This Privacy Notice (“Privacy Notice”) sets forth the policies and practices used by Better Car People, LLC (“Better Car People”) regarding how we collect, use, and disclose any information associated with an identified or identifiable individual (“Personal Information”). It also explains the rights and choices individuals have concerning their Personal Information. Better Car People, the owner and operator of www.bettercarpeople.com (the “Website”), and all related services (collectively the “Services”), is a Limited Liability Company formed under the laws of the Delaware.
If you have any questions or concerns about this Privacy Notice, you may contact our Chief Operating Officer at support@bettercarpeople.com.
1. WHAT INFORMATION DO WE COLLECT?
We collect a variety of information to provide analytics, reporting, and other services to our customers, users of the Website, and the public at large. This includes both data that we collect directly and data uploaded by third-party customers. Below is a breakdown of the types of information we collect:
- Identifying information, such as first and last name, email address, or unique identifiers (e.g., IP address or device ID.
- Contact information such as your address (including home and business), phone number, or other communication details.
- Marketing and notification preferences.
- Employment-related information, such as job titles or department names.
- Demographic information, such as age or gender.
- Communications with us, including any information you provide via email, phone, or text, as well as product ratings, reviews, user or buyer feedback responses, and survey/form responses.
- Sensory data, including call recordings (e.g., customer support calls).
- Other personal information, including vehicle license plate.
- Geolocation data, including IP-based geolocation data and, with your consent, precise geolocation data.
- Job Applicant Information, including all information contained in a job application, resume, CV, or other documentation submitted as part of an application for employment, including any responses provided to questionnaires about the application.
- Transaction information, including vehicles purchased, considered, returned, exchanged, “saved” for later, or registered, as well as purchase amounts, dates of purchase, fulfillment status, and order tracking.
- Shipping and delivery information.
- Inferences drawn from your Personal Information, including the creation of profiles based on or reflecting preferences, interests, and/or previous transactions.
- Technical Information, as described below in “Information Collected Automatically.”
- Sensitive information, including the contents of communication between individuals and our business customers.
- Other data we are required or entitled by applicable law to collect and process for authentication or identification, or for the verification of data we collect.
2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Information Uploaded by Our Customers. As part of providing the Services, we allow organizations – our customers – to upload their own datasets to our platform for analysis and reporting. These datasets may include Personal Information about individuals, which is provided at the sole discretion of the customer uploading the data. Examples of Personal Information that may be included in customer uploads are: identifying information, contact information, marketing and notification preferences, demographic information, geolocation data, and transaction information.
Important Note: We do not control the content, structure, or accuracy of the data uploaded by our customers and rely on them to ensure compliance with all applicable privacy laws, including obtaining any necessary consent from the individuals whose data they upload.
Information You Voluntarily Submit. We collect Personal Information from you when you voluntarily provide such information, such as when you contact us, sign up for alerts or our newsletter, purchase products or services, or use our Website or Services. Examples of Personal Information you may voluntarily submit includes: Identifying information, contact information, marketing and notification preferences, employment-related information, demographic information, communications, sensory data, other personal information, geolocation data, transaction information, and shipping and delivery information.
Information Collected Automatically. When you interact with the Website, we automatically collect the following information about you:
- Device Information. We collect device-specific information, such as your operating system version, device type, and the name of the mobile network you are using. Our system logs may record certain information about your visits to our Website, including web requests, Internet Protocol (“IP”) addresses, device and mobile ad identifiers, browser information, and other such information. We may also collect device information from emails you receive from us which helps us track which emails are opened and which links recipients click. If you use your login information while connected to a Virtual Private Network, we may also collect that information.
- Location Information. Depending on your device permissions, when you access the Website or use our Services, we automatically collect and process information about your general location (e.g., city and state). We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile towers.
- Client and Log Data. We collect technical details, including your device’s Internet Protocol (IP) address, time zone and operating system. We will also store your login information (registration date, date of last password change, date of last successful login), type and version of your browser.
- Usage Information. We collect information about your activity on our Website which includes a timestamp of each visit, content you click, the duration of your visit, and the order in which you engage with our content. Based on your interactions and use of the Website, we may also collect additional information that is generated as part of such use.
- Cookies. We use cookies as part of our process for collecting data automatically. “Cookies” are small text files transferred by a web server to your device’s hard drive and may be used to collect data such as the date and time of your visit, your browsing history, preferences, and username. Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Please note that not all tracking will stop even if you delete cookies. For more information, please see our Cookie Settings in the footer of the Website.
Most web browsers are set to accept cookies by default. You can usually configure your browser to remove or block cookies. Keep in mind that if you choose to remove or reject cookies, it may impact the availability and functionality of our Website and/or Services.
Information Collected from Other Sources. We may collect information from third parties, including advertising and marketing partners, public databases, and social media platforms (such as those from individuals you are friends with or otherwise connected to). If we do, this Privacy Notice explains how we use that information, whether such use is independent of or in combination with the information you have provided.
Information Collected from Job Applicants. If you apply for a job through our Website or via third-party vendors we have retained to collect or process applications, your application and any additional information that you provide may be used to assess your skills and interests as they relate to any career opportunities with Better Car People, and for any reporting purposes that may be required by applicable law. We may also use your information to communicate with you and to inform you of career opportunities.
Sensitive Personal Information. We collect certain categories of sensitive Personal Information as part of our operation of our business and our Services.
Sensitive Personal Information that we may collect (as defined by applicable law, including the CPRA) may include precise geolocation and the contents of communications. If you submit such information to us or we collect for another legitimate business purpose, it will be governed by this Privacy Notice. We do not use or disclose Sensitive Personal Information for purposes other than those permitted by law, and you have the right to limit certain uses and disclosures as described below.
Important Considerations. To help protect user privacy, we only allow limited access to another user’s contact information as necessary to fulfill any transactions made using the Website, including the collection of payments. Such access may include the other user(s)’ name, unique user ID, email address, and other contact information.
If you submit any Personal Information relating to other people in connection with any Better Car People Online Properties, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
We are not responsible for protecting any information that you choose to share with third parties through the Website and/or Services. We do not have control over how other users who have access to the Website and/or Services, including areas not open to the general public, will use any content you share publicly or privately. Please exercise discretion when sharing Personal Information with other users.
3. HOW DO WE USE YOUR PERSONAL INFORMATION?
We process Personal Information only for the purposes described in this Privacy Notice or for purposes compatible with those for which the Personal Information was originally collected. Before using Personal Information for a new purpose that is materially different from or incompatible with the original purpose, we will notify you and, where required by applicable law, obtain your consent. If you have questions about how we use your Personal Information or believe that your Personal Information has been used in a manner inconsistent with this Privacy Notice, please contact us at support@bettercarpeople.com.
Better Car People may use Personal Information as permitted by law, for the following business purposes:
To provide you with the Services: This includes the operation and maintenance of the Website and/or Services, and enabling or facilitating specific product or Service features. We use the following categories of Personal Information for this purpose: account information, identifying information, contact information, location information, transaction information, interests and preferences, and device information.
To operate our business: This includes activities and processes necessary for the ongoing operation of our business, including providing you with user support, and to fulfill or meet the reason the individual provided the information (e.g., to process orders, provide information, or operate the Services). We use the following categories of Personal Information for this purpose: account information, identifying information, location information, communications, transaction information, device information, client and log data, and usage information.
To communicate with you: This includes responding to your comments or inquiries and fulfilling your requests; sending you administrative communications, such as confirmation emails, technical notices, policy updates or security alerts; providing you with reminders, notifications, loyalty benefits, and program participation updates; and soliciting and responding to user feedback, reviews, survey responses, and other evaluations. We use the following categories of Personal Information for this purpose: account information, identifying information, contact information, communications, transaction information, device information, and usage information.
To send you marketing and/or promotions: This includes sending you promotional information, such as newsletters and advertisements, including information and advertisements from our affiliates and on behalf of our promotional and strategic partners; and notifying you of new information or services that may be of interest to you, including promotions, campaigns, programs, contests, or sweepstakes. We use the following categories of Personal Information for this purpose: account information, identifying information, contact information, communications, transaction information, interests and preferences, device information, and usage information.
For analytics, research, and product and Service improvements: This includes tracking and measuring Website performance; performing quality control of our Website and Services through analytics and market research, and to otherwise determining the effectiveness, and improving the quality, of our Website and Services; conducting aggregated or de-identified research and statistical reporting for business purposes or regulatory/royalty reporting; and researching, developing, and analyzing trends for product and service development, beta testing, and to test new features. We use the following categories of Personal Information for this purpose: account information, identifying information, contact information, location information, communications, inferences, device information, client and log data, and usage information.
For personalization and advertising: This includes improving your experience on our Website and with our Services by providing a personalized experience; reviewing the effectiveness of our Website marketing and analyze other general demographic trends; and building or sharing user audiences (custom audiences, look-alike audiences, audience matching). We use the following categories of Personal Information for this purpose: account information, identifying information, location information, communications, transaction information, interests and preferences, inferences, device information, and usage information.
To ensure the security and integrity of the Services: This includes securing our systems and protecting our business, our employees, and you bypreventing, detecting, investigating, and securing against unauthorized or illegal activity and other security-related technical issues. We use the following categories of Personal Information for this purpose: account information, identifying information, contact information, location information, communications, interests and preferences, inferences, device information, client and log data, usage information, and verification information.
For other business purposes: This includes preserving and managing records of employment, business relationships, and performance for legal/commercial purposes; sharing Personal Information with service providers, contractors, business partners, affiliates, and parent/subsidiary companies for business-related functions; managing and maintaining ongoing relationships and contracts (including vendor, employment, and ambassador relationships); in connection with a job application or inquiry, to evaluate an individual for employment consideration, conduct background checks, verify employment eligibility, and other similar manners; and for business transfers (mergers, sales, acquisitions, bankruptcy, or dissolution). We use the following categories of Personal Information for this purpose: account information, identifying information, location information, communications, transaction information, device information, client and log data, and usage information.
To comply with the law and enforce our Terms: This includes the use of Personal Information as we believe to be necessary or appropriate for certain essential purposes, including: meeting our legal or regulatory obligations, complying with valid legal process, and protecting rights, safety, and property; to detect, prevent, or investigate security incidents, data breaches, or fraud; to enforce our Terms of Service and all other applicable terms and policies; and for all other purposes requested or permitted by our users or other relevant individuals, such as Website visitors or users of our Apps. We use the following categories of Personal Information for this purpose: account information, identifying information, contact information, location information, communications, interests and preferences, inferences, device information, client and log data, usage information, and verification information.
Use of AI and ML
To the extent permitted by law, we may use Artificial Intelligence (“AI”) or Machine Learning (“ML”) as part of our processes that use your Personal Information. Such uses include:
Personalization. We use AI and ML technologies to analyze your preferences and behaviors to provide personalized content. This process helps us deliver a unique and enhanced experience based on your preferences and interests.
Recommendations. We use AI and ML technologies to analyze your preferences and behaviors to provide recommendations based on your unique personal profile.
Functionality/Operation. We use AI and ML technologies to enable normal operation of the Website, and perform analysis to help us understand how you use the Website and/or Services in order to improve upon your experience, and develop new features, technologies, or improvements, and build, train, analyze, and improve the performance and/or accuracy of our AI and ML model(s).
Communication. We use AI and ML technologies to interact with and assist the user by answering questions and providing guidance related to the Website and/or Services, and collect information and provide responses via our AI Chatbot, and provide marketing and informational messages, personalized for the specific individual, based on a profile, inferences, and/or likely interests.
Profiling and Automated Decision-Making.We do not engage in profiling or use automated processing or decision-making on your Personal Information for decisions that produce legal or similarly significant effects within the meaning of applicable U.S. privacy laws or the E.U. AI Act.
Use of AI/ML by Vendors and Service Providers
Our service providers may use techniques like AI and/or ML to help us improve our Website and/or Services. When our service providers use such tools, it either: (1) still has a human being involved in the process, and thus is not fully automated; or (2) uses such tools in ways that do not have significant privacy implications (e.g., reordering how products might appear when you visit an online store) and does not produce any legal or similarly significant effects.
AI Model Training
Better Car People may use artificial intelligence and machine learning technologies as part of our Website and Services. Our models may be trained using data from user-provided inputs and outputs (subject to your opt-out rights) and user feedback.
We do not actively set out to collect Personal Information for the purpose of training our models. However, because a large amount of publicly available data relates to people, our training data may incidentally include Personal Information. We do not use such Personal Information to contact individuals, build profiles about them, or market to them.
We take steps to minimize the privacy impact on individuals as part of our data collection and training practices, including implementing privacy-by-design safeguards during model training and training our models not to disclose personal data from training data in outputs.
We may use your inputs and outputs to train our models and improve our Services, unless you opt out through contacting us at support@bettercarpeople.com. Even if you opt out, we may use inputs and outputs for model improvement when your interactions are flagged for safety review and/or you have explicitly reported materials to us through our feedback mechanisms.
Our models do not store text like a database, nor do they replicate or "collage" existing content. Models identify general patterns in data in order to generate new content and do not have access to or pull from original training data once the models have been trained.
AI Chatbots: We may use software applications that incorporate artificial intelligence technology (“AI Tools”), such as an AI Chatbot. AI Chatbots utilize advanced algorithms to interact with users. By engaging with Better Car People’s AI Chatbots, users consent to the collection and use of their Personal Information.
Our AI Chatbot collects and processes Personal Information provided directly by users (e.g., identifiers and contact details, the text and content you provide, contextual and device data, inferences, and various other types of information) for the purposes of using Better Car People’s products and Services, to improve Website functionality, and provide personalized recommendations. This data is used to enhance user experience, develop new features, and ensure compliance with legal standards.
Our legal basis to process data provided through our AI Chatbot includes providing the service you request, performing our contract with you, and pursuing our legitimate interests in improving support and product/service discovery. Where required, we also rely on your consent. We retain and protect Personal Information provided to the AI Chatbot consistent with the terms of this Notice.
We cannot guarantee the accuracy, completeness, or up-to-date nature of the information provided by the AI Chatbot, and it is strongly recommended that users use responses as a starting point and verify any critical details before acting on information provided. Do not share sensitive Personal Information or payment details via the AI Chatbot.
DISLCAIMER: AI CHATBOT OUTPUTS ARE FOR GENERAL INFORMATIONAL PURPOSES AND DO NOT CONSTITUTE ANY KIND OF PROFESSIONAL ADVICE (E.G., LEGAL, MEDICAL). THE AI CHATBOT IS DESIGNED TO ASSIST USERS AND DOES NOT MAKE DECISIONS THAT PRODUCE LEGALLY OR SIMILARLY SIGNIFICANT EFFECTS ABOUT YOU WITHOUT HUMAN INVOLVEMENT. YOU CAN IGNORE, CHANGE, OR REQUEST A HUMAN ALTERNATIVE AT ANY TIME. BETTER CAR PEOPLE CANNOT BE HELD RESPONSIBLE FOR ANY INFORMATION THAT USERS VOLUNTARILY SHARE WITH THE AI CHATBOT OR THE RESULTS OF ANY ACTIONS TAKEN SOLELY IN RELIANCE ON A RESPONSE PROVIDED BY THE AI CHATBOT.
4. HOW AND TO WHOM DO WE DISCLOSE PERSONAL INFORMATION
We may disclose Personal Information in certain circumstances as part of our general business practices. This section discusses those circumstances.
Disclosures for Business Purposes
To the extent permitted by law, your Personal Information may be disclosed with the following categories of third parties:
Parent Companies and Affiliates. For business-related functions, we may share Personal Information with a parent company, any subsidiaries, or other companies under a common control (collectively, our “Affiliates”), but only to the extent such information is provided an equal or greater level of protection as provided by this Privacy Notice.
Business Transfers. If we sell or transfer all or part of our business assets, Personal Information may be included. We will make every effort to ensure that any transferred Personal Information receives protection equal to or greater than that provided by this Privacy Notice. In the event of such a transfer, you are encouraged to contact the recipient with any questions about their applicable privacy practices.
Professional Advisors.For professional services, such as legal, accounting, auditing, or insurance, we may share Personal Information as necessary in the course of the professional services they render to us.
Agents, Consultants and Related Third Parties. For business-related functions (such as mailings, database maintenance, and payment processing), we may share Personal Information with third parties, but only to the extent necessary to perform their designated function.
When Legally Required. We may share Personal Information with law enforcement authorities, regulators, courts and tribunals, governmental or public bodies, and other relevant third parties as we believe necessary or appropriate to protect people or property, to protect our services, rights or property, to comply with legal or regulatory requirements and to respond to legal process, law enforcement requests and requests from other public and government authorities.
Third Party Vendors. We share Personal Information with vendors who provide products and services related to the operation and maintenance of the Website, and/or the performance of certain Services, and/or the analysis of user behavior, and/or evaluation of our advertising efforts. Each third-party vendor's privacy notice explains their use of your Personal Information. These include the following:
General Operations – We use third party vendors to support general business operations, including administrative services, workflow management, internal reporting, vendor management, and day-to-day operational support. These vendors may process contact information, account information, transaction records, communications, and other information necessary to perform services for us.
Tracking - To improve our Website and Services, we may share your Personal Information in a de-identified and/or aggregated format with analytics providers that help us analyze how people use our Services. For example, we use industry-standard analytics software to understand how people use our app, enabling us to improve the Services and increase engagement. We use the following third-party service providers for tracking:
Google Analytics: Privacy Notice
Google Analytics Opt-Out. You can prevent Google from collecting and using data (cookies and IP address) by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Edge, Safari, Firefox and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser.
Data Brokers, Data Enrichment Providers, Market-Data Providers – We use third party vendors to supplement, verify, update, analyze, or enrich information we maintain about customers, users, prospects, businesses, or audiences. These vendors may provide or process demographic information, business contact information, interest data, audience segments, identity-matching data, or other commercially available or inferred information for marketing, analytics, personalization, fraud prevention, or business development.
Remarketing – We utilize remarketing tracking cookies and conversion pixels from vendors such as Google and Facebook to display targeted offers for our products and services to you across the Google Content Network and various social media networks. This means that you may see an ad for one of our products or services after having visited our Website. We also utilize custom audiences based on subscriber email addresses and phone numbers, enabling us to present targeted offers via Facebook and Google. Your Personal Information is only used by remarketers for the purposes described in this section. We use the following third-party service providers for remarketing:
Cloud Hosting & IT Infrastructure Providers – We utilize AWS and Azure to provide hosting and storage of our data and systems. Personal information may be collected and maintained by AWS and Azure as part of their provision of these services.
Surveys and Forms – We utilize third-party vendors to create and manage online surveys and other forms, facilitating the collection and organization of information. Personal Information may be collected and maintained as a result of interacting with any surveys or forms.
CRM – We utilize third-party vendors to manage customer interactions and data, which may be enriched or updated by the vendor to ensure accuracy and relevance.
Email Marketing/Newsletters – We utilize Mailgun and Twilio as our email service provider and email marketing vendor. Through Mailgun and Twilio, we collect information related to our communication effectiveness and the impact of our email marketing, including tracking the actions you take that assist us in measuring the performance of the Website and our Services and our Email Marketing.
Our marketing emails and/or newsletters contain tracking pixels, allowing us to analyze the success of our marketing emails and/or newsletters. These tracking pixels allow us to see if and when you opened an email, which links you click in the email, and which pages of the Website you visit.
Payment Processors – We use third party vendors to process payments, refunds, credits, subscriptions, financing, payouts, chargebacks, and other financial transactions. These vendors may process payment-card information, bank account information, billing information, transaction details, authentication data, tax information, fraud-screening data, and related payment records. At no time is your banking information passed to the Website from the Third Party Vendor. We receive only information necessary for order fulfillment.
AI Chatbot - We utilize third-party vendors to provide an AI-powered chatbot on our Website and/or Services. The AI Chatbot enables us to interact with and assist users by answering questions, providing guidance, and facilitating self-service tasks. Personal Information that may be disclosed to these vendors in connection with the AI Chatbot includes identifiers and contact details (such as name and email address), and/or the text and content you provide to the chatbot, and/or contextual and device data, and/or inferences drawn from your interactions, and/or usage information. These vendors process your Personal Information on our behalf under a data processing agreement, and these vendors may temporarily log prompts and/or responses to operate, secure, and troubleshoot the service. We do not authorize these vendors to use your Personal Information for any purpose other than providing the AI Chatbot service to us. Do not share sensitive Personal Information or payment details via the AI Chatbot.
We use Botsplash as our third-party vendor for hosting our AI chatbot. For information about how Botsplash collects, processes, and shares Personal Information, see the Botsplash privacy notice here.
AI Large Language Models (AI Chatbot or other customer-facing features) - Our AI Chatbot may rely on one or more third-party large language model ("LLM") providers to process and generate responses to your inputs. We utilize OpenAI to power the underlying language model used by our AI Chatbot. Personal Information that may be disclosed to OpenAI includes the text and content you provide to the AI Chatbot (including any Personal Information contained in your prompts), and/or contextual and device data, and/or usage information, and/or inferences drawn from your interactions. OpenAI processes your Personal Information solely to generate responses on our behalf and in accordance with a data processing agreement. OpenAI does not use your inputs or the responses you receive to train, fine-tune, or improve its own AI models, unless we have expressly authorized such use.
AI Transcription and Summarization - We utilize third-party vendors to provide AI-powered transcription and summarization of audio recordings and/or customer support calls. Personal Information that may be disclosed to these vendors in connection with this service includes audio, electronic, visual, or similar information, and/or identifiers and contact details (such as names of speakers or participants), and/or the content of communications. These vendors process your Personal Information on our behalf under a data processing agreement and solely for the purpose of providing transcription and summarization services. Transcripts and summaries may be retained by these vendors only as necessary to deliver the service and are deleted in accordance with the terms of the data processing agreement.
Online Contact and Support – We provide various ways for you to contact us including online contact forms, emails, live chat, and automated chat. We may use AI systems to deliver some or all of these services to you. If you choose to contact us through a contact form, the information you submit will be stored by the vendor providing the service, in accordance with that company’s Privacy Notice.
Other Third Parties. We send your Personal Information to whom you ask us to send your information.
Advertisers. We partner with demand-side platforms who buy our ad placements through third-party vendors. We share your information with those vendors in a de-identified and/or aggregated form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysis.
Data Processing Agreements
Where we engage third-party service providers to process Personal Information on our behalf, we enter into written data processing agreements that require such providers to: (i) process Personal Information only in accordance with our documented instructions; (ii) implement appropriate technical and organizational measures to protect Personal Information; (iii) assist us in responding to data subject requests and complying with our obligations under applicable data protection laws; (iv) delete or return Personal Information upon termination of services; and (v) submit to audits and inspections as necessary to demonstrate compliance. These agreements are designed to ensure that all processors handling your Personal Information maintain protections consistent with this Privacy Notice and applicable law.
Sale and “Sharing” of Personal Information
We do not sell your Personal Information to third parties in exchange for monetary compensation. However, we may disclose certain Personal Information to third parties, such as advertising technology partners, data analytics providers, social media platforms, and advertising networks, so that we can provide you with targeted advertising and measure and improve the effectiveness of our advertising campaigns. These third parties may receive other valuable consideration or benefit from the use of the disclosed information for their own purposes, such as improving or enhancing their own products, records, or services, which may qualify as a “sale” or “sharing” of Personal Information as those terms are defined under the CCPA and other applicable U.S. state privacy laws.
Categories of Personal Information that may be disclosed in this manner include: identifiers and contact information, such as your name, email address, telephone number, postal address, account name, and other similar identifiers; online and technical information, such as IP address, device identifiers, cookie identifiers, advertising identifiers, and information regarding your interaction with our Website or Services; commercial information, such as transaction history and customer records; demographic information; geolocation data; audio, electronic, visual, or similar information you choose to provide; professional or employment-related information; and inferences or profiles derived from the foregoing. We do not sell or share the Personal Information of consumers we know to be under 16 years of age unless we receive affirmative authorization as required by applicable law.
You have the right to opt out of such sales and sharing. To exercise this right, please visit the "Do Not Sell or Share My Personal Information" link available on our Website, or submit a request pursuant to this Privacy Notice to support@bettercarpeople.com. We also honor browser-based opt-out preference signals, such as the Global Privacy Control ("GPC"), as required by applicable law.
Sale of De-identified, Anonymized, and/or Aggregated Data:In addition to the sale or sharing of Personal Information discussed in this Privacy Notice, we may also sell, donate, transfer, or otherwise provide any data we have collected in a de-identified, anonymized, or aggregated format to a third party for any purpose, provided that adequate steps have been taken to ensure that data cannot reasonably be re-identified.
Disclosure of Other Information
In addition to collecting Personal Information, we may collect information that does not identify you and is not associated with your Personal Information. We may also de-identify, anonymize, or aggregate information so it no longer identifies you. When we use or disclose de-identified information, we keep it in de-identified form, do not attempt to re-identify it unless allowed by law, and require recipients to do the same through contractual agreements.
Analysis of Website Performance. We may collect and combine such information with other data to monitor, for example, the total number of visitors to our Website, the number of visitors to each page, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Information is involved or used in this process.
Customer Research. To better serve and understand the needs of the Website’s users, we may conduct research on their demographics, interests and behavior using the Personal Information and other data we collect. This research may be compiled and analyzed in the aggregate, and we may share this aggregated data with our affiliates, agents and business partners. This aggregate information does not identify you personally. Better Car People may also disclose aggregated user statistics to describe our services to current and potential business partners, as well as to other third parties for lawful purposes.
Legal Basis for Processing Your Personal Information
Some jurisdictions require that companies tell you about the legal grounds that allow your data to be used or disclosed. Below are the types of lawful bases that we will rely on to process your Personal Information:
- Legitimate Interest: The purpose of conducting and managing our business to enable us to provide you with the best service, product, and a secure experience. We balance the potential positive and negative impacts on you and your rights. If the impact on your rights outweighs our legitimate business interests, we do not use or disclose your Personal Information without your consent, unless required or permitted by law. You can obtain further information about how we evaluate our legitimate interests against any potential impact on you for specific activities by contacting us at support@bettercarpeople.com.
- Performance of Contract: Processing your Personal Information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply With a Legal or Regulatory Obligation: Processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation.
- Consent: You have given express permission to a particular use of your Personal Information.
Legitimate Interest Assessments
Where we rely on legitimate interests as our legal basis for processing your Personal Information, we conduct and document legitimate interest assessments ("LIAs") to ensure that our interests do not override your fundamental rights and freedoms. These assessments consider: (i) the nature and purpose of the processing; (ii) the potential impact on you, including any risks to your privacy; (iii) whether you would reasonably expect the processing; (iv) the relationship between you and Better Car People; and (v) any safeguards we can implement to minimize any negative impact on you. You may request further information about how we have balanced our legitimate interests against your rights by contacting us at support@bettercarpeople.com.
Phone Numbers & SMS Marketing
Collection and Purpose. If you provide your mobile number to Better Car People (e.g., when creating an account, submitting a form, touring a property, requesting pricing or availability, texting a keyword from signage, or otherwise opting in), Better Car People may use your mobile number to send you SMS/text messages, including information about motor vehicle purchases, interest, warranties, service, other similar topics, and other news. Consent to receiving messages is not a condition of purchase, lease, or sale.
How Messages are Sent. Messages may be sent using an automated dialing system to the mobile number you provide. Message frequency varies. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages.
Opt-Out (“STOP”). You may opt out of marketing texts at any time by replying “STOP” to any message we send. After you send STOP, you may receive a one-time confirmation text, and then you will no longer receive marketing texts to that mobile number unless you re-opt in. For assistance, reply “HELP.”
Transactional Texts. If you are in an active transaction or have requested a specific service, you may still receive those transactional texts; to opt out of those messages, reply “STOP” on the relevant text thread.
Sources. Better Car People collects phone numbers directly from you and, where permitted, via branded or co-branded sign-ups, and referral programs.
Sharing with Service Providers. Better Car People may disclose your phone or mobile number to SMS platform providers, delivery vendors, mobile carriers, or other marketing or communication services platforms to send texts on our behalf. Better Car People does not permit these parties to use your phone or mobile number for their own marketing. Better Car People does not “sell” or “share” your phone or mobile number for cross-context marketing or behavioral advertising.
Lawful Basis and Other Rights. Better Car People’s lawful basis for use of your phone or mobile number for SMS marketing is your consent. Withdrawal of consent does not affect the lawfulness of Better Car People’s use of your phone or mobile number for such purposes before such withdrawal. For all other purposes, the general terms of this Privacy Notice apply.
5. YOUR RIGHTS RELATED TO YOUR PERSONAL INFORMATION
We provide several ways for you to exercise certain privacy choices about your Personal Information that we process. We are committed to respecting your privacy rights under all applicable data protection and privacy laws. Some privacy laws require us to give specific details about individual rights to consumers, which we have set forth in Section 11 of this Privacy Notice.
Marketing. You may opt out of marketing-related communications from us at any time by contacting us through the contact information provided in this Privacy Notice or by using the unsubscribe mechanism contained in each email or responding “STOP” to automated text messages. We will make efforts to honor your request as soon as reasonably possible. Please note that even if you opt out of marketing emails, we may still send you important administrative messages, which you cannot opt out of.
Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you block the use of tracking technologies, some parts of the Services may then be inaccessible or not function properly.
Interest-Based Advertising. We may partner with third-party advertising networks, analytics companies, and measurement services (collectively, "Ad Partners") to serve advertisements on our Website and/or Services and on third-party websites, mobile applications, and online services. These Ad Partners may use cookies, and/or pixel tags, and/or SDKs, and/or similar technologies to collect information about your activities across different websites, mobile applications, and services to provide you with advertising that is relevant to your interests ("Interest-Based Advertising").
To opt out of Interest-Based Advertising, you may use the following tools:
Advertising industry opt-out tools:
Digital Advertising Alliance (DAA): https://optout.aboutads.info
DAA Mobile App Opt-Out: https://youradchoices.com/appchoices
Network Advertising Initiative (NAI): https://optout.networkadvertising.org- Your Online Choices (EEA): https://youronlinechoices.eu - Digital Advertising Alliance of Canada: https://youradchoices.ca
Mobile device settings:
iOS Devices: Go to Settings > Privacy & Security > Apple Advertising > Personalized Ads
Android Devices: Go to Settings > Privacy > Ads > Opt Out of Ads Personalization
Platform-specific opt-outs:
Google: https://adssettings.google.com
Meta/Facebook: https://www.facebook.com/about/ads
Please note that opting out of Interest-Based Advertising does not mean you will no longer see advertisements; rather, the advertisements you see may be less relevant to your interests. These opt-out mechanisms are specific to the browser or device on which they are exercised, and you will need to opt out on each browser and device for which you wish to limit Interest-Based Advertising.
Location Information. You can choose whether or not to allow the Website and/or Services to collect and use real-time information about your device's location information from your device in your device's privacy settings. If you block the use of location information, some parts of the Website and/or Services may become inaccessible or not function properly.
Access, Amendment, and Deletion. Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted, or otherwise exercise your rights over your Personal Information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your Personal Information:
We will process any request in accordance with – and where required by – applicable law with respect to your Personal Information. We will take steps to verify your identity before implementing your request. We do not charge a fee to process or respond to your verified consumer request unless it is excessive, repetitive, manifestly unfounded, otherwise creates a burden or workload in excess of standard requests, or is prohibited by law. If we determine that the request warrants a fee, we will inform you of our decision and provide both a written justification for the fee, as well as a cost estimate, before proceeding with your request.
If you have a User Account with us, you may also make specific changes directly through your User Account profile page. Please note that changes made to your User Account profile page may not be reflected immediately.
Although our active systems and databases will reflect updates that have been requested and processed, we may retain all Personal Information for backups, archiving, fraud and abuse prevention, analytics, and to satisfy other legal obligations that we reasonably believe apply.
We take reasonable steps to ensure that the Personal Information we hold is accurate, complete, and up-to-date. We rely on you to provide accurate Personal Information and to notify us of any changes. If you become aware that Personal Information we hold about you is inaccurate, incomplete, or outdated, please contact us at support@bettercarpeople.com so that we can take appropriate steps to correct or update the information. Some of our Website and/or Services may allow you to update your Personal Information directly through your User Account settings.
Time for Changes to Take Effect
We aim to complete requests as soon as reasonably practicable, consistent with applicable laws. Requests made on behalf of another, which require confirmation of the agent’s authority and the authenticity of the requester, will likely take more time to complete.
We may need to retain certain information for recordkeeping purposes and to complete transactions you started before requesting a change or deletion. Some residual information may also remain in our databases and records and will not be removed. We may not always be able to fully comply with your request, especially if doing so would compromise our duty of confidentiality or if we are legally allowed to handle the request differently.
For jurisdiction-specific data privacy policies, please consult Section 11 of this notice for additional information.
6. CHANGES TO THIS PRIVACY NOTICE
We may periodically update this Privacy Notice. Please reference the “LAST UPDATED” legend at the top of this page to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will take effect upon the posting of the revised Privacy Notice on the Website.
If any changes to this Privacy Notice could potentially require you to provide renewed or additional consent for the use of your Personal Information, notice of the requirement, as well as information we are required to disclose related to your renewed or additional consent, will be prominently displayed, and will be sent to you directly via email, text message, and any other acceptable means of contact under applicable law.
7. AGE RESTRICTIONS
Better Car People does not knowingly collect any Personal Information from children under 13. We encourage parents and legal guardians to monitor their children’s Internet activity and to help enforce this Privacy Notice by instructing their children never to provide Personal Information on this (or any) Website without parental permission. If a parent or guardian believes that Better Car People has Personal Information about a child under 13 in its database, please contact support@bettercarpeople.com immediately. We will make every effort to promptly remove such information and unsubscribe them from any marketing lists.
8. THIRD PARTY PRIVACY PRACTICES
Our Website and/or Services may contain links to third-party websites or apps. If you click on one of these links, be aware that each one will have its own Privacy Notice. We do not control these websites/apps and are not responsible for their policies. When you leave the Website, we encourage you to read the Privacy Notice of every website you visit.
We are not responsible for the privacy and data security practices of other organizations, such as Facebook, Instagram, Apple, Google, Microsoft, X, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer. Please read their privacy policies and consider customizing your browser or device settings to limit the disclosure of certain information, such as location data.
Any Personal Information that you provide through these third-party websites, mobile applications, or social platforms will be subject to the Privacy Notice of its operator, and not this Privacy Notice.
9. DO NOT TRACK, GPC, OPT-OUT SIGNALS
Do Not Track
We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Notice.
Global Privacy Control and Opt-Out Preference Signals
In addition to traditional Do Not Track signals, Better Car People recognizes and responds to the Global Privacy Control ("GPC") opt-out preference signal, which is a browser-based signal that communicates your preference to opt out of the “sale” and/or “sharing” and/or processing for purposes of targeted or cross-context behavioral advertising of your Personal Information, as those terms are defined under applicable laws. If our Website and/or Services detect that your browser or device is transmitting a GPC signal, we will process that signal as an opt-out request for that browser or device in accordance with applicable law.
Please note:
- The GPC signal applies only to the specific browser and/or device from which it is transmitted. If you access our Website and/or Services from a different browser or device, you will need to enable the GPC signal separately for each.
- If you clear your cookies, change your browser settings, or uninstall and reinstall your browser, your opt-out preference may need to be re-established.
- The GPC signal is offered by third parties that we do not control. For more information about how GPC works, please visit https://globalprivacycontrol.org/.
10. MISCELLANEOUS TERMS AND CONDITIONS
Other Terms and Policies
This Privacy Notice is to be read in conjunction with this Website’s Terms of Use. Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Better Car People. Please refer to those agreements as needed.
Reservation of Rights
Regardless of any other part of this Privacy Notice, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in emergencies, to protect the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations to reduce credit risk and protect against fraud.
Security of Personal Information
We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your Personal Information. Unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you suspect that the security of any Personal Information you provided to us has been compromised), please notify us immediately at support@bettercarpeople.com.
Privacy by Design
We are committed to integrating data protection considerations into the design and development of our products, services, and business processes from the outset. This means that we: (i) consider privacy implications before launching new products, services, or features that involve the processing of Personal Information; (ii) implement technical and organizational measures to ensure that, by default, only Personal Information necessary for each specific purpose is processed; (iii) apply data minimization, pseudonymization, and other privacy-enhancing techniques where appropriate; and (iv) provide individuals with meaningful choices and control over their Personal Information. Our goal is to build privacy protections into our Website and/or Services so that your Personal Information is protected by design rather than as an afterthought.
Retention of Personal Information
We retain each category of Personal Information for only as long as necessary to fulfill the purposes described in this Privacy Notice. We consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it and whether those purposes can be achieved through other means; and any relevant legal, regulatory, tax, accounting, or reporting requirements.
Be Advised: We retain datasets uploaded by our customers for as long as our customers are members of our Services. We therefore maintain the right to store any Personal Information contained therein for as long as the customer maintains their account. To protect any Personal Information included in customer-uploaded datasets, we employ the following security measures:
- Encryption and Secure Storage is used to safeguard data both at rest and in transit;
- Access Restrictions allow only authorized personnel to access Personal Information; and
- Customers are contractually obligated to comply with all applicable data protection laws, including requirements to obtain appropriate consent for any data they upload.
If you believe that your Personal Information has been improperly included in a dataset by one of our customers, please contact that customer directly to exercise any rights you may have regarding such information.
11. ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS
Residents of certain countries or U.S. states have additional rights under applicable privacy laws, as described in this section. The term “Personal Information” encompasses “Personal Information” as defined by Canadian, Australian, and New Zealand law, as well as “Personal Data” as defined by the EU, the UK, Swiss, and Singaporean law. See the list below for which section applies to you.
- If you are a California resident, please review Section 11.1.
- If you are a resident of another U.S. state, please review Section 11.2.
- If you are a resident of Canada, please review Section 11.3.
11.1. Residents of the State of California
CCPA Personal Information Use Disclosure
The California Consumer Privacy Act of 2019 (“CCPA”) requires that we disclose certain categories of Personal Information that we collect, the sources of that Personal Information, the purpose of collecting such information and the categories of third parties with whom we share that information.
Categories of Personal Information that we collect and disclose. Our collection, use and disclosure of Personal Information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Below we describe the categories of Personal Information we may collect about California residents (including the categories of Personal Information that we have collected about California residents in the past 12 months):
Identifiers: Includes direct identifiers such as a real name, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, driver’s license number, or other similar identifiers.
Customer records: Paper and electronic customer records containing Personal Information, which you provide to us, such as name, digital signature, address, telephone number, email and other contact information, government identifiers, financial and payment information.
Commercial information: Including records of personal property, products, or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage data: Internet or other electronic network activity information including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Location data: Location information about a particular individual or device.
Employment history: Professional or employment-related information, including inferences about such information based on other types of information we have collected from you or from third parties.
Education information: Education history and background, including inferences about such information based on other types of information we have collected from you or from third parties.
Profiles and inferences: Inferences drawn from any of the information identified above to create a profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Sensitive Personal Information: In limited circumstances, we may collect certain information considered to be sensitive Personal Information under the CCPA, including driver’s license, state identification card, or other government identifier; and geolocation data. If we process Sensitive Personal Information, California residents may also exercise the ‘Limit the Use and Disclosure of My Sensitive Personal Information’ option by contacting us as described above.
We may disclose any of the categories of Personal Information we collect about you to other third parties as directed by or consented to by you, or where necessary to fulfill your specific requests.
Sales and Sharing. The CCPA defines a “sale” as disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available Personal Information to a third party for cross-context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA): (i) identifiers, usage data, customer records, commercial information, and profiles with our affiliates and subsidiary companies (e.g., so they can improve or enhance their own records and for other purposes); (ii) identifiers, customer records, and commercial information related to transactions with partners and third-party businesses, who may use or process the information for their own commercial purposes; and (iii) identifiers, usage data, and commercial information to ad networks, social media platforms, and data analytics providers (e.g., to improve and measure our ad and marketing campaigns). Some third-party cookies and similar technologies on our Website may constitute a ‘sale’ or ‘sharing’ of Personal Information under California law. You can manage these by using the ‘Cookie Preferences’ or by enabling GPC in your browser.
Sources of Personal Information. As described in more detail in Section 2, above, we may collect Personal Information from the following sources:
- Directly from the individual;
- Our customers (automobile dealerships, service centers, and similar automobile-related businesses) who have collected Personal Information pursuant to their own collection notices;
- Property records, public records, and other publicly available sources;
- Advertising networks;
- Data analytics providers;
- Social networks;
- Government entities;
- Data brokers;
- Affiliate and subsidiary companies; and
- Service providers.
Purposes of Collection, Use, and Disclosure. As described in more detail in Section 3, above, we collect, use, disclose, and otherwise process Personal Information (including sensitive Personal Information) for the following business or commercial purposes or as otherwise directed or consented to by you:
- Providing support and related services;
- Analyzing and improving our business;
- Personalizing content and experiences;
- Advertising, marketing, and promotional purposes;
- Securing and protecting our business;
- Defending our legal rights;
- Planning and facilitating business transactions;
- Auditing, reporting, corporate governance, and internal operations; and
- Complying with any legal obligations.
Retention. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice or otherwise disclosed to you at the time of collection unless an extended retention period is required or permitted by law. We may retain Personal Information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend, or protect our legal rights.
California law may permit you to request that we:
- Provide you with a list of the categories of Personal Information we have collected or disclosed about you in the last twelve (12) months; the source category of such information; the business or commercial purpose for collecting or selling the information; and the categories of third parties to whom we disclosed the information;
- Provide access to and/or a copy of the Personal Information we have collected about you.
- Delete certain Personal Information we have collected about you.
- Do not sell your Personal Information to any third parties.
Certain information is exempt from such requests under applicable law. You may also have the right to receive information about the financial incentives we offer you (if any). You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising your CCPA rights.
Minors. We do not knowingly sell or share Personal Information of consumers under 16 years of age without express consent. If we become aware that a consumer is between 13 and 16 years old, we will obtain that consumer’s affirmative authorization (opt-in) before any sale or sharing; for consumers under 13, we will obtain parental/guardian consent.
Submitting CCPA Requests. California residents may exercise their CCPA privacy rights to know/access, delete, correct, and limit use/disclosure of sensitive Personal Information by submitting a verifiable request to us via:
We will respond to verified requests received from California residents as required by law. When you submit a request to know or delete, we will take steps to verify your identity by matching the information you provide with the information we have on file. You must provide all requested information so that we can process and verify your request. In some cases, we may ask for additional information to verify your request or, if necessary, to process it. If we are unable to verify a request, we will notify the requester. Authorized agents can submit a request on behalf of another individual by contacting us via email or phone. To do so, they will need to provide proof of their authorization. Additionally, we may also require the relevant consumer to directly verify their identity and the authority of the authorized agent.
Requests to Opt Out. Our Website and/or Services responds to GPC signals as provided in this Privacy Notice.
For more information about GPC, please visit: www.globalprivacycontrol.org/. You may also submit a request to opt out of other sharing and sales by submitting a request via:
Rights Under California Shine the Light Law. California residents may request from businesses with whom they have an established business relationship: (1) a list of categories of Personal Information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes and (2) the names and addresses of all such third parties. To request the above information please contact us by writing to us under the “Contact Us” section above. We will respond to such requests within 30 days of receipt.
For more information about our privacy practices, contact us as set forth above.
11.2. Residents of Other U.S. States
Certain other U.S. states provide their residents with rights related to their Personal Information, which may include:
- Confirming whether we process their Personal Information, and if so, providing limited information about the nature of the Personal Information collected, processed, and disclosed, the business or commercial purpose, and information concerning third parties to whom the Personal Information was disclosed.
- Accessing and deleting certain Personal Information.
- Correcting inaccuracies in their Personal Information, considering the Personal Information’s nature and processing purpose (excluding Iowa and Utah).
- Data portability.
- Opting-out of Personal Information processing for:
- targeted advertising (excluding Iowa);
- sales; or
- profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
- Either limiting (opting-out of) or requiring consent to process sensitive Personal Information.
The exact scope of these rights may vary by state. To exercise or appeal a decision regarding a consumer rights request, please contact us at support@bettercarpeople.com
If we deny your request, you may appeal our decision by emailing us and including ‘Appeal’ in the subject line and a brief explanation. We will inform you in writing of any action taken or not taken in response to the appeal within 45 days, including a written explanation of the reasons.
Nevada provides its residents with a limited right to opt out of the sale of Personal Information. However, please note that we do not currently sell data that triggers the statute's opt-out requirements.
11.3 Residents of Canada
Canadian privacy laws, including the Federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Personal Information Protection Act, SBC 2003 c 63, in British Columbia, the Personal Information Protection Act, SA 2003 c P-6.5, in Alberta, and the Act Respecting the Protection of Personal Information in the Private Sector, CQLR c P-39-1 (“Quebec Private Sector Act”), in Quebec, apply to the collection of Personal Information from and about Canadian residents. “Personal Information,” as used in this Privacy Notice, includes “Personal Information” as defined under those laws.
Better Car People’s Chief Operating Officer is responsible for managing Personal Information, including under the Quebec Private Sector Act. You may contact them by email at support@bettercarpeople.com. When Better Car People collects Personal Information from Canadian residents, including those in Quebec, it transfers that data to data centers in the United States. When Better Car People relies on service providers to process Personal Information as described herein, these providers may also be located outside of Canada or Quebec.
Personal Information may be processed in the United States and other countries by Better Car People and its service providers. While your Personal Information is stored outside Canada, it will be subject to the laws of that foreign jurisdiction, which may differ from Canadian law.
You have the right to request access or rectification of the Personal Information Better Car People holds related to you or to withdraw any consent given to the processing of such Personal Information. You may exercise those rights by contacting Better Car People’s Chief Operating Officer at support@bettercarpeople.com. If Better Car People has your Personal Information that was initially collected with your consent by an entity that subsequently provided it to Better Car People, please contact that entity for any questions related to that entity’s privacy policies and consent practices.
12. SECTOR-SPECIFIC PRIVACY REQUIREMENTS
FTC Act Compliance
Better Car People is committed to complying with Section 5 of the Federal Trade Commission Act, which prohibits unfair or deceptive acts or practices in or affecting commerce. We strive to ensure that our privacy practices are consistent with the statements made in this Privacy Notice and any other representations we make about our data practices.
