Whenever you visit our Website, we will collect some information from you automatically simply by you visiting and navigating through the site, and some voluntarily when you submit information to request information, products, or services, or when you sign up for our newsletter. Through our Website, we will collect information that can identify you and/or your activity.
And whenever you communicate, interact or do business with us, whether online or at our Dealership locations, we will be collecting personal information from you or about you in the course of our interaction or dealings with you.
The Dealership may collect the following categories of personal information about you based on your specific transactions and interactions with the Dealership or its website. For each category of information, the business purposes for which we use the information and the third parties with whom we have shared the information in the last 12 months are referenced by a number that coincides with the number in the lists that follow below in this policy.
|Category||Examples||Business Purpose||Sources||Shared in Last 12 Months With|
|Personal Identifiers & Contact Information||Name, alias, address, email address, social security number, driver’s license number, account username and password||1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 18||From you the consumer||A, B, E, F, G, H|
|Protected Classifications||Gender, ethnicity, language preference||1, 3, 4, 11, 13||From you the consumer||A, B, E|
|Commercial Transactional Data||Records of products or services provided, purchasing history, financing transactions, request for credit approval||1, 3, 4, 7, 12||From you the consumer||A, B, D, E, G, H|
|Biometric Data||Voice recordings of customer calls recorded for training or quality assurance purposes; thumbprints or fingerprints; surveillance footage on Dealership property||11||From you the consumer||Not shared|
|Internet Activity||Browsing history, search history, type of browser used, cookies, device used to access the site, domain name from which our site was accessed||12, 13, 14, 15, 16, 17, 18||Visitors of our website and the device and browser used to access the website||G|
|Geolocation Data||IP address; GPS trackers in loaner vehicles||12, 13, 14, 15, 16, 17, 18||Visitors of our website and the device and browser used to access the website||Not Shared|
|Mobile Device Data||Information collected when you navigate, access or use any of our websites via mobile device, including device type, software type||12, 13, 14, 15, 16, 17, 18||Visitors of our website and the device and browser used to access the website||G|
|Financial / Employment Data||Information collected through credit or financing applications, including employment history, company name, role, salary, dates of employment, bank accounts, income sources||1||From you the consumer||B|
|1||To process and submit financing applications, including to apply for credit, lease or credit pre-qualification|
|2||For security and insurance purposes, a copy of the driver’s license is obtained to permit a customer to test drive a vehicle|
|3||To process, complete, and maintain records on transactions including vehicle purchase, service, products, parts or accessories|
|4||To provide complete warranty coverage on vehicles, products, parts, service, and accessories|
|5||We retain your selection for Text opt in/opt out to ensure customers who opted out are not sent any text messages|
|6||To provide and communicate recall notifications to customers|
|7||To reserve a vehicle that a customer expressed interest in and requested that it be reserved|
|8||To schedule, manage and keep track of customer appointments|
|9||To complete a vehicle appraisal|
|10||To maintain records of when customers decline a service or sale|
|11||To respond to consumer inquiries, including vehicle interest, request for information, Customer Support online, phone calls, and in-store inquiries|
|12||To provide interest-based and targeted advertising|
|13||To improve user experience on our website|
|14||To understand the demographics of our website visitors|
|15||To detect security incidents|
|16||To debug, identify, and repair errors that impair existing intended functionality of our website|
|17||To protect against malicious or illegal activity and prosecute those responsible|
|18||To verify and respond to consumer requests|
The Dealership may share your personal information with the following categories of service providers or third-party businesses depending on your transactions or interactions with the Dealership:
A. Vehicle OEMs
B. Financial Institutions
C. Lead providers
D. Product manufacturers/administrators
E. Government agencies
F. Promotional or other fulfillment vendors
G. Marketing support vendors
H. Transaction support vendors (e.g., check guaranty, rental car, payment processors)
The Dealership does NOT and will not sell your personal information in exchange for monetary consideration. However, we may share some of your information with third parties for other valuable consideration. First, if you were referred to the Dealership by a third-party website (such as Autotrader) that you visited or to which you provided your information or expressed interest in particular products or services, and if we happen to have a contract for that third-party to provide us with leads and referrals that resulted in you being referred to us, our contract with that party may require us to then report to them whether you ended up conducting business with the Dealership and the type of transaction. Second, the Dealership also allows IP addresses and other cookie-related data to be collected in an automated manner and managed by our marketing vendors in order to provide you with targeted ads based on what you appear to be interested in as a result of your activity online, both on our website and elsewhere. If you opt-out, you will still see ads but they will not be personalized based on your online activity. Other than these two exceptions, we do not and will not disclose your personal information to any third party in exchange for monetary or other valuable consideration.
Notice of Right to Opt-Out of Sale of Your Information
While the Dealership does not sell your personal information in exchange for money, we may share your personal information for other valuable consideration as described above. This is the only circumstance where your personal information may be disclosed in exchange for valuable consideration. You have the right to tell the Dealership NOT to sell your personal information. You have full and free right to opt-out of the Dealership’s disclosure of your personal information to any third parties where the disclosure constitutes a “sale” as defined by the California Consumer Privacy Act. You may exercise your right to opt-out without fear of discrimination for doing so. To opt-out of the Dealership’s selling of your information, meaning, the Dealership will not disclose your information to third parties for any monetary or other valuable consideration, you can do any of the following:
- Click here to be taken to an online opt-out submission form.
- Visit the Dealership’s website at: www.hoehnmotors.com/your-california-privacy-rights/. Click on “Do Not Sell My Personal Information” to be taken to an online submission form.
- Visit our Dealership location to request a paper opt-out submission form.
You can have an Authorized Agent submit a request on your behalf if you both come into a Dealership location and provide proof of identity with a driver’s license or passport and provide your consent via mail-in form for the Authorized Agent to complete your verifiable consumer request.
To submit an opt-out through use of an authorized agent you must provide that agent with written permission to submit an opt-out on your behalf. The Dealership maintains the right to deny any request from an authorized agent that does not submit sufficient proof that they have been authorized by you to act on your behalf.
In order to verify your identity and respond to your request, the Dealership will need you to provide your name, address, email, phone number, last 4 of your SSN, and your date of birth. In addition, our third-party identity verification provider may require your authorization to access your credit report.
The Dealership may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from vendors working on our behalf.
In the event the Dealership sells or transfers a particular portion of its business assets, consumer information may be one of the business assets transferred as part of the transaction. If substantially all of the assets of the Dealership are acquired, consumer information may be transferred as part of the acquisition.
Compliance with law/safety:
The Dealership may disclose specific personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect the users of our Website, the site itself, or the public.
- Compile data about site traffic to offer a better Website experience
- Understand and save visitor preferences for future visits
Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. However, there is currently no universal standard for sending and receiving DNT signals. Due to this lack of universal standard, it would be impossible for us to promise that we comply with all known and unknown DNT standards.
Therefore, we do not respond to DNT signals or other mechanisms that provide a choice regarding the collection of personal information about activities over time and across different Web sites or online services. If a universal standard for DNT becomes available, we may revisit our DNT Policy.
The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.
Children under the age of 16:
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.
How we protect the information that we collect:
The protection of the information that we collect about visitors to this Website is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:
- We keep automatically collected data and voluntarily collected data separate at all times.
- We use internal encryption on all data stores that house voluntarily captured data.
- We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
- We restrict access to private information to those who need such access in the course of their duties for us.
Your Rights as a California Consumer:
If you are a California resident, you have the following rights:
- Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
- Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
- Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
- Right to Opt-Out. The right to opt-out of the sale of your personal information to third parties;
- The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
- The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.
You can submit any of the above 4 types of consumer requests by any of the 2 options below:
- Submit an online request on our website at www.hoehnmotors.com/your-california-privacy-rights/
- Visit our Dealership to complete a paper form, which can be requested at the reception/front desk.
How we will verify that it is really you submitting the request:
When you submit a Right to Know, Right to Access, or Right to Delete consumer request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us. For example, we may need you to provide your name, address, email, phone number, last 4 digits of your SSN and your date of birth. In addition, our third-party identity verification provider will require your authorization to access your credit report. If your sole interaction with us was as a website visitor, then in order to verify your identify, we will need to ask you to provide your name, email, phone number, IP address, device ID, browser ID, and/or cookie ID.
Responding to your Right to Know, Right to Access, and Right to Delete requests
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days or 90 days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Responding to your consumer request to opt-out of the sale of your personal information
We will act upon a verifiable consumer request to opt-out within fifteen (15) days of its receipt. We will notify all third parties to whom we have sold personal information within 90 days of our receipt of your request that you have exercised your right to opt-out and instruct them not to further sell the information. We will notify you when this has been completed by mail or electronically, at your option.
A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.
If You Have an Authorized Agent:
You can have an Authorized Agent submit a request on your behalf if you both come into a California store and provide proof of identity with a driver’s license or passport and provide your consent via mail in form for the Authorized Agent to complete your verifiable consumer request.
Consumers With Disabilities
This policy is in a form that is accessible to consumers with disabilities. For more information on our website accessibility, click here
Questions About the Policy
**This policy was last updated June 23, 2020.