Privacy Statement

Privacy Statement
Effective Date: December 20, 2015
Revised: November 1, 2020

Welcome

Thank you for your interest in this online automotive shopping quote form (the “Form”), which is operated by Detroit Trading Services, LLC (“Detroit Trading”). We encourage you to read the following Privacy Statement, which outlines how the Form and Detroit Trading collects, uses and maintains personal information from Form users. This Privacy Statement also outlines your rights as a consumer.

The Form provides users with various services, including an online platform that enables users to (1) comparison shop new and/or used vehicle pricing based on style, segment, brand, payment amount or other configurations determined by Detroit Trading in its sole discretion; (2) fill out online quote forms to ask dealers and/or authorized brand representatives questions, receive pricing information, learn about available manufacturer incentives, estimate the trade-in value of a vehicle and/or be placed in contact with an original equipment manufacturer, local vehicle dealer and/or seller; and (3) learn more about pricing on new and/or used vehicle inventory through a toll free telephone number (the “Services”). By using the Form or by providing personal information to us, you agree to the terms set forth below (the “Terms”). We respect your privacy when you use our Form.

What This Privacy Policy Covers and Does Not Cover

This Privacy Statement covers Detroit Trading’s use of the personal information you submit. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, and includes your first and last name, home mailing address, email address, phone number and/or any additional information that is not otherwise publicly available (“Personal Information”).

This policy does not cover the practices of companies that Detroit Trading does not own or control, or to people that Detroit Trading does not employ or manage, or to information collected by means other than those provided on this Form.

Information Detroit Trading Collects About You

Detroit Trading collects two (2) broad categories of Personal Information from individuals who use its Form:

• Personal Information Collected on Behalf of our Clients: We collect information on behalf of vehicle dealers, sellers and/or original equipment manufacturers, related service providers and their representatives and/or affiliates (each a “Client”, collectively, “Clients”). For example, the information you provide to us when filling out the Form is collected by us on behalf of our Clients. In this context, Detroit Trading is acting as a service provider and the Personal Information captured is subject to the privacy notices of the Client on whose behalf it is collected. You can access a Client’s privacy notice by visiting their site, scrolling to the footer of the page and clicking on the applicable link.
• Personal Information Collected to Operate our Services: In order to operate and improve our services, we capture Personal Information automatically from the users when they interact with the Form. We also obtain information from our affiliates, public sources, or other sources.

Personal Information Collected on Behalf of our Clients. Detroit Trading collects Personal Information on behalf of our Clients and acting as a service provider when you:

• Use Our Quote Form to Request Additional Information. When you use our Quote Form to request additional information regarding the purchase of a motor vehicle, we ask for Personal Information such as your first and last name, home mailing address (including street number, street name, city, state and zip code) email address, phone number and that make/model/year/trim of any vehicles that you select.
• Use Our Toll Free Number to Request Additional Information When you call us, we, Detroit Trading, or an authorized service partner acting on our behalf, may request and collect additional Personal Information to learn more about you, your needs and, if you expressly consent to further contact, we will place you in contact with up to five (5) automotive dealers and/or partner affiliates who will contact you about your request. We, or an authorized service partner acting on our behalf, may also collect other information about the call, such as call duration and call disposition.

Personal Information Collected to Operate our Services: In addition to collecting Personal Information on behalf of our clients, Detroit Trading collects Personal Information as follows

• Analytical Information. Detroit Trading uses automated methods to collect and aggregate information regarding general use of this Form. This is collected and stored in the form of user analytics, and it is used to help us improve user experience and the relevance of content that we provide and deliver. This analytical information may include, but is not limited to:
• Your IP address and the type of browser and operating system used.
• The date and time you accessed the Form and the pages you visited.
• Whether or not you linked from or to another website.
• Whether or not you open any email generated from the Form, and if so, the links that you click within the email.
• Your ISP or mobile carrier, and the type of handheld or mobile device that you used.
• Cookies, Local Shared Objects, Web Beacons and other Data Technologies. Detroit Trading automatically receives and records information on our server logs from your browser. This information may include, but is not limited to:
• • Cookies. Cookies are small identifiers sent from a web server and stored on your device for the purpose of identifying your browser and/or storing information or settings in your browser.
  • Local Shared Objects. Local shared objects are used to store your preferences or display content based on what you have viewed on other websites. They are sometimes known as “Flash Cookies”, and are used to personalize your viewing experience.
  • Web Beacons. Web beacons link web pages to web servers and their cookies.
  • Data Technologies. Any other technology that may be developed to track and analyze online browsing patterns and provide more customized browsing experiences on the Form.
• Publicly Posted Information. Detroit Trading may collect information that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms or similar functionality. This information is public information that we or others may share or use in accordance with the law.

How Detroit Trading Uses and Shares the Personal Information It Collects

When Detroit Trading collects Personal Information on behalf of a Client, the Personal Information collected is provided to that Client and the Client uses the information to provide you with the products and services you requested. The Client may follow up with you about the nature of your request or use your Personal Information to communicate with you about your request in accordance to their respective privacy statements and/or privacy policies, which you can access via visiting the applicable Client’s website, scrolling to the footer and clicking on the applicable link. As service providers, we provide this information to our Clients pursuant to a written contract, in response to the business purpose of responding to your request for more information about the purchase, finance and/or service of a motor vehicle and in return for compensation provided by our Clients or otherwise. After you have used our Form and consented to receiving additional information about the purchase and/or finance of an automobile, we may also contact you with a manually dialed phone call and/or an additional communication to request and/or share additional information about your request.

In regards to the Personal Information collected to operate our services, we may use and share it in the following ways:

1. For EverFor Everyday Business. Detroit Trading may share Personal Information collected to operate our services with group companies and entities that provide services to us for everyday business purposes such as managing your user account (if any), diagnosing technical issues, improving financial performance, improving user experience and evaluating our business.
2. In Response to Legal Action. Detroit Trading will share your Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
3. To Prevent Fraud or Illegal Action. Detroit Trading will share your Personal Information when we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Form’s Terms or Use, or as otherwise required by law.
4. In the context of a merger or acquisition: If we agree to sell, transfer or merge all or a portion of our business or assets, or in preparation for such operation under a non-disclosure agreement, in which case we will endeavor to ensure that the transferee agrees to use the Personal Information in a manner consistent with this notice.
5. Combined with Other Sources. We may combine Personal Information that you provide to us with information we receive from our affiliates and other sources, as well as with other information that is automatically collected. The combined information may include information about vehicle history, your interests and activities, additional demographic data, your use of the Form, your use of other websites, devices and mobile applications and information from our affiliates and other sources, and may be used to verify the accuracy of the data that you submit and/or provide us and our partners with additional insight about your preferences and the nature of your online request.

Transferability Notice. By providing us with your Personal Information, you expressly consent to the onward transfer of this Personal Information to our Clients so that they can follow up to your request. You understand that your Personal Information will be used in accordance to the terms of the Privacy Statements and/or Privacy Policies of those Clients.

Verification of Vendors and Partners. As noted above, we may share your Personal Information – whether for compensation or otherwise – with Clients with whom we have a contractual relationship as a service provider and who wish to do business, or attempt to do business with you, so that they can follow up to your request regarding the purchase and/or finance of a motor vehicle. While we use good faith efforts to verify that such entities will promote products and services in response to the requests made by you while using our Form, we cannot, and do not, endorse them unless we expressly state otherwise.

Your Express Consent. By using the services on this Form, you expressly consent to give to us and to our Clients the right to contact you and to attempt to sell, finance and/or service a motor vehicle. Such contact may be made to the number that you provide, whether land line number or mobile phone number, using automated telephone dialing systems, text and/or pre-recorded messages. By submitting a quote form, you expressly consent to these methods of contact and the onward transfer of your consent to the parties who will be contacting you about your request. You also expressly consent to the packaging of your information and transaction of your information – for compensation or otherwise – to a vehicle seller or related party as a sales lead.

Your use of this Form establishes a business or other applicable relationship with us for purposes of CAN-SPAM, the Telephone Consumer Protection Act and all other applicable law that addresses unsolicited commercial communications.

If you wish us to learn more about the data that we collect, opt-out from communications and/or refrain from providing your Personal Information in this manner, please see the opt-out information and contact information provided below.

Our Use of Cookies and Related Technology

As disclosed earlier, Detroit Trading may set and access cookies on your computer. We offer certain features that are only available through the use of cookies. We use cookies to help identify you, maintain your search results and introduce you to new products and/or services. You are always free to decline our cookies, if your browser permits, though doing so may interfere with your use of the Form.

Detroit Trading may engage advertising agencies and/or direct clients to provide advertisements on the Form. Those entities might use cookies and other tracking devices to collect information about your online activities over time and across different websites and services. That information may include: browser, IP address, page(s) visited, time, and date. This information is used to evaluate advertising activities and/or introduce related products, services and/or offers from these entities or their clients.

You might be able to exercise choices regarding such companies using third-party tools. Information about those third-party tools is available at http://www.networkadvertising.org/choices/ and http://www.aboutads.info/choices/.

Additionally, most web browsers include a “do not track” setting. There is a lack of certainty among companies on the web about the impact of the setting on the information collected. If you enable that setting, it will not change what information is exchanged with your computer, or how that information is used, when you visit our website(s).

Data Security

Detroit Trading uses commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard information about you in our possession against loss, theft and unauthorized use, disclosure or modification. Despite these measures, we cannot guarantee perfect security of networks, servers and databases we operate or that are operated on our behalf.

Your Data Rights

With regards to Personal Information Collected on Behalf of our Clients, you may have rights as stated in the respective privacy statements and/or privacy policies of the Client, which you can exercise following the steps outlined in their privacy notices which are accessible via visiting the applicable Client’s website, scrolling to the footer and clicking on the applicable link.

With regards to Personal Information Collected to Operate our Services Detroit Trading provides Form users the rights described below:

1. Right to Request Access to the Information Collected and Shared. You have a right to request disclosure of the categories and specific pieces of Personal Information we have collected about you. Please see below for the methods for submitting such a request.
2. Right to Delete. You have a right to request us to delete the Personal Information we have collected about you. Please see below for the methods for submitting such a request.
3. Right to Opt Out from Communications. You have the right, at any time, to opt out of receiving communications from us. Please see below for the methods for submitting such a request.
4. Right to Opt Out from Information Being Sold. You have the right, at any time, to opt out of the sale of your Personal Information by one of our Clients to a third party. Please see below for the methods for submitting such a request, which we will share with our Client so that they can process.
5. Right to Non Discrimination Related to Exercising Your Rights. We will not discriminate against you if you exercise any of these rights.

Methods to Submit a Request:

1. Via Email: To exercise any of the aforementioned rights, please email us at: info@rydeshopper.com , subject line “Rydeshopper – Right to Request”. In the body of your email, please clearly state the right you would like to exercise (e.g. Right to Request Information Collected and Shared, Right to Request Information Sold, Right to Delete, Right to Opt Out from Communications and/or Right to Opt Out from Information Being Sold.”
2. Via Phone: To exercise any of the aforementioned rights, please call us toll-free us at 1-833-621-0227 and clearly indicate that you would like to exercise your data rights. You will be asked what right you would like to exercise. Be ready to clearly disclose the data right you would like to exercise, e.g. Right to Request Information Collected and Shared, Right to Request Information Sold, Right to Delete, Right to Opt Out from Communications and/or Right to Opt Out from Information Being Sold.

Detroit Trading will comply with such requests as soon as is commercially practicable. This compliance may involve batch processing and other processes that may take ten (10) days or longer to process.

Limitations. Because your privacy is important to us, Detroit Trading extends the rights described above to all Form users regardless of whether they reside in a State that mandates them or not. Please note that your rights are subject to certain conditions and exceptions. For States that mandate and regulate these rights, Detroit Trading will comply with applicable law which provides for limitations (such as limitations under California law to the right to know based on our compliance with evidentiary privileges recognized under California Law) and exceptions (such as exceptions to the California right to erase under Cal. Civ. Code Sec. 1798.105(d).) For States where these rights are not mandated under applicable law, Detroit Trading will follow its own internal policies and procedures to consider and grant the rights and establish appropriate limitations.

Please also note that, on a case by case basis and in compliance with the California Consumer Privacy Act and any other state or federal statutes governing the collection and storage of Personal Information, we may continue to keep your Personal Information and any related information to the extent necessary to respond to any request involving your data rights above and/or respond to any governmental or legal proceedings.

Opt-Out Rescission. If you opt out per the process set forth above, but then either (a) provide your Personal Information to us again using the Form, (b) provide your Personal Information to us again using a related Form owned by a Detroit Trading affiliate or parent or (c) under other circumstances permit us to use your Personal Information, then we will regard your opt-out as rescinded.

Detroit Trading does not share Personal Information it collects to operate its services with third parties who are not Clients for the marketing purposes of those third parties who are not Clients.

Changes to this Privacy Statement

Detroit Trading may update this policy from time to time. If we make changes, we will revise the date at the top of this Privacy Statement. In some cases, we will also email users who have opted to receive communications from us, notifying them of the changes.

Other important information

The services that Detroit Trading offers on this Form are intended to be used by residents of the fifty (50) United States who are of the legal age to purchase and operate a motor vehicle in their state of residence. The information that these persons provide is stored on secure servers located in the United States.

Disputes

This Privacy Statement, the use of your Personal Information and any dispute you may have related to such is governed by the laws of the State of Michigan, USA. By accessing this Form and by using the services offered on the Form, you consent to the exclusive jurisdiction and venue of the courts in Oakland County, Michigan, USA.

Questions and Suggestions

If you have questions or suggestions about this Privacy Statement or any experience you have had with this Form, please contact our parent company at:

Detroit Trading Services, LLC
Attn: Privacy Statement Inquiries
13335 15 Mile Road
Sterling Heights, MI 48312-4271
248.352.1313

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