CCPA - Freedom Auto Financing

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Last Updated: December 31st 2022

California Privacy Statement (California Residents Only)

This Privacy Statement for California Residents (“Privacy Statement”) supplements the information contained in the Privacy Policy (the “Privacy Policy”) made available on the website located at 60secautoloan.com (the “Site”). The Site is owned and operated by Freedom Auto Financing LLC (“Company,” “we,” “us” or “our”). This Privacy Statement applies solely to residents of the State of California (“CA Users”). We adopt this Privacy Statement in compliance with the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2021) (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Statement. CA Users with disabilities who wish to access this California Privacy Statement in an alternative format can contact us by: emailing us at: [email protected]; or sending us U.S. Mail to: Freedom Auto Financing LLC 7000 W. Palmetto Park Road Suite 210, Boca Raton Florida 33433

Summary of Your Rights under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2021) (“CCPA”)

  • Right to opt out of the “selling” or “sharing” of certain personal information—including, but not limited to sharing your information for targeted advertising;
  • Right to know the categories of personal information that are being collected;
  • Right to know whether your personal information has been sold—including the categories and specific pieces of personal information we have collected;
  • Right to request additional information about our collection, use, disclosure, or sale of such personal information;
  • Right request the correction of inaccurate personal information;
  • Right to request that we delete your personal information (subject to exemptions);
  • Right to designate an Authorized Agent to exercise your privacy rights;
  • Right to access and receive your personal information in portable format that allows you to transfer it to another business without hindrance;
  • Right to not be discriminated against for exercising your privacy rights;
  • Right to receive notice of our privacy practices at or before collection of personal information;
  • Right to opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable
  • Right to Limit the Use and Disclosure of Sensitive Personal Information;

Categories of 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 and sensitive 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. YES
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. NO
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. NO
L. Sensitive Personal information Social Security, driver’s license, state identification card, or passport number; Account log-in financial account, debit card, or credit card in combination with security access code or password; Precise geo location (within 1850 feet); racial ethic origin, religious or philosophical beliefs, or union membership; contents of your mail, email, and text messages unless you intend for us to be the recipient; your genetic data. 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.

Sensitive Personal Information

We collect your social security number when you input it in our webform and submit it to us. We only use your social security number to assist in connecting you with a car dealer and/or
lender as requested by you. We do not use your sensitive information (social security number) for any additional purpose outside of the disclosed purpose.

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 F: Internet or other similar network activity
  • Category I: Professional or employment-related information.
  • Category L: Sensitive Personal 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 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 shared/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 F: Internet or other similar network activity
  • Category I: Professional or employment-related information.
  • Category L: Sensitive Personal Information

We share/sell consumers’ personal information to the following categories of third parties:

  • Third parties to whom you or your agents authorize us to disclose your personal information to in connection with products or services you request on our site.

Retention

We will keep your personal information for as long as necessary to fulfill the purposes described above, unless a longer retention is required or permitted by law. We may delete or de-identify your information sooner if we receive a verifiable deletion request that complies with law, subject to exemptions under applicable law.

The retention period that applies to your information may vary depending on the services you use and how you interact with them. We may retain cached or archived copies of your information. As it pertains to Sensitive Personal Information, any Sensitive Personal Information we collect is immediately encrypted and always deleted within 24 hours.

Your Rights

Deletion Requests Rights

You have the right to request that we delete any personal information that we have collected about you.

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

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.

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

Right to limit selling and/or sharing of your personal information

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  https://60secautoloan.com/dnsmpi page to opt-out of having your personal information sold.

California Residents also have the right, at any time, to opt-out of the “sharing” of their personal information.

The CCPA defines “sharing” as renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross- context behavioral advertising. Moreover, under the CCPA’s definition of sharing, a consumer that uses or directs the business to intentionally disclose personal information or intentionally interact with one or more third parties is exempt from the CCPA’s definition of “sharing”.

While we are not aware of any activity on our website that would fall under the CCPA’s definition (above) of “sharing”—in an abundance of caution, we are still electing to offer our users the ability to limit any activity on our site that could potentially fall under the CCPA’s definition of “sharing”. Click Here to limit any potential “sharing”.

Non-Discrimination Rights

We will 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.

Exercising Access, Data Portability, Opt-out of Selling, Correction and/or 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 any of 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:

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.

We will allow you up to two verified requests, free of charge, in a 12 month period (subject to any applicable exemptions).

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.