CarNow Privacy Policy

This website and any related mobile applications (collectively, the “Site” or “Websites”) is operated by CarNow, Inc., a Delaware corporation (“CarNow “). This Privacy Policy (the “Policy”) describes CarNow’s collection, use and disclosure of information practices in connection with the Site. This Policy also describes CarNow’s collection, use, and disclosure practices with respect to any personally identifiable information and Usage Data (as defined below) that is provided to CarNow by any of its third-party distribution partners that display CarNow vehicle listings.

This Policy does not describe CarNow’s collection, use and disclosure of personal information through means other than this Site (e.g., off-line) or the collection, use and disclosure practices of any third parties. For information on a third party’s information collection, use and disclosure practices, please review the privacy policy on the applicable third party’s website. Also, please note that this Site contains links to other websites. CarNow is not responsible for the websites, content or privacy practices of any third party. CarNow will treat all personally identifiable information and usage data gathered via the Site as set forth in this Policy.

Collection of Personally Identifiable Information

You are not required to provide any personally identifiable information to visit the Site and are not required to provide any personally identifiable information if the information collected is not related to the primary purpose for which the information was collected or the personally identified information was disclosed to third parties.

“Personally identifiable information” or “personal information” is information that we can use to identify you as an individual. Personally identifiable information includes your name, address, email address, telephone number, IP address, and any other information that is connected with you personally. CarNow automatically collects Usage Data (as described below) and may collect ZIP codes and other personal information in connection with your use of the Site (e.g., the type of car you are looking for). CarNow collects personally identifiable information only when you use the Site or make it available through your use of the Site. You may be required to provide personally identifiable information to use certain services on this Site. In addition, you may submit personally identifiable information through the Site in other ways, including: (a) participating in online surveys, promotions, contests and sweepstakes; (b) subscribing to newsletters, editorial content, or promotional content sent via email, (c) using “Feedback” and “More Information” forms; and (d) in connection with other products, services, features, or requests made available through the Site. We may also publish toll-free phone numbers for many of the dealerships that list vehicles for sale on the Site. If you dial one of these phone numbers, CarNow or a service provider operating on CarNow’s behalf may record the date, time and length of your call and the phone number from which the call originated, along with other information that may be captured. Any Usage Data (as defined in the next section) and/or personally identifiable information resulting from such calls may be used as described in this Policy. The types of personally identifiable information that you provide will depend on the nature of the submission, but could include your name, address, phone number, email address and credit card information. Your choice about personally identifiable information being disclosed to third parties will be honored. You will also have the right and means to change your choice as described in the Section entitled “Accessing, Changing or Deactivating Information Collected by CarNow.”. CarNow may use third party personally identifiable information to send a one-time email message to the person to whom the information concerns to solicit their consent to using their personally identifiable information. All newsletters and promotional email messages that CarNow sends to users, apart from the messages the user has agreed to receive as a condition of using the CarNow service, will include an unsubscribe link and as described in the Section entitled “Accessing, Changing or Deactivating Information Collected by CarNow.”.

Passive Information Collection

The Site automatically collects information and may also customize your visit through technical means, including the following:

Cookies: Cookies are small text files that are placed on your computer’s hard drive by computers (or servers) to identify your computer.

Web Beacons: Web beacons (also known as pixel tags, internet tags, clear GIFs, or single-pixel GIFs) are electronic images embedded into a webpage.

IP Address Logs: CarNow also logs Internet Protocol (IP) addresses – the location of your computer on the internet.

Cookies allow CarNow to recognize you when you visit the Site, to personalize your experience and generally to serve you better. For example, if you enter your name, address or ZIP code on one of the Site’s forms, it may be stored in a cookie so you do not have to enter it again on other forms on the Site. Cookies and web beacons can tell us what advertising you have seen on the Site, which allows CarNow to offer you a more diverse selection of advertising information and may also be used together to measure the effectiveness of CarNow advertising campaigns. Cookies, web beacons and IP addresses are also used to compile data regarding Site usage (e.g., what website you came from, what pages of the Site you visit, how long you were on the Site, what type of browser you are using, what website you went to). Web beacons may also be included in emails sent by CarNow to determine when and if such emails are opened or forwarded. You can disable cookies or otherwise manage them through tools provided with your browser software and with third-party software packages. If you turn off cookies, many of the Site’s features will not work as well or at all. Anonymous information regarding use of our Site and services that is collected and/or aggregated by or on behalf of CarNow through the use of such technical means or otherwise is referred to in this Policy as “Usage Data.”

Information Use

Personally Identifiable Information. Personally identifiable information collected by CarNow through your use of the Site may be stored on servers or in a cookie on your computer and may be used by CarNow for any of the following purposes:

  1. To confirm or fulfill a request that you make (e.g., in order to send you specific information you have requested, CarNow may share your contact information with a participating CarNow dealer and/or manufacturer).
  1. To follow up on any request that you have previously made (e.g., CarNow may contact you to determine whether the dealer and/or manufacturer responded to your original request).
  1. To communicate with you regarding the CarNow service (e.g., CarNow may send you emails or call you about new features or to request that you participate in a survey).
  1. To send promotional materials, newsletters or other content via email or otherwise. If you no longer wish to receive a particular email newsletter or other promotion from CarNow, you must follow the opt-out instructions included in such email newsletters and promotions.
  1. To permit third parties (to whom CarNow may disclose personally identifiable information specifically for direct marketing purposes) to send you promotional or informational messages, but only if you have first affirmatively agreed to receive such messages.
  1. To improve your user experience.
  1. To manage CarNow’s business and its relationships with Affiliates, customers, and other third parties to which CarNow may disclose personally identifiable information pursuant to this Policy.
  1. For Site administration, analysis, research, development, optimization and other internal purposes, including, without limitation, to compile Usage Data.

Usage Data: Usage Data is used by CarNow for administrative, analytical, research, optimization and other purposes. For example, CarNow may use statistical analyses of Usage Data in order to measure interest in the various areas of the Site, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.

With respect to promotional materials and newsletters that CarNow may send from time to time, CarNow will not continue to send you such communications if you ask us not to, as described below in the Section entitled “Accessing, Changing or Deactivating Information Collected by CarNow.” However, you agree that CarNow may send to you, and you cannot opt out of, communications of a transactional or relationship nature, including, but not limited to, communications regarding fraudulent or illegal activity, the status of your Account, and changes to this Policy or the CarNow Terms of Service.

Sharing of Your Personal Information

We Never Sell Personal Information. We will never sell, rent or otherwise provide your Personal Information to any third party for marketing purposes.

Sharing Information with Third Parties. We only share your Personal Information with third parties as described in this Privacy Policy, to carry out your instructions, as may be compelled by law, or as necessary to protect our rights or property. For example, we may share data with trusted partners to help us process information, extend credit, fulfill orders for our products and services, sell or deliver products and services to you, provide customer service, assess your interest in products and services, conduct customer research or satisfaction surveys, or help us perform statistical analysis. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. We also employ other companies and people to provide services to visitors to our Websites on our behalf and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies. We may be liable if third parties fail to meet Privacy Shield obligations unless we prove we are not responsible for the event giving rise to the damage.

Compliance with Legal Process. We may be required to disclose your Personal Information and/or information with respect to your use of our Websites, products and services if required by governmental or regulatory agency or by court order, subpoena or other legal process or requirement or if we reasonably believe that such disclosure is necessary (i) to investigate, prevent or take action with respect to suspected or actual illegal activities or to assist government enforcement agencies, (ii) to protect the safety of any person from death or serious bodily injury, (iii) to prevent fraud or abuse of our Websites, products and services or infringement of our intellectual property rights in our Websites, products and services, (iv) to enforce our terms of use or your agreements with us, or (v) to investigate and defend ourselves against any third party claims or allegations.

Business Transfers. We may sell, transfer or otherwise share your information to a third party in connection with a merger, acquisition, reorganization or sale of assets of us or in the event of bankruptcy of us and you agree that any such third party will have the right to continue to use your Personal Information and other information that you provide to us or which we obtain through your use of the service.

Aggregated or Anonymized Data. We may also share aggregated or anonymized information that does not directly identify you with the third parties described above.

With Your Consent. We will share your personal information with third parties when we have your consent to do so.

In addition, CarNow may share personally identifiable information that you provide with third parties in the following cases:

  1. Affiliates. CarNow may share your personally identifiable information with Affiliates on the condition that the Affiliates’ disclosure and use of the information is consistent with this Policy.
  1. Requests. If you request information or services through the Site, you agree that CarNow may share personally identifiable information with third parties as may be necessary to provide such information to or perform such services for you. For example, if you use the Site’s form to request a price quote from a dealership, CarNow will share the information you entered with that dealership (or its designee). If that vehicle listing was provided by an automobile manufacturer on behalf of a dealer, CarNow may also share the personally identifiable information you submit as part of the request with the automobile manufacturer and/or its affiliates. Similarly, if through the Site you request additional information from a financial institution, CarNow will share your information with that institution. Personally identifiable information also may be included in reports to these third parties, but only when you have intended to submit the information to the third party as described above. After the information is provided to such third parties, the subsequent use or disclosure of such information is subject to those third parties’ privacy policies and practices and CarNow does not control their subsequent use or disclosure of information.
  1. Sweepstakes/Promotions. In the event that you participate in a sweepstakes, contest or other promotion on the Site that is sponsored by CarNow and a third party, CarNow reserves the right to share personally identifiable information collected in conjunction with the sweepstakes, contest or promotion with the third party. After the information is provided to such third parties, the subsequent use or disclosure of such information is subject to those third parties’ privacy policies and practices.
  1. Direct Marketing. Except as provided herein, it is CarNow’s policy not to disclose personally identifiable information of our customers to third parties specifically for the third parties’ direct marketing purposes. If you are 18 years of age or older and have affirmatively agreed to receive third-party direct marketing materials, CarNow may share personally identifiable information with third parties for direct marketing purposes. Although CarNow will notify all third-party direct marketers that the information provided to them is confidential, the subsequent use or disclosure of such information is subject to those third parties’ privacy policies and practices.
  1. Service Providers. CarNow may work with third parties that provide services on its behalf, including, among others, providers of analytical, development, promotional, research, credit card processing, technical and other services. For example, CarNow may ask that a third party conduct an online survey or sweepstakes or send newsletters on its behalf. Similarly, if you make a payment to CarNow by credit card, CarNow may share your personally identifiable information and credit card information with a third party in order to process credit card transactions, or such information may be collected directly by the credit card processing service provider on CarNow’s behalf. In such cases, CarNow asks that the third party maintain your personally identifiable information as confidential and use the information only to perform the services specified by CarNow.
  1. Email List Opt-Outs. In the event CarNow sends promotional emails to you on behalf of third-party advertisers and you inform CarNow you wish to opt out of future promotional emails from a particular third party, CarNow may share your email address with that third party so the third party may add you to its opt-out lists.
  1. Other. CarNow expressly reserves the right to release any personally identifiable information or other information you provide to third parties under the following circumstances: (a) when required by law or legal processincluding to judicial or other government agencies subject to warrants, subpoenas or other governmental orders, (b) to investigate and/or take action against illegal activity, suspected abuse or unauthorized use of the Site, (c) to protect the property or safety of our users or others, (d) to enforce our Terms of Service and (e) in connection with any sale or other transfer of ownership of all or a part of CarNow. Further, if you make any personally identifiable information publicly available on the Site, CarNow reserves the right to disclose such information to third parties, including, without limitation, insurance companies and CarNow’s Affiliates and third-party distribution partners.

Please note that the messages that CarNow sends to you to confirm, fulfill or follow up on a request may incidentally include promotional material or other content from CarNow or its partners. In the case of these messages, CarNow is not sharing your personally identifiable information with those third parties. CarNow reserves the right to share Usage Data with any third party for any reason.

Message Boards

CarNow also may offer message boards, bulletin boards, chat rooms, comments areas or other forums (“Forums”) on the Site for use by visitors who are 18 years of age or older. Any information you disclose when posting a message in these Forums may become public. You should not include any information in your posting that you do not want other parties to see or use. Moreover, if you post any messages in the Forums that include your email address or phone number you may receive unsolicited emails or calls from third parties.

Accessing Your Information. You may access, review, revise, correct, or delete the Personal Information provided in your registration or account profile by changing your “account settings.” If you update any of your information, we may keep a copy of the information that you originally provided to us in our archives for uses documented in this Privacy Policy.

Email a Page

The Site offers you the ability to share certain pages of the Site to a friend or other third party via email, text message, and social media. If you choose to use the “Share” functionality, your name, email address and any message you are allowed to include will be visible to the recipient of the email. The “Share” functionality is for informational purposes only and may not be used for any unlawful purpose, including any harassment or threats. Information collected by CarNow through the “Share” functionality shall be used in accordance with this Policy.

Changes to this Policy

Any changes to this Policy will be posted on the Site in this location and this Policy will be identified as “Updated”. Your continued use of the Site after such notice constitutes acceptance of such changes. In the event of such changes, you can then choose to do nothing, modify the personally identifiable information in your SIY Account, change your email preferences or deactivate your SIY Account.

Security

Your personally identifiable information is one of our most valuable assets. We take steps, such as encryption, to keep it physically secure in our data centers and it is accessible only to authorized personnel as needed to perform operations governed by this policy. In addition, when CarNow collects credit card information from you, CarNow uses Secure Socket Layer (SSL) encryption, the industry standard for protecting privacy in web transactions. Please keep in mind that despite these measures, CarNow cannot guarantee or warrant 100 percent security of its servers and databases. Moreover, CarNow cannot guarantee that personally identifiable information that you submit through the Site will not be intercepted or otherwise disclosed.

Children

CarNow believes that it is especially important to protect children’s privacy online. CarNow does not knowingly collect or use any personally identifiable information from children under the age of 16 and CarNow does not knowingly provide any personally identifiable information, regardless of its source, to any third party for any purpose whatsoever from visitors younger than 16 years old. No information should be submitted to or posted at CarNow by visitors younger than 16 years old.

Links

This Site contains links to other sites. While CarNow encourages our business partners to adopt privacy policies that build users’ trust and confidence in the internet, CarNow is not responsible for the privacy practices or the content of websites linked to the Site or any third-party products or services offered through the Site.

Compliance with privacy laws and regulations

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). You agree not to use our Websites, products or services in a manner that would violate laws protecting an individual’s privacy rights, health or financial data, including the Health Insurance Portability and Accountability Act of 1996 as amended (HIPAA) and the Gramm-Leach-Bliley Act and its implementing regulations, the Privacy Rule and the Safeguards Rule.

Opting-Out and Unsubscribing

Reviewing, Correcting and Removing Your Personal Information. Please check the following link for your current subscription preferences If you provide us with your Personal Information, you have the following rights with respect to that information:

  • To review the user information that you have supplied to us
  • To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
  • To request that your user information not be used to contact you
  • To request that your user information be removed from any solicitation list that we use
  • To request that your user information be deleted from our records
  • To otherwise opt out of receiving solicitations

To exercise any of these rights, please contact us at privacy@carnow.com or by sending us postal mail to: 1100 Circle 75, Suite 800, Atlanta, GA 30339

We will promptly change, correct, or delete your information.

To Unsubscribe From Our Communications. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, revising your subscription settings online at or by sending us email us at privacy@carnow.com, or by sending us postal mail to: 1100 Circle 75, Suite 800, Atlanta, GA 30339.

How You Can Opt Out of Web Tracking. There are several ways to opt out of web tracking: email us at privacy@carnow.com, or by sending us postal mail to: 1100 Circle 75, Suite 800, Atlanta, GA 30339.

Most browsers allow you to block third-party cookies or prevent cross-domain tracking. This will limit the cookies that can be set by third-party scripts. This will not completely eliminate tracking by some third-party services though as they may use first-party cookies.

Most browsers also allow you ask not to be tracked (it sends the “Do Not Track” request header). If you have enabled this feature, we will not track the pages you visit in a way that enables us to connect them to your personal information. Your page views may still be collected anonymously though. Many of the third-party services we use for collecting anonymous data also respect the Do Not Track setting.

If you have an unresolved privacy concern related to personal data processed or transferred by us pursuant to the Privacy Shield Principles that we have not addressed satisfactorily, please contact (free of charge) our U.S.-based third party dispute resolution provider by clicking here. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Collection of Information by Third Parties

As noted above, Affiliates, third parties who place advertisements on this website, and other service providers may collect and use information about your visits to and use of this website through the use of cookies, web beacons and other similar technologies. For example, we work with companies that collect statistical information regarding Site usage and provide related analytical services. We may work with third-party advertising companies that use cookies and web beacons to serve advertisements when you come to the Site and to generate statistics and metrics related to the delivery of such advertisements. We also may work with third-party advertising networks that use cookies, web beacons and other technologies to collect non-personally identifiable information about your visits to and interactions with this Site and other websites in order to provide targeted advertisements about goods and services of interest to you across their networks of websites (which may or may not include this Site). These third parties also may use this information for determining or predicting the characteristics and preferences of their respective advertising audiences, for measuring the effectiveness of their advertising and for other purposes.

If you would like to obtain more information about the practices of some of these parties, or if you would like to make choices about their use of your information, please click here: http://www.aboutads.info/choices/

Some of the vendors we use that may collect Personal Information on our behalf are as follows:

  1. Grasshopper: We use Grasshopper to manage our inbound phone traffic.  This allows us to monitor the quality of our phone calls and route contacts to the proper group.  Read Grasshopper’s privacy policy here. https://www.logmeininc.com/legal/privacy
  2. ZipRecruiter: We use ZipRecruiter to manage our available job postings and resume database.  This allows our hiring managers to stay better organized when filling job roles.  Read ZipRecruiter’s privacy policy here. https://www.ziprecruiter.com/privacy
  3. MailChimp:  We use MailChimp to manage our email marketing and email messaging to our active users. Read MailChimp’s privacy policy here. https://mailchimp.com/legal/privacy/
  4. LinkedIn: We use LinkedInin conjunction with metadata.io to reach target audiences via LinkedIn Ad’s and their inbox. Read LinkedIn’s privacy policy here. https://www.linkedin.com/legal/preview/privacy-policy
  5. Facebook: We use Facebook in conjunction with metadata.io to reach target audiences via Facebook Ad’s. Read Facebook’s privacy policy here. https://www.facebook.com/policy.php
  6. Zoom: We use Zoom for web conferencing. Web conferencing is used as an umbrella term for various types of online collaborative services including web seminars, webcasts, and peer-level web meetings. Read Zoom’s privacy policy here. https://zoom.us/terms
  7. Zapier: We use Zapier to connect two or more apps to automate repetitive tasks. We do this to move information between apps automatically. Read Zapier’s privacy policy here. https://zapier.com/privacy/
  8. BaseCRM: We use BaseCRM to manage all the customer interactions through different media including; phone calls, email, communities, as well as social media. BaseCRM is our primary method to support our sales process. Read BaseCRM’s privacy policy here. https://getbase.com/privacy/
  9. Vimeo: We use Vimeo to creating, managing, and share videos embedded in our website. Vimeo provides detailed analytics on content viewed. Read Vimeo’s privacy policy here. https://vimeo.com/privacy
  10. YouTube: We use YouTube as a host to reach more people with our video content. Read YouTube’s privacy policy here. https://www.youtube.com/static?template=privacy_guidelines
  11. Google AdWord: We use Google AdWords to launch retargeting campaigns. Code is added to our footer to recognize an individual on any page of our website. By associating the visitor we can offer them an appropriate ad they might be interested in. Read Google AdWord’s privacy policy here. https://policies.google.com/technologies/ads
  12. Google Tag Manager: We use Google Tag Manager to manage and deploy marketing tags (snippets of code or tracking pixels) on ourwebsite. Read Google Tag Manager’s privacy policy here. https://www.google.com/analytics/tag-manager/use-policy/
  13. Google Analytics: We use Google Analytics to review data on websitevistis including; geographical, browser information, platform information, page information, visit duration, referring site, time of visits, click throughs. The data is used to improve our site and give our visitors what they like. Read the Google Analytics privacy policy here. https://policies.google.com/privacy?hl=en
  14. Twitter: We use Twitter on our websites to enable the Twitter audience to share our content, and follow our Twitter accounts. Read Twitter’s privacy policy here.

More information and additional consumer choice options may be found here:

http://www.networkadvertising.org/managing/opt_out.asp

Self-Regulatory Principles for Online Behavioral Advertising

CarNow adheres to the Self-Regulatory Principles for Online Behavioral Advertising. For more information please visit http://www.aboutads.info.

Privacy Shield

CarNow, Inc. complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  CarNow, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, CarNow, Inc. commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CarNow, Inc. at:

By Email: privacy@carnow.com

By Mail: ATTN: Chief Privacy Officer
CarNow, Inc.
2802 Paces Ferry Road SE
Suite 200
Atlanta, GA 30339

CarNow, Inc. has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

Contact Us

If you have any questions about this Privacy Policy, please email us at legal@carnow.com or use our online feedback form.

If you would like to contact PrivacyTrust regarding this Privacy Policy, please email PrivacyTrust via their online contact form at https://www.privacytrust.com/about/contact.php.

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Last Updated: May 30, 2018