has collected;
  • Say no to the sale of your personal information (1798.120(a);
  • Access your personal information;
  • Receive equal service and price even if you exercise your privacy rights.

Your Rights

Deletion Requests Rights

Pursuant to 1798.105(a) you have the right to request that we delete any personal
information that we have collected about you.

Pursuant to [1798.105 (d)(1)-(9)] we may deny your deletion request if retaining
the information is necessary for us, or our service providers to:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Access to Specific Information and Data Portability Rights

Pursuant to 1798.110(a)(1)-(5) you have the right to request that a business that collects personal information about you disclose to you the following:

  1. The categories of personal information it has collected about you.
  2. The categories of sources from which the personal information is collected.
  3. The business or commercial purpose for collecting or selling personal information.
  4. The categories of third parties with whom your personal information is shared.
  5. The specific pieces of personal information that have been collected about you.

Pursuant to 1798.115(a)(1)-(3) you have the right to request that a business that
sells your personal information, or that discloses it for a business purpose, disclose
to you the following:

  1. The categories of personal information that the business collected about you.
  2. The categories of personal information that the business sold about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom your personal information was sold.
  3. The categories of personal information that the we disclosed about you for a business purpose

Pursuant to 1798.120 California residents also have the right, at any time, to direct a business that sells personal information about the consumer, to third parties, not to sell the consumer’s personal information. This right is referred to as the right to opt out. Please go to our “Do not sell my personal information” page to opt-out of having your personal information sold.

Non-Discrimination Rights

Pursuant to 1798.125(a)(1)(A)-(D) a business shall not discriminate against you because you exercised any of your rights under this title, including, but not limited to, by:

  1. Denying you of goods or services.
  2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  3. Providing a different level or quality of goods or services to you, if you exercise your rights under this title.
  4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Information We Collect

We 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:

Category Examples 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, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. 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. NO
F. Internet or other 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. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act) 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 other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal information does not include:

  • 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 and indirectly from activity on our website(s). For example, from consumers submitting forms on our websites or website usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, and/or SMS messages that may interest you—providing that you opted in to receive those messages while using our website(s).
  • To improve our website and present its contents to you.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
  • 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.

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.

Disclosing/Sharing Personal Information

We may share and/or sell information that we collect about you in many ways and for numerous different purposes—for which we may be compensated—including the following.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • With our vendors that assist us with delivery of email and/or SMS messaging
  • With one or more vendors who provide independent verification of consent, including verification of consent under TCPA;
  • 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;
  • Third party vendors that assist us in storing and/or processing of your data;
  • Third party vendors that assist us in identifying site issues, observing user behavior, and tracking page performance.

In the preceding twelve (12) months, we have sold the following categories of consumers’ personal information:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.

We have sold consumers’ personal information for a business purpose to the following categories of third parties:

  • Our affiliates and/or other;
  • 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.

Exercising Access, Data Portability, and Deletion Rights

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the
ways in which we collect and use your personal information, your choices and rights
regarding such use, or wish to exercise your rights under California law, please do
not hesitate to contact us. Only you or a person registered with the California
Secretary of State that you authorize to act on your behalf, may make a verifiable
consumer request related to your personal information. You may also make a
verifiable consumer request on behalf of your minor child. You can submit a verified
request by either:

Response Timing and Format

After receiving a verified request we will deliver the information to you within 45
days. In certain instances where it is reasonably necessary, it could take up to 90
days. In those instances you will be notified within the first 45 days of our intent to
use the 45-day extension as set forth in 1798.130(a)(2)

You may only make a verifiable consumer request for access or data portability
twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the
personal information relates to you. Making a verifiable consumer request does not
require you to create an account with us. We will only use personal information
provided in a verifiable consumer request to verify the requestor’s identity or
authority to make the request.