Off Lease Only Privacy Policy

September 17, 2021

Off Lease Only, LLC. (“OLO,” “we,” “us,” “our”) respects your privacy. This Privacy Policy (the “Privacy Policy”) applies to our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”), such as www.offleaseonly.com, and any services, transactions, or other engagements you might have with us (collectively, “Services”). This privacy policy does not apply to our collection or use of information for employees.

This Privacy Policy explains what information we collect about you, how we use or disclose that information, how to exercise any rights you may have with respect to your Personal Information (defined below), and the safeguards we have in place to reduce the risk of unauthorized access and use.

Please carefully read this Privacy Policy before using our Site and/or Services. If you do not agree with this Privacy Policy, you must refrain from using out Site and/or Services. By Accessing or using our Site and/or Services you agree to our use of your information consistent with this Privacy Policy.

If you provide information to us or we collect Personal Information about you in connection with a financial service such as a loan (potential or complete), your nonpublic personal information will also be governed by federal and state financial privacy laws such as the Gramm-Leach-Bliley Act, and the Financial Privacy Notice we previously provided. Any inconsistency between this Privacy Policy and the Financial Privacy Notice will be resolved in accordance with the Financial Privacy Notice.

Table of Contents

About this Privacy Policy

Personal Information

We collect, and in the past 12 months have collected, information that personally identifies, relates to, describes, or is capable of being associated with an individual (“Personal Information”), including:

  • Personal Identifiers and Contact Information such as name, mailing address, garaging address, email address, phone number, social security number, date of birth, driver’s license number, passport number, IP address;
  • Documents Containing Personal Information such as bills of sale, finance agreements, vehicle service contracts, GAP insurance plans, extended service agreements, utility bills, bank statements, tax returns, paystubs;
  • Financial Information such as bank account number, debit/credit card number, expiration date, check images;
  • Commercial Information such as VIN, vehicle characteristics, license plate number, vehicle registration, product interest and purchase history;
  • Internet and Network Information such as browsing/search history, data collected by cookies and other automated technologies;
  • Audio/Visual Information such as call recordings, customer photographs, photo ID, review/testimonial videos, CCTV footage;
  • Professional/Employment Information such as employer information, income, occupation;
  • Education Information such as education level;
  • Insurance Information such as vehicle insurance information; and
  • Inferences Drawn from the Above Categories of Personal Information that relate to your preferences, characteristics, behavior, attitudes, and aptitudes such credit reports, credit score, bankruptcy history, criminal record, etc.

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of online chat conversations, text messages, or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), apply for loan, purchase a vehicle from us, participate in consumer surveys, sweepstakes or contests, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.

Information About Others

If you provide Personal Information to us about any person other than yourself (such as a reference when applying for a loan), you represent and warrant that you have obtained permission from the relevant person to share their Personal Information with us.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokerages, insurance companies, consumer reporting agencies, marketing/advertising agencies, analytics firms, telecommunications providers, and government agencies.

Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet ExplorerFirefoxChromeSafari (iOS)Safari (Mac), and Opera. However, certain features of the Site may not work if you delete or disable cookies.

We use the following types of cookies:

  • Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Site and are typically deleted once you close your browser. For example, session cookies allow your online credit application to function properly.
  • Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Site. For example, persistent cookies may allow us to remember your preferences.
  • Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
  • Analytics Cookies: Analytics cookies help us understand how our Site is working and who is visiting our Site. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.

We employ software technology that enables us to track certain aspects of a user’s visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user. If you arrive at the Site by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Interest-Based Advertising

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Site or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Site or on third-party websites. If you do not want to receive interest-based advertising, please visit the Digital Advertising Alliance (DAA) Consumer Choice Page. The DAA website allows you to opt-out of certain interest-based advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA’s Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising.

Information from Advertisements

If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time of interaction).

Surveys

From time to time we may request Personal Information from consumers via surveys. Participation in these surveys is completely voluntary and you have a choice whether or not to disclose Personal Information. The requested information typically includes personal identifiers and contact information.

Sweepstakes and Contests

We may offer opportunities for consumers to participate in sweepstakes or contests. Participation in these sweepstakes or contests is completely voluntary but participation usually requires providing certain Personal Information. The requested Personal Information typically includes personal identifiers and contact information.

Social Media Widgets

The Site may include social media features, such as the Facebook, Google+, YouTube, LinkedIn, Instagram, Pinterest, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.

Third Parties that Collect Information on This Site

Certain third parties collect Personal Information and/or Usage Data from users of our Site using automatic information collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their privacy policies. This following third parties may collect Personal Information via our website:

Third Party Privacy Policy
Facebook https://www.facebook.com/privacy/explanation
Google https://policies.google.com/privacy?fg=1
Instagram https://help.instagram.com/519522125107875?helpref=page_content
LinkedIn https://www.linkedin.com/legal/privacy-policy
Pinterest https://policy.pinterest.com/en/privacy-policy
Twitter https://twitter.com/en/privacy
Criteo https://www.criteo.com/privacy/
Bing https://privacy.microsoft.com/en-us/privacystatement

How We Use and Share Information

Generally

We use Personal Information for internal purposes, such as to:

  • Provide you with the Site and Services;
  • Facilitate consumer transactions;
  • Market our products to you;
  • Perform marketing and other types of analytics;
  • Operate information security and anti-fraud programs;
  • Retrieve information from and report information to consumer reporting agencies;
  • Collect on consumer accounts (including repossession and auction, if necessary);
  • Complete legal filings and processes such as registering vehicles, paying taxes, placing and removing liens, and transferring vehicle ownership;
  • Perform day-to-day business operations such as accounting and general management; and
  • Respond to governmental and other legal requests.
Reviews and Testimonials

If you provide a review or testimonial, we may post it publicly on the Site or in other advertising material. By providing a review or testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Service Providers

We may establish a relationship with other businesses, including corporate affiliates, to provide services to us (“Service Providers”), including:

  • Providing goods or services to you or servicing your account or benefits;
  • Payment processing;
  • Facilitating marketing and non-marketing communications;
  • Marketing design and development;
  • Business analytics (both marketing and non-marketing related);
  • IT and network administration such as data storage and management, website hosting, and data security;
  • Professional services such as legal and accounting;
  • Obtaining legal records such as bankruptcy records;
  • Collection of accounts including repossession and auction of vehicles;
  • Consumer/credit report services; and
  • Day-to-day business operations such as courier services, facilities management, and document destruction.

We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

Information we Share or Sell to Third Parties

We may share Personal Information with other companies who do not provide services to us (“Third Parties”) such as companies that provide the ancillary products and services you purchase from us. This sharing may be considered a “sale” in some jurisdictions.

Categories of Personal Information we may sell include personal identifiers and contact information; documents containing Personal Information; commercial information; internet and network information; and inferences drawn from the above categories of Personal Information. We may share each of these categories of Personal Information with the following categories of third parties: providers of GAP insurance, service contracts, GPS services, vehicle protection products and key replacement.

Security and Other Relevant Information

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.

Other Websites

Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

Children’s Privacy

The Site and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

Additional California Consumer Rights

If you are a resident of California, you may have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell, under the California Consumer Privacy Act. Please be aware that much of the Personal Information we collect, use, disclose, and sell is governed by the Gramm-Leach-Bliley Act and, therefore, exempt from the California Consumer Privacy Act.

Right to Know

You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers. To protect your Personal Information, you must provide required information and/or documentation to verify your identity. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law

Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity.

Right to Opt-Out from the Sale of Personal Information

As a California resident, you have the right to direct us not to sell your Personal Information to Third Parties. We will process verified requests within 15 days, subject to any applicable exceptions and extensions permitted by law.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Site and Services do not respond to “do not track” signals.

Submitting a Request

If you are a California resident and would like to exercise your rights, you may submit a request though our online California Consumer Privacy Act Request Form or calling us at 833-551-0335.

Authorized Agent

If you are an authorized agent submitting a request for another California resident, you must provide a copy of a lawful power of attorney or written authorization from the Consumer (along with proof of your identity). You may provide this documentation via email to [email protected] after submitting the request. We may contact you or the Consumer on whose behalf you claim to act to verify your authorization.

Contact Us

If you have any questions about our Site, Services, or this Privacy Policy, please email us at [email protected], call us at 833-551-0335, or send us a letter to the following address:

Off Lease Only, LLC
Attn: Privacy
827 South State Road 7
North Lauderdale, Florida 33068