Effective Date: May 30, 2021
Swift Auto Inc., Inc. and its subsidiaries and affiliated entities (collectively “Swift Auto Inc.,” “Company,” “we”, “us” or “our”) is primarily engaged in the business of digital marketing for the automotive industry that assists automotive retail dealers, automotive manufacturers and other third parties market and sell new and used vehicles and related products and services to Consumers through our programs for online Consumer referrals, dealer marketing products and services, email marketing, postal advertising and online advertising. The primary component of our business is the collection of Personal Information voluntarily provided by Consumers in order to refer the Consumer to Third Party vehicle dealers, vehicle manufacturers and other Third Parties offering products and services related to the automotive field and vehicle ownership, leasing or use.
“Consumer” means a natural person.
“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
“Third Party” means a person or entity not owned, operated or controlled by Swift Auto Inc. or any person or entity owned, operated or controlled by Swift Auto Inc..
II. Personal Information We Collect And How We Collect It
We collect Voluntarily-Provided Personal Information and Automatically-Collected Personal Information through the means described below.
Voluntarily-Provided Personal Information
“Voluntarily-Provided Personal Information” means Personal Information collected from a Consumer as a result of the Consumer providing that information voluntarily to Swift Auto Inc. or to a Third Party that sells or otherwise transfers the Personal Information to Swift Auto Inc.. Swift Auto Inc. collects Voluntarily-Provided Personal Information only when you make it available through your use of a feature or service offered by Swift Auto Inc. or a Third Party that requires the entry of Voluntarily-Provided Personal Information in order to provide the product or service you have requested. The types of Personal Information that a Consumer provides will depend on the nature of the submission for the products or services the Conumer is requesting, but typically will include the following:
• First and last names
• Mobile and landline phone numbers
• Email addresses
• Postal/street addresses
• Vehicle information
“Consumer Requests” means the submission of a specific request online from a Consumer that (i) is initiated by the Consumer; (ii) contains Voluntarily-Provided Personal Information furnished by the Consumer; and (iii) expresses the Consumer’s interest in (1) test driving, purchasing, leasing or receiving a price quote or other information regarding a new or used vehicle; or (2) other products and services offered by Third Parties. We collect Voluntarily-Provided Personal Information in Consumer Requests submitted by Consumers directly from Swift Auto Inc. Sites or that were submitted by Consumers through Third Parties and that were acquired by us from the Third Parties in order to provide the Consumer’s Voluntarily-Provided Personal Information to a vehicle dealer, vehicle manufacturer or other Third Party that can contact the Consumer directly and provide the Consumer the product, service or information that the Consumer has requested or in which the Consumer may have an interest or to send the Consumer advertising, marketing or content. Consumers may come to Swift Auto Inc. Sites to submit Consumer Requests directly by visiting an Swift Auto Inc. Site or may indirectly submit Consumer Requests to us by clicking on advertisements or links to Swift Auto Inc. Sites that Swift Auto Inc. places or has placed on Third Party sites, social media platforms or emails sent by Swift Auto Inc. or Third Parties.
We may conduct surveys of Consumers who have submitted Consumer Requests for marketing purposes and to better target our content to our audience or for the benefit of Third Parties with whom we do business. We also conduct follow-up surveys to confirm that a Consumer was contacted by the Third Parties to which the Consumer was referred for a vehicle or other product or service and to assess the Consumer’s experience with the Third Party.
Automatically-Collected Personal Information
“Automatically-Collected Personal Information” is Personal Information collected automatically through the use of Data Technologies without any action or entry of Personal Information by a Consumer when the Consumer visits or uses Swift Auto Inc. Sites or Third Party sites. Automatically-Collected Information does not identify a Consumer personally and cannot be linked back to a Consumer unless the Consumer decides at some point to identify the Consumer by submitting Voluntarily-Provided Information.
Swift Auto Inc. collects the following Automatically-Collected Personal Information from a Consumer’s desktop computer, laptop or handheld or mobile device when the Consumer visits an Swift Auto Inc. Site, even if the Consumer does not submit Voluntarily-Provided Personal Information:
Internet or Other Electronic Network Activity, including:
• Online identifier Internet Protocol address
• Online Behavioral Information
Automatically-Collected Personal Information generates “online behavioral information,” which is the collection of data online from a particular computer or device regarding Web viewing behaviors over time, and across non-affiliated Web sites, for the purpose of using such data to predict visitor preferences or interests. Online behavioral information includes browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Online behavioral information may be used to generate “interest-based advertising,” also called “online behavioral advertising,” which is advertising that is customized and targeted based on predictions generated over time from a Consumer’s visits across different websites, devices and mobile applications.
“Data Technologies” are technologies, such as cookies, local shared objects, pixels and web beacons, used to collect information about your actions and your visit to Swift Auto Inc. Sites or Third Party sites, and includes all current and similar future technologies, including anonymous advertising identifications used on mobile devices and otherwise in a manner similar to cookies. One or more Data Technologies may be used on the Swift Auto Inc. Sites and other websites and mobile applications (that may not be the Swift Auto Inc. Sites) by Swift Auto Inc. or Third Parties. Data Technologies may be used to collect information about web pages you visited and visit and to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications. Swift Auto Inc. places or “sets” Swift Auto Inc. cookies on a Consumer’s computer or device when the Consumer visits Swift Auto Inc. Sites. We may also set cookies on a Consumer’s computer or device on behalf of Third Parties authorized by Swift Auto Inc. or may enable certain Third Parties to set their own cookies on the Consumer’s computer or device.
Swift Auto Inc. uses Third Party tracking services for which Swift Auto Inc. sets cookies on your computer or enables the Third Party tracking services to set cookies on your computer or device, when you visit Swift Auto Inc. Sites. These cookies track visits, page views and click stream behavior. Third Party tracking services report this data to Swift Auto Inc. in aggregated form so Swift Auto Inc. can better understand our users and improve the Swift Auto Inc. Sites. Swift Auto Inc. shares such anonymous, aggregated information obtained from these cookies with our advertisers and other Third Parties.
Anytime you visit Swift Auto Inc. Sites, we collect the Internet Protocol (“IP”) address to help diagnose problems with our servers, administer the Swift Auto Inc. Sites and track site usage statistics. A Consumer’s IP address may vary each time the Consumer visits, or it may be the same, depending on how the Consumer accesses the Internet. We also collect information on whether the Consumer reached an Swift Auto Inc. Site by clicking on a link or advertisement on a Third Party site, which helps us to maximize our Internet exposure, and to understand the interests of our users. We also collect information on the Consumer’s ISP or mobile carrier and the type of handheld or mobile device the Consumer used. All of this information is collected and used only in the aggregate; that is, it is entered into our database, where we can use it to generate overall reports on our visitors, but not reports about individual visitors.
Swift Auto Inc. uses Google Analytics to collect information through Data Technologies. This data is collected on an anonymized basis and is aggregated, but may include or be associated with other non-Personal Information or with Voluntarily-Provided Personal Information. Our primary goal in collecting user information is to enhance a Consumer’s experience on Swift Auto Inc. Sites. Google Analytics is a web analytics tool provided by Google, Inc. (“Google”) that helps website owners understand how visitors engage with their website. We can view a variety of reports about how visitors interact with Swift Auto Inc. Sites so we can improve the Swift Auto Inc. Sites. Google uses first party cookies and IP addresses, and it reports website trends without identifying individual visitors. For more information related to Google Analytics, click here.
“Advertising Networks” are Third Parties that serve interest-based advertising to Consumers and generate statistics and metrics related to the delivery of interest-based advertising. Swift Auto Inc. engages with Advertising Networks that may use information collected through a variety of Data Technologies to provide customization, auditing, research and reporting for us, our affiliates and other advertisers. This data collection takes place both on the Swift Auto Inc. Sites and on Third-Party’s websites and mobile applications. This process allows Swift Auto Inc. and Third Parties to deliver interest-based advertising, enhance marketing programs and help track the effectiveness of such efforts. Advertising Networks also may use this information for determining or predicting the characteristics and preferences of their respective advertising audiences and measuring the effectiveness of their advertising.
Mobile-specific information we may collect
Swift Auto Inc. collects information from a Consumer’s mobile devices such as hardware IDs and device type, the request type, your carrier, the Consumer’s carrier user ID, and the content of the Consumer’s request, which does not by itself identify the Consumer, though it may be unique or consist of or contain information that the Consumer may consider personal.
Trackable Telephone Numbers
We publish uniquely-generated, trackable toll-free phone numbers for many of the dealers that list vehicles for sale on the Swift Auto Inc. Sites or in advertisements posted on Swift Auto Inc. Sites. If a Consumer dials one of these phone numbers, Swift Auto Inc. or a service provider operating on Swift Auto Inc.’s behalf may record the date, time and length of the Consumer’s call and the phone number from which the call originated.
“Geolocation Information” is physical location information that is sufficiently precise to allow us to locate a computer or device, including data such as the Consumer’s computer or mobile device’s physical location and may include GPS-based, WiFi-based or cell-based location information. When a Consumer downloads or uses the Swift Auto Inc. Sites, we may collect Geolocation Information. We may use Geolocation Information and provide it to Third Parties to provide the Consumer with content and services that are relevant to a particular location, such as advertising, search results, vehicle dealers in the area, and directions and to customize marketing to the Consumer for what is available in the Consumer’s area or close proximity. This Geolocation Information may reveal a Consumer’s actual location, such as GPS data, or it may not, such as when the Consumer submits a partial address to look at a map of the area.
Combined or Appended Personal Information and Personal Information from Other Sources
We may combine Voluntarily-Provided Information or Automatically-Collected Information for a Consumer with other information that is voluntarily provided by Consumers or automatically collected by us or Third Parties. The combined information may include information about the Consumer’s use of the Swift Auto Inc. Sites; use of other websites, devices and mobile applications; interactions or transactions with vehicle dealers; interests and preferences; and other information about the Consumer or the Consumer’s household.
When we refer a Consumer to a vehicle dealer we may obtain Personal Information that we did not originally provide to the vehicle dealer in a Consumer Request from sales matching information that we acquire from the vehicle dealers or other Third Parties. Sales matching information may include the Consumer’s name, postal address, phone number, and email address; the make, model and trim of the vehicle purchased; the purchase price; and the purchase date.
III. How We Use and Share Personal Information We Collect
Internal Use by Swift Auto Inc.
Personal Information collected by Swift Auto Inc. is used internally by Swift Auto Inc. to improve the content or layout of the Swift Auto Inc. Sites; improve user experience on Swift Auto Inc. Sites; provide services requested by users of the Swift Auto Inc. Sites; respond to questions, requests or complaints from Consumers; request feedback from Consumers; develop new products and services; evaluate the effectiveness of the Swift Auto Inc. Sites; and to contact Consumers for marketing purposes, including through email and SMS/text marketing.
When a Consumer provides the Consumer’s email address as Voluntarily-Provided Information, we automatically include the Consumer’s name and email address and other Voluntarily-Provided Information in our marketing database to receive email communications from us that contain marketing, advertisements and content. We may collect information regarding the effectiveness of our email and other communications with the Consumer.
Third Parties To Which We Sell or Otherwise Share, Transfer or Disclose Your Personal Information
We may sell, disclose, or transfer Personal Information to Third Parties under the following circumstances:
• To Third Parties, including vehicle dealers, that can provide the Consumer with the products, services or information that the Consumer has requested;
• To our advertiser clients to assess the effectiveness of advertising campaigns we have provided for them;
• To other digital marketing services companies that purchase Consumer Requests from Swift Auto Inc. for sale, disclosure or transfer to such Third Party’s customers;
• To service providers that may provide services or perform functions on our behalf;
• To Third Party vendors and suppliers of products and services in which the Consumer has expressed an interest or about which a Consumer has requested information;
• To Third Parties that may wish to send the Consumer email, postal mail or SMS/text messages containing advertising or marketing materials regarding products or services that the Consumer may find of interest; and
• To enforce our rights or as required by law or order of a court or government agency.
We may aggregate Personal Information from all of our users and provide that information in the aggregate to vehicle dealers, vehicle manufacturers, advertisers and other Third Parties for marketing and promotional purposes. However, if we do so, that information will be anonymized so as not to be personally-identifiable.
“Service Providers” are Third Parties that have contracted with Swift Auto Inc. to provide services to or on behalf of Swift Auto Inc. that may involve access to or processing of Personal Information collected by Swift Auto Inc.. We may allow Third Party Service Providers (such as market research firms, marketing services providers, advertising agencies and information processors) access to your Personal Information to perform services on our behalf.
Swift Auto Inc. will cooperate with legal authorities, and may in some circumstances be required to disclose Personal Information in response to requests from law enforcement or other governmental agencies, or in response to a subpoena or other legal process. We can also share information about you if we believe we must in order to (i) prevent a violation of the law; (ii) protect or defend our interests and the legal rights or property of Swift Auto Inc. and our affiliates; (iii) protect the rights, interests, safety and security of users of the Swift Auto Inc. Sites or members of the public; (iv) protect against fraud or for risk management purposes; or (v) comply with prudent legal practice as we may determine, and with applicable law or legal process. We may also share Personal Information in the course of legal proceedings if we are legally required to do so, if we reasonably believe that doing so may mitigate our liability, or if doing so will assist us in enforcing our legal rights.
Business Transfers and Other Transactions
Information about our users and the Swift Auto Inc. Sites is a business asset of Swift Auto Inc.. As we continue to develop our business, we might sell or buy websites, subsidiaries or business units. In such transactions, Personal Information generally is one of the transferred business assets. Also, in the event that Swift Auto Inc. or substantially all of its assets are acquired, Personal Information will of course be one of the transferred assets. In addition, Personal Information will be disclosed as part of any creation of a separate business to provide an Swift Auto Inc. Site, or to provide other services or fulfill products; debt financing, sale or pledge of company assets, or insolvency, bankruptcy or receivership. We will make reasonable efforts to ensure that the acquirer of our users’ Personal Information respects the provisions of this Policy, although this may not be possible in certain legal settings (such as bankruptcy).
IV. Your Choices Regarding Your Personal Information
You may limit and control the Personal Information collected by us in a number of ways.
Voluntarily-Provided Personal Information
You are not required to provide any Voluntarily-Provided Personal Information to visit or use the Swift Auto Inc. Sites. You may elect to not provide Voluntarily-Provided Personal Information for any purpose. However, in doing so, you may not be able to use all features of the Swift Auto Inc. Sites. For example, if you do not provide the Voluntarily-Provided Information required to submit a Consumer Request, you will not be able to submit Consumer Requests, and Swift Auto Inc. and vehicle sellers, manufacturers and other third party service and product providers will not be able to contact you to provide you the products, services or information in which you may be interested. You may also choose not to participate in surveys.
Opting Out of Email Marketing
In addition, we provide you the opportunity to indicate your preferences as to what types of offerings of products or services you wish to receive from third parties or, subject to the exceptions below, to opt-out of disclosures to those third parties altogether. You may update your preferences at any time by contacting us at consumercare@Swift Auto Inc..com. Those third parties who receive your Personal Information prior to your opt-out will remain able to send you communications, subject to their privacy policies and practices. To opt-out from receiving third party emails, you must contact those third parties directly.
Even if a Consumer decides not to receive offers or other product or service information, Swift Auto Inc. and the dealers, manufacturers, other product and services providers, fulfillment third-parties and other referral services with which Swift Auto Inc. has relationships, may use a phone number, mailing address or email address that the Consumer has provided to contact the Consumer regarding a Consumer Request that the Consumer submitted. Additionally, phone numbers and email addresses may be used to conduct customer surveys regarding individual experiences with Swift Auto Inc., dealers, or other product and services providers. Phone numbers and email addresses are made available only to Swift Auto Inc., its affiliates and dealers, manufacturers, other referral services, fulfillment third parties and other referral services who receive a Consumer Request.
If a Consumer requests to opt-out of receiving emails from us and then subsequently submits a Consumer Request (either directly or submitted through a Third-Party and are referred to us), we will reinstate the relationship with us and we will the Consumer’s Personal Information as set forth herein, unless the Consumer subsequently requests to opt-out. Each time a Consumer submits a Consumer Request, this process will restart.
Automatically-Collected Personal Information
Opting Out of Data Technologies.
Consumers have a number of choices regarding certain Data Technologies.
Most web browsers automatically accept cookies, but a Consumer can usually modify the Consumer’s browser’s setting to decline cookies if the Consumer prefers. Consumers have the ability to accept or decline cookies by modifying the Consumer’s browser settings, and our websites are viewable even if the Consumer disables the cookie function on the Consumer’s browser. However, if a Consumer disables cookies, note that certain features may not function properly or at all as a result, and some advanced and customized features or offerings will not be available to the Consumer, including personalization features.
If a Consumer prefers not to accept cookies, the Consumer should consult documentation for the Consumer’s browser or device for more information. Most browsers will explain how to view and disable cookies under the help portion of the toolbar or notify the Consumer when the Consumer receives a new cookie. Use of third party cookies is subject to the privacy policies and opt-out procedures of these third parties and not Swift Auto Inc.’s policy and procedures. Please click here www.networkadvertising.org in order to learn more about the data and information collection and use practices of some of the third parties for which we set cookies on Swift Auto Inc. Websites or for which we enable to set their own cookies. Please click here http://www.networkadvertising.org/managing/opt_out.asp in order to learn more about the “opt-out” procedures of some of these third parties. At times, not all of the third parties for which we set cookies on Swift Auto Inc. Websites or for which we enable to set their own cookies are included in the preceding link to opt-out from these cookies. Should you wish to opt-out of these cookies, a Consumer will need to access the third party’s website to determine their opt-out procedure.
A Consumer may also render some web beacons unusable by rejecting their associated cookies and disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or opting out at www.evidon.com or the website of the technology provider.
A Consumer may refuse to accept a cookie from us on mobile devices by adjusting the use of advertising identifiers through the settings on the Consumer’s computer or device. A Consumer’s mobile device may also have settings that allow the Consumer to prevent sharing Geolocation Information with us. Consumer’s should consult their mobile device’s settings or help documentation for more information about exercising these options.
Consumers can opt out of delivery of interest-based advertising to the Consumer by multiple companies by visiting www.aboutads.info/choices, www.networkadvertising.org/managing/opt_out.asp and www.evidon.com. Please note that even if a Consumer opts out, the Consumer will continue to receive advertisements, but the advertisements will not be tailored to the Consumer’s specific interests.
To control use of flash cookies, visit Adobe’s website at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html for tools to control and disable flash cookies. If a Consumer uses Firefox, the Consumer can also obtain an add-on to detect and delete flash cookies by visiting https://addons.mozilla.org/en-US/firefox/addon/betterprivacy/ and clicking “Add to Firefox.”
Swift Auto Inc. uses Google Analytics, which helps Swift Auto Inc. better understand its audience and target communications and advertisements based on demographic or interest-based information. Consumers may learn more about opting out of certain Google advertising initiatives and to install Google Analytics Opt-out Browser Add-on here. Please note that Consumers may still receive advertising even after opting out, but that advertising may not be tailored to the Consumer or the Consumer’s interests.
Trackable Telephone Numbers
If a Consumer does not want to have information collected through the Consumer’s use of a trackable telephone number, the Consumer may choose to not call the vehicle dealer to which the number is assigned by using the trackable phone number displayed on Swift Auto Inc. Sites.
Response to Do Not Track Signals
Children and Minors
Swift Auto Inc. Sites are not directed to minors under the age of 16, and we do not intend, and Swift Auto Inc. Sites are not designed, to collect Personal Information from minors under the age of 16, and we do not knowingly collect Personal Information from minors under age 16. If you are under 16 years old, you should not provide Personal Information to any Swift Auto Inc. Website. Should we obtain actual knowledge that we have collected or received personal information from a minor under the age of 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 age 16, please contact our Consumer Care Department as specified in the ” Contact Us” section below.
V. Retention and Security of Personal Information
Swift Auto Inc. has implemented commercially reasonable administrative, technical, personnel, and physical security measures designed to help protect the Personal Information stored in our systems against loss, theft and unauthorized use, disclosure or modification. For example, we limit access to Personal Information to employees who we believe reasonably need to come into access that information. We also employ processes (such as password hashing, login auditing, and idle session termination) to protect against unauthorized access to Personal Information. Technical measures also include use of firewall protection. We use TLS (Transport Layer Security) encryption technology to protect Personal Information during transmission.
Some of our service providers may store information in servers hosted in countries outside the United States. As such, Personal Information may be subject to the laws of other countries, where the data protection and other laws may not be as comprehensive as those in the United States. Personal Information may be disclosed in response to inquiries or requests from government authorities in the countries in which we operate.
Although Swift Auto Inc. has endeavored to create a secure and reliable networks, servers and databases that we operate or that are operated on our behalf, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security and cannot guarantee protection of all information against interception, misappropriation, misuse, or alteration, or that information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.
A Consumer’s Personal Information is collected by a Third Party:
• When the Consumer initially provides the Third Party the Consumer’s Personal Information on a Third Party site and not on an Swift Auto Inc. site.
• When a Consumer clicks on a link to a Third Party site from an Swift Auto Inc. Site, including clicking on an Third Party advertisement placed on an Swift Auto Inc. Site, the Consumer will leave the Swift Auto Inc. Site the Consumer was visiting and be redirected to the Third Party site.
• When we sell or otherwise transfer or disclose the Consumer’s Personal Information to the Third Party, for example, when we sell a Consumer Request to a vehicle dealer to contact the Consumer regarding the information, product or services the Consumer requested.
• When Swift Auto Inc. authorizes a Third Party to place the Third Party’s cookie or other Data Technology on an Swift Auto Inc. site.
• When Swift Auto Inc. authorizes a Third Party to offer their products and services on Swift Auto Inc. Sites through use of a “framed” format, where the Swift Auto Inc. border will surround the pages served by the Third Party, or by directly linking the user to the Third Party’s sites. In either case, the Third Party is prominently identified.
VII. Changes or Revisions to This Policy
IX. Updating or Correcting Your Personal Information.
X. Revocation of TCPA Consent and Opting Out of Automated Calls and Text Messaging
You may revoke your consent and opt-out from receiving automated calls or text messages at any time. You may opt-out of text messages by replying STOP to any text message you receive or follow other opt-out instructions included with the text message. You acknowledge and agree that you may receive a text message confirming your opt-out. To opt-out of automated telephone calls from Swift Auto Inc. (but not text messages), contact our ConsumerCare Department as provided below under “Contact Us.” To opt-out of receiving automated telephone calls or texts from third parties, please contact the third party directly. Please note that if you opt out of automated calls, Swift Auto Inc. and any third parties reserve the right to make non-automated calls to you relating to any transaction or your relationship with Swift Auto Inc. or the third parties. To obtain assistance from our ConsumerCare Department with respect to text messaging, contact our ConsumerCare Department as provided below under “Contact Us.”
XI. Contact Us
If you have any questions or need help or assistance regarding privacy, security, opting-out of email or text communications, your email and marketing preferences, or understanding how your Personal Information is being used, please contact our Consumer Care Department by email at consumercare@Swift Auto Inc..com or by calling via our toll-free number at (800) 267-2015.
Notice to California Residents—Your California Privacy Rights
Right to Request and Obtain Information Regarding Personal Information. The CCPA entitles California residents to request information about the consumer’s Personal Information collected by the business in the 12 months preceding the request and concerning the categories of Personal Information; the categories of sources from which the Personal Information was collected; the business or commercial purpose for collecting or selling the Personal Information; the categories of third parties with whom the business shares Personal Information; and the specific pieces of Personal Information that a business has collected about the individual consumer. If the business also sells or discloses the Personal Information for a business purpose, in addition to the foregoing information, the consumer has the right to obtain the categories of Personal Information that the business sold about the consumer in the 12 months preceding the request and the categories of their parties to whom the personal information was sold (by category or categories of Personal Information for each third party to whom the Personal Information was sold); and the categories of Personal Information that the business disclosed about the consumer for a business purpose. These requests for information must be made by a “verifiable request” (as defined by the CCPA and the rules and regulations thereunder). California residents who wish to request the foregoing information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How to Contact Us and Submit Requests” section below.
Right to Have Personal Information Deleted. The CCPA entitles California residents to request that a business delete all Personal Information about the consumer that the business has collected, subject to certain exceptions set forth in the CCPA. These requests for information must be made by a “verifiable request” (as defined by the CCPA and the rules and regulations thereunder). California residents who wish to request the foregoing information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How to Contact Us and Submit Requests” section below.
Right to Opt-out From the Sale of Your Personal Information to Third Parties. The CCPA entitles California residents to direct that a business that sells Personal Information about the consumer to third parties not to sell the consumer’s Personal Information. California residents who wish to exercise this right in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How to Contact Us and Submit Requests” section below. In addition, consumers may exercise this opt-out right by accessing the internet web page that we have provided at “Do Not Sell My Personal Information.”
No Discrimination Against Persons Exercising Rights Under the CCPA. Swift Auto Inc. will not discriminate against any Consumer because the Consumer exercised any of the Consumer’s rights under the CCPA. Unless permitted by applicable law, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We do not currently offer any financial incentives with respect to the collection of your Personal Information. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Information Regarding Collection and Sale of Personal Information and Requests. The following information regarding Personal Information collected and sold by Swift Auto Inc. and Consumer requests can be accessed by clicking here:
• A list of the categories of Personal Information collected by Swift Auto Inc. during the preceding 12 months and for each such category (i) the categories of sources from which the Personal Information was collected; (ii) the business or commercial purposes for which the Personal Information was collected; and (iii) the categories of Third Parties with whom the Personal Information was shared.
• We sold or disclosed Personal Information to Third Parties for a business or commercial purpose during the preceding 12 months. The Twelve-Month Personal Information Categories Lists contain a list categories of Personal Information sold or disclosed for a business or commercial purpose during the preceding 12 months.
• Metrics for the preceding 12 months regarding the following:
o The number of requests to know about Personal Information collected that We received, compiled with in whole or in party, and denied.
o The number of requests to delete Personal Information that We received, compiled with in whole or in party, and denied.
o The number of requests to opt-out from the sale of Personal Information that We received, compiled with in whole or in party, and denied.
o The median number of days within which We substantively responded to requests to know, requests to delete and requests to opt-out.
Other California Privacy Rights Right to Request Information Regarding Sharing of Personal Information With Third Parties for Direct Marketing Purposes. The California “Shine the Light Law” (Cal. Civil Code Section 1798.83) entitles California residents to request information concerning whether a business has disclosed certain Personal Information about the consumer during the immediately preceding calendar year to any third parties for the third parties’ direct marketing purposes. California residents who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact our Consumer Care Department as specified in the “Contacting Us Regarding Your California Privacy Rights” section below.
How to Contact Us and Submit Requests to Exercise Your California Privacy Rights
Contacting Us Regarding California Privacy Rights
If you have any questions regarding your California privacy rights (e.g., rights to opt-out of the sale of your Personal Information to third parties, your right to know about Personal Information we collect about you, your rights to have Personal Information deleted or to update Personal Information we have about you), please contact our Consumer Care Department by email at consumercare@Swift Auto Inc..com or by calling via our toll-free number at (800) 267-2015.
Submission of Requests To Exercise Privacy Rights (eligible California residents only)
Requests to Know About Personal Information and Requests to Delete Personal Information
To exercise your right to know about Personal Information we collect about you or to have us delete your Personal Information, you must submit a verifiable request to our Consumer Care Department by email at consumercare@Swift Auto Inc..com, by calling via our toll-free number at (800) 267-2015, or by accessing our request form online at https://Swift Auto Inc..truyo.com/consumer/request_form.
A verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• In the case of a request to delete your Personal Information, a two-step process will be used whereby you must first clearly submit the request to delete, and then second, separately confirm that you want your Personal Information deleted.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Within ten (10) days of receiving a request to know or a request to delete Personal Information, we will confirm receipt and provide information about Swift Auto Inc.’s verification procedures and processing of the request. We will make our best effort to respond to a verifiable consumer request regarding your right to know or to delete your personal information within 45 days of receipt of a request. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will maintain records of consumer requests made pursuant to CCPA as well as our response to said requests for a period of at least twenty-four (24) months.
We will deliver our written response to a request to know information by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
You may only make a verifiable consumer request for access Personal Information twice within a 12-month period.
Requests to Opt-Out From the Sale of Personal Information
To exercise your right to opt-out from the sale of your Personal Information, you must submit a request to our Consumer Care Department by email at consumercare@Swift Auto Inc..com, by calling via our toll-free number at (800) 267-2015, or by accessing our request form online at https://Swift Auto Inc..truyo.com/consumer/request_form.
We will act upon your request to opt-out from the sale of your Personal Information within fifteen (15) days after receipt of your request, and will notify all third parties to whom your Personal Information was sold, shared, or disclosed within the ninety (90) days prior to receipt of your request that you have exercised your right to opt-out and instruct these third parties to not to further sell, share or disclose your Personal Information. Upon completing these third-party notifications, we will notify you that these third-party notifications have been completed.
Once you make an opt-out request, if we wish to ask you to reauthorize sales of your Personal Information, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Opting-In To Sale of Personal Information
A Consumer who has exercised the Consumer’s right to opt-out from the sale of the Consumer’s Personal Information, may change the Consumer’s mind and opt back in to personal information sales at any time by submitting a request to our Consumer Care Department by email at consumercare@Swift Auto Inc..com or by calling via our toll-free number at (800) 267-2015. A two-step process will be used whereby the Consumer must first clearly submit the request to opt-in, and then second, separately confirm the Consumer’s choice to opt-in.
We do not charge a fee to process or respond to requests unless they are 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.
Requests made on behalf of California Consumer (i.e., Authorized Agents, Power of Attorney, on Behalf of Minors)
Only the Consumer, or an Authorized Agent that the Consumer has authorized to act on the Consumer’s behalf, may make requests related to the Consumer’s Personal Information. If a request is submitted by an Authorized Agent on your behalf, we will require that you provide the Authorized Agent written permission to do so and verify your own identity directly. The Authorized Agent will be required to submit proof that the Authorized Agent has been authorized by you to act on your behalf. The Authorized Agent must also be registered as an Authorized Agent for CCPA matters with the California Secretary of State.
Requests to exercise your rights under the CCPA require verification of your identity, and may be made only by you, your parent or guardian (if you are under 18 years of age), a person to whom you have given power of attorney pursuant to California Probate Code sections 4000 to 4465, or an authorized agent that is registered with the California Secretary of State. If a parent or guardian is submitting a request on behalf of a minor, the parent or guardian must submit proof that they are the parent or guardian of the subject consumer, and must verify the consumer’s identity (e.g., provide a notarized letter). If someone with power of attorney is making a request on behalf of a consumer, they must verify the individual consumer’s identity and submit documentation establishing the power of attorney. If an authorized agent is submitting a request on behalf of a consumer, they must verify the individual consumer’s identity, provide written permission from the consumer to submit the request on the consumer’s behalf, and submit documentation establishing registration with the Secretary of State. If Swift Auto Inc. cannot verify that the requestor is authorized by the consumer to act on such consumer’s behalf, Swift Auto Inc. is not obligated to provide information or respond to the request. If you have any questions about making a request on behalf of another consumer, please contact our Consumer Care Department by calling via our toll-free number at email@example.com | +66 83 532 0070