Privacy Policy

Effective Date: February 1, 2024


Jurisdiction-Specific Notices: If you are a California or Virginia resident, see the Jurisdiction Specific Privacy Rights Statement section below for important information about your rights under California or Virginia law and to see the categories of information we collect and the purposes for which the information is used, or to exercise your rights under the laws applicable in these states.  If you are located in the European Economic Area, UK, or Switzerland, please also see the Supplemental European Privacy Statement below. To learn more about our online chat functionality and how we may collect your personal information through that feature, see the Chat Feature.


Protecting your privacy is fundamental to the way CarNow, Inc. and subsidiaries and affiliated entities under common ownership and control, (“Company”, “we”, “us”, or “our”) conduct business and provide our services. This Privacy Policy describes our collection, use and disclosure of the information we may collect from you whenever you visit any of our digital properties, website(s) (hereinafter a “Site” and collectively the “Sites”), or otherwise interact with us or access any of our other products, services, and content (hereinafter “Services”). This Privacy Policy applies to all visitors and customers of our Sites. If you become an inactive customer, or if we close or suspend your account, we will continue to adhere to the Privacy Policy in place when we collect your personal information as long as we retain it in our databases. We may delete any or all of your information at any time without notice to you or for any reason or no reason unless we are otherwise required by law or retain it. You may have other privacy protections under state laws and we encourage you to refer to the Jurisdiction Specific Privacy Rights Statement to review these. Unless otherwise specifically noted, this Policy does not apply to your use of third-party sites linked to the Sites.

1. Updates and Supplemental Notices to this Privacy Policy

We may provide additional or supplemental privacy notices for specific products or services that we offer at the time of collection. Unless otherwise noted, those supplemental notices should be read together with this Privacy Policy.

This Privacy Policy may change from time to time. The “Effective Date” legend at the top of this page indicates when this Privacy Policy was last revised. Any chances will become effective when we post the revised Privacy Policy and your continued access to the Sites and Services is deemed to be your acceptance of those changes, so we encourage you to check back periodically for updates.

Sections

This Privacy Policy is comprised of the following sections and you can jump to particular topics by going to the headings below:

2. Personal Information We Collect and Purpose of Collection

We collect personal information when you access and interact with our Sites and Services or provide information by contacting us via our Sites or Services, through a website chat feature, or when you make a comment or request in relation to our products and services. In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. This information may be provided by you voluntarily or automatically as part of your interaction with our Sites and Services. Detailed information about the personal information we collect, and why we collect it is provided in the chart below:

Context of Collection Types of Data Legal Bases for Collection and Use of Data

Identifiers

We may collect your real name, login or screen name, postal address, IP address, email address, SSN, driver’s license number, passport number, cookies, pixel tags, and similar identifiers. When we collect SSN, driver’s license numbers, passports numbers, we are collecting sensitive personal information.

We have a legitimate interest in monitoring our networks and visitors to our websites and a contractual basis for fulfilling your request for services.

Contents of Communications

We collect personal information such as a consumer’s mail, email, and text messages.

We have a legitimate interest in monitoring our networks and visitors to our websites and a contractual basis for fulfilling your request for services.

Audio/Video/Visual/Electronic

We may collect photographs, videos, recorded calls, voicemails, and online & electronic communications, such as those made via a live or automated online chat module.

We have a legitimate interest in monitoring our networks and visitors to our websites and a contractual basis for fulfilling your request for services.

Commercial

We may collect information about your vehicle(s), products and services obtained or considered; personal property records (e.g., vehicle titles and registration cards); or other purchasing or consuming histories or tendencies.

We have a contractual basis for fulfilling your request for services.

Customer Records

We may collect digital and electronic signatures, telephone numbers, insurance policy numbers, credit and debit card numbers, financial and credit-related information, physical characteristics and descriptions (e.g., government identification), bank account numbers and information.

We have a contractual basis for fulfilling your request for services.

Online Account or Credit Card Info Combined with a Security/Access Code 

We may collect, directly or through a third party processor, such as account login information, credit or debit card numbers, or financial account information that is combined with a security or access code. This information, if collected is considered sensitive personal information.

We have a contractual basis for fulfilling your request for services.

Internet Activity

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. These technologies track interactions with our websites, applications, and advertisements.

We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.

Professional/Employment

We may collect information about your job and profession such as job title, employer, occupation, company or business name.

We have a contractual basis for fulfilling your request for services.

Protected Classes

We may collect information that is protected under state or federal law, such as gender, age, and veteran status.

We have a contractual basis for fulfilling your request for services.

Inferences

We may collect inferences about your preferences, characteristics, behavior and attitudes.

We have a legitimate interest in monitoring our networks and visitors to our Sites.

Log and Usage Data

We collect log and usage data for service related purposes such as diagnostic, usage, and performance information collected by our servers when you access or use our Site(s) or Services. We record this information in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about activity on the Site and in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you access), device event information (such as system activity, error reports, and hardware settings).

We have a legitimate interest in monitoring our networks and visitors to our websites.

Device Data

We collect device data such as information about your computer, phone, tablet, or other device you use to access the Site(s) or Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet Service provider and/or mobile provider, operating system, and system configuration information.

We have a legitimate interest in monitoring our networks and visitors to our websites.

Location Data

We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Site(s) or Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling you location setting on your device but doing this may inhibit your access to certain aspects of the Services.

We have a legitimate interest in monitoring our networks and visitors to our websites.

3. Why We Collect Personal Information

We may collect the categories of personal information listed below. We use this information for one or more of the following “business purposes”:

  • Customer Service and Support – to provide customer service and support, maintain, and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
  • Respond to Inquiries – to respond to your inquiries and provide you with requested services or resolve any issues you may have with our Services.
  • Administration of Our Services – to send you details about our Sites and Services, update you about changes to our terms and policies, and other similar information.
  • Advertising & Marketing – to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
  • Counting Ad Impressions & Website Interactions – to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities to determine how to provide marketing and promotional campaigns that are most relevant to our customers.
  • Identify Usage Trends – to better understand how our Site and Services are being used so we can improve them.
  • Request Feedback – to contact you and get your feedback about your use of the Site and the Services.
  • User-to-User Communication – if you choose, to allow for communications with another use of our Site or Services.
  • Fraud Prevention – to help ensure security and integrity, such as necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.
  • Processing Transactions – to process or fulfill orders and transactions, verify customer information, process payments.
  • Providing Financing Options – to connect you with a company that will provide financing in connection with a vehicle purchase, lease, or related products or services.
  • Protect Individual Interests – to save or protect an individual’s vital interest, such as to prevent harm.
  • Compliance with Legal Obligations – To comply with our legal and contractual obligations and to protect our legal interests, such as in the event of a complaint or dispute.

4. Disclosure of Personal Information

We do not sell, exchange, transfer, or give your personal information to any other company or individual for any reason except as set forth in this Privacy Policy and as described below.

In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information we collect from you:

  • if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others;
  • to our authorized service providers such as our contractors and other third parties we use to support our business and fulfill the purposes set forth above (including, in some cases chat functionality providers);
  • to fulfill the purpose for which you provide it;
  • to other Company-owned business entities for the purposes of coordinating our provision and development of products and services;
  • and a buyer or other successor in the event of a sale, merger, reorganization or transfer of some or all of our business or assets;
  • to our business and marketing partners, such as third parties with whom we may co-sponsor events or promotions or with whom we jointly offer products and services, or whose products and services may be of interest to you;
  • for any other purpose disclosed by us when you provide the information;
  • to comply with applicable law including in connection with any court order, law enforcement investigation, legal process, including responding to any government or regulatory request;
  • to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us, and subject to professional and contractual obligations of confidentiality;
  • 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 courts and public authorities to protect you, Company, or third parties from harm; or
  • with your consent or as required to provide you with Services.

5. Data Security

We have organizational and technical measures and safeguards in place that are designed to secure and protect your personal information. The use of, and access to, your personal information by us is restricted to authorized individuals who need to know that information to provide services to you, and who receive training about the importance of protection personal information. Our service providers and business partners are also contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purposes.

Unfortunately, no method of transmission of information via the internet or electronic storage is completely secure. Although we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

If you believe your information is not secure, please immediately notify us of the problem at the address provided in the “How to Contact Us” section below.

6. Retention of Personal Information

Generally, we will hold your personal information for as long as you remain a Customer of ours or as long as necessary to perform the activities described in this Privacy Policy, unless we have an ongoing legitimate business need that requires a different retention period. We retain the information in order to provide and maintain the quality of the Services you have requested, or if we are obliged to retain such information for legal, regulatory, fraud prevention, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use and/or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When our legitimate business need for retaining your personal information ceases to exist, we will either delete or anonymize your information so that it can no longer be attributed to you.

7. Other Important Information

a. Chat Modules

We may collect certain categories of personal information from you when you use the interactive chat module available on our Site or Services. In addition to the information you may enter into the chat box or live chat feature, the categories of personal information include, but are not limited to, name, phone number, email, mailing address, and other identifiers you may provide. Additionally, we may also store any transcripts from such conversations and link those transcripts with your personal information. We may also collect information from you to perform data analytics and thereby enhance your experience and help improve the functionality of our tools and digital advertising in an effort to present to you only relevant products and services. Such information includes, but is not limited to, geolocation, IP address, pixel tags, browsing history, viewing behavior, clicks, online activity, and other analytics. By interacting with the chat module, you understand and agree that we may use this data to communicate with you about our products and services. You also consent to our collection and analysis of all personal information provided as part of the chat module and understand that we utilize a vendor to process, analyze, and store the content of the chat on our behalf. By using the chat module, you are consenting to us disclosing and sharing with the chat module vendor any personal information you provide.

b. Session Replay Tools.

We may collect certain categories of personal information from you when you interact with our Sites or Services through the use of session replay tools. Session replay is a visual tool that recreates your sessions from our Sites or Services, giving us a better understanding of how you interact with our Sites and Services to help maximize the customer’s experience. Session replay tools that we may utilize include, but are not limited to, video-like playback, error tracking integration, application performance monitoring (APM) integration, real user monitoring (RUM) session timeline, and speed controls. Depending on your interaction with our Sites and Services (e.g. when you complete a “Contact Us” form), the categories of personal information we may also capture include, but are not limited to, name, phone number, email, mailing address, and other identifiers that you may provide. By interacting with our Sites or Services, you are consenting to us capturing any interactions and any personal information you provide.

c. Children’s Information

We do not knowingly contact or collect personal information from children under 16. Our website is not intended to solicit information of any kind from children under 16. It is possible that by fraud or deception we may receive information pertaining to children under 16. If we become aware of this, as soon as we verify the information, we will immediately comply with our legal obligations and delete the information from our servers. If you want to notify us of our receipt of information by children under 16, please do so by emailing us at privacyinfo@__.

d. Conducting Data Analytics

We are an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect.  We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you.

We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that your rights and the legitimacy of our activities are ensured through the use of aggregated or otherwise de-identified data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve our Sites and Services and to promote our business.  We will not attempt to re-identify any such data, except as permitted by law.

e. Cookies and Other Technologies

Company and our partners (e.g., marketing partners, analytics, advertising, or service providers) may use various tracking technologies such as cookies, beacons, tags and scripts to analyze trends on our Sites and Services, administer our Sites and Services, and to gather demographic information about our user base as a whole. We receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Please see our Cookies Policy for more details including, information about your choices with respect to advertising and social media cookies and for access to our cookie consent manager.  We respond to the Global Privacy Control signal for California residents.

We also use chat technologies, such as those provided by CarNow, Inc. and similar technology providers that employ cookies and software code to operate the chat features that you can use to communicate with us through the Sites and Services.  Our online chat provider and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

f. Non-Personal Information. 

This Privacy Policy does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.

g. Accessibility. 

If you have a disability and require an alternative format to this Policy, please email us at: privacy@carnow.com so that we may provide you with a more suitable format.

8. Privacy Rights and Choices

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. Any rights you may have in relation to your personal information are not absolute. We reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that takes into account the administrative costs for providing the information or taking the action requested.

  1. Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
  2. Right to Correct. You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate.
  3. Right to Delete. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal information, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable law.
  4. Right to Portability. You have the right to receive a copy of the personal information we have collected about you in a structured, commonly used and machine-readable format.
  5. Right to Opt-Out of Automated Decision-making or Profiling. You may have the right not to be subject to a decision which significantly impact your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
  6. Right to Appeal. In certain jurisdictions, you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.
  7. Right Against Discrimination. You may have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your rights.
  8. We do not sell your personal information.  We do not sell your personal information for targeted advertising.  We do not process any information that may be considered “sensitive personal information”, under certain laws, to infer characteristics about you.

To make a privacy rights request, please contact us by email at privacy@carnow.com or contact use the webform available at https://www.carnow.com/do-not-sell/. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

In your request, please make clear what information you would like to have changed, whether you would like to have your personal information correct, deleted, or other limitations you would like to put on our use of your personal information. We may only implement requests with respect to personal information that is associated with the particular email address that you use to send your request.

You may use an authorized agent to submit a rights request on your behalf.  If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.

Depending upon the applicable law, access to your rights may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

For individuals located in the European Economic Area, Switzerland or the United Kingdom during data collection, please refer to Section 10 below for more information about your rights.

9. International Data Transfers

We are a global business, with a primary location in the US, but we may store, process and transmit personal information in locations around the world, including locations outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.

10. Contact Information

If you have questions or comments about this Privacy Policy, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at [link to third party DRP].

If you have any general questions or comments for Us, please contact us at:

CarNow, Inc.
1100 Circle 75 Parkway, #800
Atlanta 30339

Or via e-mail at privacy@carnow.com

Exercise your Data Subject rights via this https://www.carnow.com/do-not-sell/

11. Other Jurisdictions

Jurisdiction Specific Privacy Rights Statement

Personal information that you submit through the Website or Services may be transferred to other States or countries other than where you live. The following provisions may apply to you depending on where you are located. If you choose to access services from somewhere other than your home country or state, you are responsible for compliance with local laws.

  • Australia. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Privacy Notice, you may wish to contact the Office of the Australian Information Commissioner.
  • Canada. Personal information maintained and processed by our affiliates and third-party service providers in the U.S. and other foreign jurisdictions may be subject to disclosure pursuant to a lawful access request by U.S. or foreign courts or government authorities. We will not provide your information to third parties for marketing purposes without your prior consent. For more information about our privacy practices; to access, update or correct inaccuracies in your personal information; or if you have a question or complaint about the manner in which we or our service providers treat your personal information, please contact us as set forth in the Contact us section of this Privacy Notice.
  • European Economic Area (EEA) and the United Kingdom (UK). If you are located in the EEA, the UK we comply with applicable laws to provide an adequate level of data protection for the transfer of your personal data to the US.
  • Transfers outside the EEA and UK. Where applicable law requires that a data transfer have legal mechanism, we use one or more of the following: Standard Contractual Clauses with a data recipient outside the EEA or the UK (or additionally, in the case of the UK, the International Data Transfer Agreement (IDTA) or Addendum to the Standard Contractual Clauses issued by the ICO), verification that the recipient has implemented Binding Corporate Rules, or other legal method available to us under applicable law. 
    Complaints. If you are a resident of the EEA, and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. To exercise your privacy rights set forth in this Privacy Notice, you may contact us as set forth in the Contact us section.

United States Privacy Laws

This Section describes our additional information practices related to your Personal Information under applicable state laws. This Section DOES NOT cover information that is exempted, including information that is protected by the Gramm-Leach-Bliley Act (GLBA) and the Health Insurance Portability and Accountability Act (HIPAA).

  • Connecticut (Effective July 1, 2023). Under the Connecticut Data Protection Act (“CTDPA”), if applicable to us, Connecticut residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CTDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a Connecticut resident, and we collect Personal Data subject to applicable Connecticut law, in addition to those rights outlined in Your Choices section above, you also have the following rights:
    • Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of the CTDPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. We do not “sell” Personal Information under this definition. Connecticut residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
    • Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.
  • Colorado (Effective July 1, 2023). Under the Colorado Privacy Act (“CPA”), if applicable to us, provides some Colorado residents with the right to receive certain disclosures regarding a business’ processing of “Personal Data” as defined under CPA. To the extent you are a Colorado resident, and we collect Personal Data subject to applicable Colorado law, in addition to those rights outlined in Your Choices section above, you also have the following rights:
    • Right to Know: You can request the following information about how we have collected and used your Personal Data and to see what Personal Data we have collected about you in a portable format.
    • Right to Correct: You can ask us to correct inaccurate personal information that we have collected about you.
    • Right to Delete: You can ask us to delete the personal information that we have collected from you.
    • Right to Opt-Out of Targeted Ads and Significant Profiling: You may have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
  • Nevada. This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing customers, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at privacy@carnow.com or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov.
  • Texas. If you have a complaint, first contact us by visiting our Website at privacy@carnow.com.
  • Utah (Effective December 31, 2023). Under the Utah Consumer Privacy Act (“UCPA”), Utah residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under UCPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Utah, and we collect Personal Data subject to applicable Utah law, in addition to those rights outlined in Your Choices section above, you also have the following rights:
    • Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of UCPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation. We do not “sell” Personal Information under this definition. Utah residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
  • Vermont. In accordance with Vermont law, we will not share information we collect about you with companies outside of our group companies, except as required or permitted by law. For example, we may share information to service your accounts, complete requested transactions, or to provide rewards or benefits to which you are entitled.
  • Virginia (Effective January 1, 2023). Under the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the VCDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Virginia and we collect Personal Data subject to applicable Virginia law, in addition to those rights outlined in Your Choices section above, you also have the following rights:
    • Right to Opt-Out of Sale: Under the VCDPA, a “sale” includes disclosing or making available Personal Information to a third party in exchange for money. We do not “sell” Personal Information under this definition.
    • Right to Opt-Out of Targeted Ads and Significant Profiling: You may have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
    • Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.

Effective Date: January 17, 2024
Last Update: January 17, 2024

Supplemental European Privacy Rights Statement

If you are a resident of the European Economic Area, we rely on our legitimate interest as described in this Privacy Policy to process your personal information. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below.

  • Right of Access. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
  • Right to Rectification. If your personal information is inaccurate or incomplete, you may be entitled to ask that we correct or complete it.
  • Right to Erasure. You may ask us to erase your personal information in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and where there is no other legal basis for processing.
  • Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as if you contest its accuracy or object to us processing it.
  • Right to Data Portability. You may have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
  • Right to Object. You may ask us at any time to stop processing your personal information, and we will do so: (a) if we are relying on a legitimate interest to process your personal information, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your personal information for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
  • Right to Withdraw Consent. If we rely on your consent to process your personal information, you may have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
  • Right to lodge a Complaint. If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns.