Last Updated: January 12, 2019
1. Scope and Your Consent
– Information collected from those who use our Services(“you” or “your”); and
– Information that our Business Partners (defined below) share with CarStar or that we share with our Business Partners.
2. Information Collected or Received
When you use the Services, CarStar may collect “Non-Personal Information” and “Personally Identifiable Information” (defined below) (collectively, “Information”) about you, your use of the Services, or the device you use to access the Services.
a. Non-Personal Information
“Non-Personal Information” is any information that does not enable identification of an individual, such as, without limitation, technical information, behavioral information, and aggregated information, including service usage information, web traffic information, content viewed on the Services, your preferences, and information about your operating system, browser, device, keyboard language and hardware.
b. Personally Identifiable Information
“Personally Identifiable Information” (or “PII”) is information that identifies you. Examples of PII that may be collected through the Services include, without limitation:
– Email address
– Mailing address
– Telephone number(s)
– Login information
– Social networking handle or username
– Photos (eg., for profiles)
– Date of birth
– Social security number
– Driver’s license state and number
– Financial information
– Employment information
– Residency or credit proof information (e.g., utility bill, references)
– Insurance information
The specific Information actually collected by CarStar will depend on the portion of the Services you access. If Non-Personal Information is connected or linked to PII, we treat the Non-Personal Information as PII.
3. How We Collect Information
We collect Information that is provided by you voluntarily, collected automatically through the Services, or provided by Third Parties.
a. PII Provided Directly by You
You may voluntarily provide us with PII when using the Services, including, without limitation, when you perform the following activities:
– Register for an Account or create a profile
– Use Interactive Areas
– Make Submissions, post comments, or provide reviews or testimonials
– Submit online forms or make requests for communication or support
– Initiate or complete transactions through the Services
– Initiate or complete credit check applications through the Services
– Make or receive payments
– Send or receive Texts
– Conduct and/or save searches
– Electronically sign agreements
– Communicate with any of the CarStar Representatives
Please note that content posted to the Interactive Areas, including your Submissions posted in such areas, may be publicly viewable or viewable by anyone who uses the Services. Therefore, if you upload or share any Information to the Interactive Areas, unless otherwise expressly stated by CarStar, such Information may be non-confidential and may become publicly available. This means that the Information may be collected, used, or redistributed by others, so please proceed with caution before posting anything sensitive or confidential to the Interactive Areas.
b. Information Collected Automatically
We and certain Third Parties may also automatically collect Non-Personal Information about you and your devices when you interact with the Services. This Information may include, without limitation:
– Computer or device operating system information
– IP address
– Network information
– Browser type and language
– Connection speed
– Mobile device ID
– Device hardware type
– Referring website or application accessed before or after accessing the Services
– Parts of the Services accessed
– Access times for and length of time spent on a page or using a feature
– Geographic location
c. Information Collected Through Tracking Tools
When you access our Services, we or Third Parties may use technologies such as “cookies”, local storage capabilities, or other similar technologies to monitor usage of the Services (“Tracking Tools”). These Tracking Tools allow the collection of Non-Personal Information (such as pages viewed by you within a certain Service and the duration of the browsing) and PII (such as your login information), including over time and across different properties and devices. Among other things, Tracking Tools can enable CarStar to automatically activate certain features for you, make your experience on the Services simpler, more relevant and more convenient, and provide you with personalized, interest-based advertisements, as further described below. Tracking Tools are used widely across the industry.
d. More About Tracking Tools
By accessing the Services, you consent to us setting and accessing Tracking Tools, including cookies, on your device and in the emails we send you, and to tracking your activities and your use of the Services through these Tracking Tools. For clarity, Third Parties do not have access to Tracking Tools set by CarStar on our Services except to the extent necessary to help us provide the Services. CarStar and Third Parties may use the following Tracking Tools:
– Unique Identifiers: We may use unique identifiers to collect information about your use of the Services on an individual basis, such as length of time spent on a particular page and pages viewed during a particular log-in period. We use this information to evaluate and improve the Services.
– Web Beacons: Web beacons, or clear GIFs or pixel tags, are small graphic image files that can be embedded in web pages or emails to collect information about your use of our Services or the correspondences that we send. The information collected by web beacons allows us to analyze how and how many people are using the Services or when you open our emails.
– Mobile Device Identifiers: Mobile device identifiers are stored on your mobile device and track how you use the Services through your mobile device. Mobile device identifiers enable collection of Non-Personal Information (such as usage and traffic data). As with other Tracking Tools, mobile device identifiers help CarStar learn more about your preferences and internet behaviors in order to operate and improve the Services.
e. Transferring Information Between Jurisdictions
4. CarStar’s Use and Sharing of Information
Generally, we use and share your Information to provide our Services, to improve our Services, and to send you news about promotions, products, or services offered by us or our Business Partners.
a. To Provide the Services
We use the Information collected, and may share such Information with Third Parties to provide, operate, and maintain our Services, including for the following purposes:
– Personalizing, improving, and operating our business and the Services
– Better understanding the needs and interests of you and others who may use the Services
– Fulfilling requests you make related to the Services, including to respond to your support requests or to process and facilitate transactions conducted on the Services
– Processing and facilitating payments
– Providing Service announcements or providing you with further information, recommendations, and offers from us or Third Parties
– Complying with applicable law, regulation, legal process, subpoena, or governmental requests, or other legal obligations
– Resolving disputes or security or technical issues
– Protecting, investigating, and deterring against fraudulent, harmful, unauthorized or illegal activity, or otherwise as we believe to be necessary to protect the rights, property, or safety of CarStar, the CarStar Representatives, you, or the general public
– Performing statistical analysis and research activities
– Processing or storing Information through CarStar’s affiliated companies and authorized Third Parties, as reasonable for business purposes (including, as applicable, their affiliates as necessary to provide us with the requested services)
– Other commercial purposes (including, without limitation, offering you insurance, financing, service contracts, or other products in connection with the purchase or sale of a vehicle)
b. Marketing and Advertisements
We may use your Information to send you information about our Services or the services of our Business Partners, including new products and promotions. Additionally, we may provide your Information to our Business Partners to contact you directly about their products and services, if we think you would be interested. Some advertisements may come from Third Parties called “ad networks.” Ad networks may include ad servers, ad agencies, ad technology vendors, and research firms. We do not provide PII to any ad networks for use not related to the Services. In some cases, advertisements served through the Services may be targeted to those who fit a certain general profile category or may be based on information inferred from the Information provided by you, your Services usage patterns, or your activity on Third Party services, including over time and across properties and devices. By using the Services, you consent to us providing you with marketing materials, which may include the following:
– Direct Marketing: Communications or advertisements sent directly to you by CarStar or our Business Partners via telephone, mail, email, text, or other methods for the purpose of ofering you products or services that may interest you.
– Advertisements: Advertisements and commercials from us or Third Parties. Note that if you click on any Third-Party advertisements, you may be transferred to a website of the Third Party or receive other messages, information or ofers from the advertiser and/or other Third Parties, and these advertisers and/or Third Parties may use their own Tracking Tools to collect information in order to send you advertisements and for their legitimate business interests.
– Interest-Based Advertisements: Content and advertisements personalized to your interests, which are inferred from your activity on our Services and other sites and services, and based on information gathered by us or Third Parties using Tracking Tools. These advertisements may be served to you on our Services or other services, sites, or apps. To learn more about interest-based advertising, and to opt-out of collection and use of your information for interest-based advertising, please click here to opt-out of collection and use by Digital Advertising Alliance (DAA) participating companies and here to opt-out of collection and use by NAI member companies. For mobile opt out, please visit the NAI Mobile Choices page here, or download the Ghostery mobile application.
You may withdraw your consent to receive marketing materials by following the opt-out instructions for removing yourself from our mailing list that is made available in the commercial materials transmitted to you. Furthermore, we give you the ability to opt out of marketing-related emails by clicking on a link in each such email. Please note that even if you choose to remove your Information (opt out), you will still see advertisements while you’re browsing online, however they may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. Please note that if you opt-out of targeted advertising, we may still track your use of the Services for analytics, operations and security purposes.
c. Uses and Disclosure of Non-Personal Information
Non-Personal Information informs us how you interact with the Services. Some of this Information may be derived from PII, but, if so, we anonymize or aggregate the PII so that it does not identify the individual from whom it was derived. Non-Personal Information enables us and Third Parties we authorize to figure out how and how often you engage with diferent parts of the Services so that we can analyze and improve them. We may use Non-Personal Information for:
– Industry analysis
– Marketing and advertising
– Facilitating collection of data concerning your interaction with the Services
– Fighting spam/malware
– Other business purposes (e.g., by reporting on trends in the usage of our Services)
CarStar may transfer and disclose Non-Personal Information to Third Parties at its own discretion.
5. Third Parties
Who we have in our passenger seats…
We may share Information with Third Parties, and they may share Information with us. Unless we tell you differently, our Service Providers do not have any right to PII that we share with them beyond what is necessary to assist us or provide products or services requested or accessed by you. You consent to our sharing of Information, which may include PII, with Third Parties, such as, without limitation:
– Social media networks
– Payment processors
– Credit check and financing Service Providers
– Vehicle inspectors
– Vehicle history providers
– Shipping providers
– Web hosting services
– Analytics and advertising Service Providers
– Sales management tools
– Marketing and promotion partners
– Law enforcement or other legal authorities or bodies pursuant to a subpoena or court order; however, if permitted, we may allow you an opportunity to object to the subpoena or court order before we provide the requested Information
Some specific Third Parties include, without limitation:
6. More About Financial Information
All about the Benjamins: The Information that helps you get either your dream car, or a chunk of change for your no-longer-dream car.
If you make a purchase or sale through the Services, or otherwise use the Services in a way that involves sending or receiving payment, we may request Information to process and complete the transaction such as:
– Credit card information
– Name and contact information of financial institution
– Account type
– IBAN number
– Routing number
– Account number
– Completing transactions you initiate through the Services
– Enrolling you in discount, rebate, and other programs in which you elect to participate
– Protecting against or identifying possible fraudulent transactions
– Otherwise as needed to manage and operate our business
If you fill out a credit application through our Services, we may collect and store your credit application details that are eventually shared with CarStar’s Business Partners or Service Providers, such as, without limitation, RouteOne LLC or Capital One, and which may contain some or all of the following Information:
– Email address
– Mailing address
– Phone number
– Date of birth
– Driver’s license number
– Employment information
– Income information
By submitting your Information, you expressly authorize (i) CarStar to transfer such Information to its Business Partners or Service Providers, and (ii) CarStar, and any of its Business Partners or Service Providers, to use that Information in accordance with their respective privacy policies.
7. Ways to Limit our Information Collection and/or Use
Here are some ways you can limit the Information that we collect and/or use from you. And don’t forget your privacy road flare if you have any questions: firstname.lastname@example.org
If you want to limit our collection and/or use of your Information, you have several choices, including:
– Limiting Information provided to CarStar: You can always opt not to disclose certain Information to us; however, if you choose not to provide us with certain Information, you may not be able to access certain features or services.
– Terminating your Account(s): You may be able to limit our collection and use of some of your Information by terminating your Account(s) on the Services.
– Your choices for Tracking Tools: You can opt-out of collection by certain Tracking Tools as described in the section titled “Marketing and Advertising”. Most browsers will allow you to erase cookies from your computer’s hard drive or from your device, block acceptance of cookies or receive a warning before a cookie is stored. You may also be able to erase or disable other Tracking Tools using the settings of your browser or mobile device. However, please note that if you block or erase Tracking Tools then our Services (and your experience) may be limited.
– Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. We do not support Do Not Track requests at this time. Furthermore, we can’t and don’t make any promises about how Third Parties react when you set this signal on your browser.
8. Accessing Your Information
If you are registered, you can access Information associated with your Account by logging into the Services.
United Kingdom Privacy Rights: Under United Kingdom Civil Code sections 1798.83-1798.84, United Kingdom residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.
9. Deleting or Modifying Your PII
10. Our Commitment to Data Security
We take reasonable physical, managerial and technical measures to maintain the security and integrity of your Information and the Services and prevent unauthorized access or use through generally accepted industry standard technologies and internal procedures, which include:
– Taking reasonable steps to verify your identity when you log-in to your Account and/or our Services, such as requesting a unique password. You are responsible for maintaining the secrecy of your unique password and Account information at all times.
– Maintaining PII behind secured networks and facilities that is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
– Encrypting sensitive financial information, such as credit card information, via Secure Socket Layer (SSL) technology prior to transmission over the Internet.
– Implementing a variety of industry standard security measures and tools, including, for example, the use of Microsoft Azure Cloud servers.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage, and we cannot guarantee that unauthorized access or use of your PII will never occur. We will not be responsible or liable for unauthorized access, hacking, or other security intrusions or the theft, deletion, corruption, destruction, damage, or loss of any data or information.
CarStar reserves the right to stop, temporarily or permanently, the operation of any and all Services without notice, at any time. All information (ours or yours) made available on the applicable portion of the Services may be removed or deleted, so please make your own copy of any Information you submit to CarStar. CarStar will not be liable to you or to any third party for any changes, suspension, or discontinuance of the Services or any malfunctions that may occur in connection thereto.
12. Children’s Policy
We do not intend to and do not knowingly collect PII from children under the age of thirteen (13). We reserve the right to request proof of age at any stage so that we can verify that children under the age of thirteen (13) are not using the Services. Please email us at email@example.com if you have reasons to suspect that we collected PII from a specific child under the age of thirteen (13).
13. Business Transfers
In the event that there’s a “merge ahead” (that is, if we choose to buy or sell assets), your Information is typically one of the transferred business assets. Additionally, if we, or substantially all of our assets, are acquired, or if we go out of business or enter bankruptcy, your Information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Information, including your PII, as set forth in this policy.
15. Any Questions?