Last
Updated: May 18, 2023
Off Lease Only
LLC, Off Lease Only LLC d/b/a CarSquad, and Off Lease Only d/b/a Used Cars For Less (“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, www.carsquad.com, and www.usedcarsforless.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
Information We Collect
How We Collect Information
Cookies and Interest-Based Advertising
Third Parties that Collect
Information on This Site
How We Use and Share Information
Security and Other Relevant Information
Children’s Privacy
Additional California Consumer Rights
Contact Us
About this Privacy Policy
Privacy Policy Changes
This Privacy
Policy is subject to change. We encourage you to review this Privacy Policy
frequently for any revisions or amendments. Changes to this Privacy Policy will
be posted on this Site and will be effective immediately upon posting. You will
be deemed to have been made aware of and have accepted the changes by your continued
use of our Site or Services. If we determine that a change to this Privacy
Policy will result in using your Personal Information acquired before the
change in a materially new way, we will provide you
notice before using your Personal Information in the new way.
Conflict Between this Policy and Laws and Regulations
When federal,
state, and local laws and regulations require a higher level of protection for
your Personal Information, they take precedence over this Privacy Policy. In
addition, the specific requirements of this Privacy Policy apply only when
local laws and regulations permit.
Information We Collect
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 Explorer, Firefox, Chrome, Safari
(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:
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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 CCPA – Data Privacy
– Request 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 privacy@offleaseonly.com 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 privacy@offleaseonly.com, call us at 833-551-0335, or send us a letter to
the following address:
Off Lease Only, LLC
Attn: Privacy/Legal
827 South State Road 7
North Lauderdale, Florida 33068