Effective Date: January 1, 2020
We collect the following categories of information from and about you:
- Contact information, such as name, postal address, email address, and phone Number.
- Information regarding your lease or finance terms and monthly payment amounts, that we may obtain from third-party sources.
- Information regarding the mileage on your vehicle, which is collected when you bring your vehicle to our Hoehn Motors dealerships service department, or that we may obtain from third-party sources.
- Geolocation information.
- Online identifiers, such as username and IP address.
- Usage information, such as how you and your device interact with our website (e.g.,the pages you visit or the search terms you enter).
- Other information, such as your car preferences, or information regarding your potential trade-in vehicle, that you provide or that we may obtain from third-party sources.
View for our Notice at Collection of Personal Information here, which lists the categories of personal information we collect from consumers and the purposes for collecting the information.
Below is a chart regarding the personal information we have collected about consumers during the last 12 months:
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
(Including, but not limited to) or (non-exhaustive list)
(YES or NO)
|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 (including language use and possession of a driver’s license issued to persons unable to provide their presence in the United States as authorized under federal law), citizenship, religion or creed (including religious dress and grooming practices), marital status, medical condition (including cancer or a record or history of cancer), AIDS/HIV, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, childbirth, breastfeeding and related medical conditions), sexual orientation, veteran or military status, Political affiliations or activities, status as a victim of domestic violence, assault, or stalking, genetic information (including familial genetic information), request for family care leave, request for leave for an employee’s own serious health condition, request for Pregnancy Disability Leave, retaliation for reporting patient abuse in tax-supported institutions.||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||Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.||NO|
|F. Internet or similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data||Physical location or movements.||YES|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||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 personal information||Profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our users when they submit a lead form or other web form on the site.
- Directly and indirectly from interaction with our website (or an affiliated site). For example, from submissions through our website portal or website usage details (including without limitation IP address, device ID, geolocation data collected automatically).
- Directly and indirectly from our service providers or their agents.
- From data aggregators/providers and similar vendors.
- From third parties that interact with us in connection with the services we perform. For example, we may receive aggregated vehicle sales records for analytics and other purposes.
- From anti-fraud and other crime prevention partners.
Use of Personal Information:
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order to indicate interest in a particular vehicle, promotion or offering.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- 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 improve our website and present its contents to you including the powering of products and features used throughout the site.
- To power and maintain saved user accounts.
- For attribution purposes.
- To send promotional materials.
- To provide custom and/or individually-tailored website experiences.
- For ad serving, targeting and retargeting, creation of audience segments, and related OBA (online behavioral advertising) purposes.
- To create inferred search preferences and inclination/intent to purchase certain vehicles or makes/models for improved ad targeting and custom experience implantation.
- For internal operations and site optimization including product development.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To enable anti-fraud and crime prevention efforts.
- 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.
Sharing Personal Information:
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- A. Identifiers
- B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- C. Protected classification characteristics under California or federal law
- D. Commercial information
- F. Internet or similar network activity
- G. Geolocation data
- K. Inferences drawn from personal information
In the preceding twelve (12) months we have not sold personal information.
Categories of Parties to which we may Disclose Personal Information:
We may disclose your personal information for a business purpose to the following categories of third parties:
- Our subsidiaries, parent(s) and affiliates
- Service providers (including, without limitation, website and internal operations platform providers)
- Automotive OEMs
- 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.
- Essential – Some cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
Collection and Use of Information from Children:
Our Services are not intended for children. We do not knowingly collect personal information from children, and none of our Services are designed to attract children. In the event that we learn that a person under the age of 13 has provided personal information to us, we will delete such personal information as soon as possible.
We provide you the opportunity to opt-out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided below. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.
Additionally, we may send you information regarding our Services, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature, rather than promotional.
Third Party Links:
Our website contains links to other sites. Hoehn Motors is not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.
Your California Privacy Rights:
California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information, once a year, regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email using the contact information provided below and put “Shine the Light Request” in the subject line of your email: email@example.com
From January 1, 2020, California consumers have the following rights:
Right to know
You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. Please see above.
Right to delete
You have the right to request the deletion of your personal information. Please note that notwithstanding your request, California law permits us to retain certain categories of personal information for numerous purposes, including to complete a transaction, to perform a contract between you and Hoehn Motors, and to comply with a legal obligation.
Right to opt-out of sale
You have the right to opt out of the sale of your personal information to third parties. We do not sell your personal information to third parties.
Right to non-discrimination
You have the right to not be discriminated against for exercising any of these rights.
We do not sell or knowingly collect the personal information of minors under 16 years of age.
If you would like to exercise on or more of the above rights, please contact us using the contact information provided below:
Notice Regarding Public Posting Areas:
Please note that any information you include in a message you post to any public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. HOEHN MOTORS IS NOT RESP®ONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.
We implement reasonable security measures to ensure the security of your personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, Hoehn Motors cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
International Data Transfers:
Hoehn Motors is based in the U.S. If you choose to provide us with information, please understand that your personal information may be transferred to the U.S. and that we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the EU or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the U.S. and other jurisdictions which may not have the same data protection laws as the EU. We put in place appropriate operational, procedural and technical measures in order to ensure the protection of your personal information. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Policy; and (ii) your personal information may be transferred to the U.S. and other jurisdictions as indicated above, in accordance with applicable law.
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal information collected via the Services.
We reserve the right to change this Policy from time to time. When we do, we will also revise the “Effective Date” at the top of this Policy. If we make material changes to the Policy, we will notify you by placing a prominent notice on our website and/or by sending you an email at the email address we have on file for you. We encourage you to periodically review this Policy to keep up to date on how we are handling your personal information.
Last Updated January 1, 2020