Privacy Policy

This is the United States privacy notice (“Privacy Notice”) of Retail Automotive, LLC. (“Retail Automotive” “we,” “us,” or “our”).

We at Retail Automotive recognize the importance of protecting you and your customers’ personally identifiable information. To demonstrate our commitment to maintaining the privacy of personally identifiable information, we have created this Privacy Notice to disclose our privacy practices for the personally identifiable information that we collect and receive through use of our products and services either offline or online. Our online operations include all websites (collectively, the “Websites”) and applications (“Apps”) of Retail Automotive.

By submitting personally identifiable information to us, you consent to Retail Automotive’s use and disclosure of personally identifiable information as set forth in this Privacy Notice. Your use and/or continued use of Retail Automotive products, services and websites signifies your consent that your and your customer’s information may be transferred to or stored on servers and processed outside the country of your residence. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected. If you do not agree with the terms of this Privacy Notice, please do not submit any information to Retail Automotive either offline or through our Apps or Websites.

Purpose of this Privacy Notice

We recognize the importance of protecting personally identifiable information (which includes name, address, telephone number, date of birth, e-mail address, credit or debit card information, drivers license number, and other contact information) that is provided to Retail Automotive (collectively, “PII”). The purpose of this Privacy Notice is to tell you how Retail Automotive strives to better allow you to serve your customers by safeguarding PII. This Privacy Notice sets forth our policies regarding the collection, use and disclosure of PII both through our online and offline operations.

Who is Covered under this Privacy Notice

This Privacy Notice is applicable to PII that is provided to Retail Automotive. This Privacy Notice applies to all of the products, services, Apps and Websites offered by Retail Automotive or its subsidiaries or affiliated companies.

What Personally Identifiable Information Retail Automotive Collects

The services that you choose will determine what information we collect from you and your customers. Here are some examples of information we may collect from you or your customers:

  • Name
  • Email Address
  • Home and/or Business Address
  • Telephone Numbers
  • Date of Birth
  • Payment Information (i.e. debit or credit card and expiration date)
  • Information from Driver’s License or other Government issued identification (e.g., a Passport)

Retail Automotive will also record non-personally identifiable information about vehicle rentals (e.g. where a vehicle is rented, where and when a vehicle is returned, payment arrangements, insurance preferences, gas consumption, mileage and other information related to the vehicle). This information is necessary in order to administer a loaner vehicle and/or process your transaction.

How Retail Automotive Collects Personally Identifiable Information

The PII we collect will be with express or implied consent. How we collect this information will depend on how you and your customers use our services. We may collect this information directly from you or your customer by telephone, fax, postal mail, email, at the customer suite, upon completion of an application or enrollment form, or through you or your customers use of our Websites, Apps or the Internet, or via dealership ecosystem technology integrations.

As a part of the Retail Automotive services, courtesy vehicles may be equipped with a device that allows Retail Automotive to use a global positioning satellite or other technology to track, locate and/or disable the vehicle and to provide such information and the capability to track vehicle assets.

How Personally Identifiable Information is Used and Disclosed by Retail Automotive

Usage

To provide the level of service we believe you expect from us, we may use you and your customer’s PII for the following purposes:

  • Provide and administer the services that you request, and communicate with you and your customers regarding such services and offerings;
  • Research, develop, manage, protect and improve our Websites and services;
  • Maintain and develop our service-oriented software and other business systems; and
  • Analyze data, or have a third party do so on our behalf.

We may also use non-personally identifiable information (including aggregated and anonymized PII) for other purposes.

Disclosing

We may disclose your PII to affiliated and non-affiliated organizations including, for example:

  • To entities that provide services on our behalf;
  • To any previously specified ecosystem partner;
  • To a credit card issuer;
  • To government, regulatory and law enforcement agencies where the disclosure is required or authorized by law, and otherwise as we believe is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our Websites and Apps properly, or to protect or defend our rights or the rights or well-being of our employees, users or others or if you are involved (or are suspected by governmental authorities or our security functions to be involved) in any illegal activity, even without a subpoena, warrant or court order.

We may also transfer or assign your PII to third parties as a result of or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.

 

Website and Internet Privacy

If you use our Apps or Websites or otherwise interact with us via the Internet, the following privacy-related policies also apply:

 

Website Tracking and the Use of Cookies and Other Technologies

If you use our Websites, certain information may be collected from your computer in the course of your use of our Websites. As with many websites, we may use both session based and persistent “cookies” and/or other technology (e.g., web bugs, e-mail bugs, clear GIFs, web beacons, tracker GIFs and “clickstream” data logs) in our Websites or in our electronic communications with you to enhance the functionality of our Websites and services. These technologies also make your transactions and other activities more convenient and efficient.

Cookies

“Cookies” are small amounts of data that a website can send to your web browser and store on your computer. It is our policy not to save sensitive data, such as passwords or credit card information, in cookies.

Most web browsers are initially set up to accept cookies. You have the option of disabling or refusing cookies at any time in your browser preferences. However, note that some parts of our Websites will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized preferences, and/or may have difficulty completing transactions.

The use of cookies is an industry standard, and as such, you will find that most major websites use them. Retail Automotive and Retail Automotive’s affiliates have two (2) primary uses for cookies. First, we use them to specify a user’s preferences. For example, we use cookies to store information about travel preferences and rental history. Second, we use cookies to track Website usage trends and patterns. This helps us understand our users’ needs better and improve areas of our Websites.

IP Addresses

An IP address is a unique number that is automatically assigned to your computer whenever you are using the Internet so that your computer can be identified on the Internet. This allows us to gather useful information and data about our customers’ use of the site.

Retail Automotive collects IP addresses for the purposes of: helping us diagnose problems with our main computers, for system administration, to report aggregated information to our business partners, and to audit the use of our Website. When users request Web pages from our Web Site, our Web servers log the user’s IP address. We do not normally link IP addresses to anything personally identifiable, which means that a user’s session will be logged, but the user will remain anonymous to us. For example, we collect and/or track the home server domain name, the type of computer, and the type of Web browser used by you to access this Web Site. Such collection and tracking information is gathered by us as you navigate through our Websites, and will be used by us for our business purposes only.

In select instances, we may use IP addresses to help us identify you when we feel it is necessary to enforce compliance with our Website Terms of Use or to protect our service, site, users or others.

Third Party Use of Technology

Third parties (including, but not limited to, software vendors, advertisers, ad servers, content providers, and services providers) may also use similar technologies by or through our Apps or Websites or through their own websites. In connection therewith, such entities may collect information about you and your usage activity on this and other websites. Retail Automotive does not control these third parties and is not responsible for the actions of our third party business partners. We encourage you to check their terms of use and privacy policies for such information.

We may use third-party servicing technology and service providers to serve ads on our behalf across the Internet and sometimes on our Apps or Websites. They may collect non-personally identifiable information about your visits to our Websites, and your interaction with our products and services. They may also use non-personally identifiable information about your visits to send you targeted advertisements for goods and services. This information is collected through the use of a pixel tag, or similar technology which is industry standard technology used by most major websites. If you would like more information about this practice and to know your choices about not having this non-personally identifiable information used, please visit http://www.networkadvertising.org/managing/opt_out.asp.

We may also share Website usage information about visitors to our Websites with selected third parties for the purpose of targeting our Internet banner advertisements on our Websites and other websites. To do this, we use web beacons and cookies provided by our third-party ad server on our Websites. In connection therewith, such third parties may have access to and use non-personalized information about your online usage activity. The use of advertising cookies and web beacons sent by such third-party Web servers is standard for commercial activity in the Internet industry.

Web Beacons

Web pages may contain an electronic file called a web beacon that allows a website to count users who have visited that page or to access certain cookies.

Visiting Third-Party Websites

Our Websites may contain links or references to third party websites. These websites are outside of our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over these third-party websites and our Privacy Notice does not apply to such websites. We encourage you to check the terms of use and privacy policies of such sites before disclosing any PII via such sites.

Occasionally when linking to a third-party website from our Websites, you may still see Retail Automotive affiliate logo or a Retail Automotive affiliate website frame. This is to provide you with a seamless experience when visiting our Websites. In these cases, you are no longer on our Websites but the third-party website, and therefore the information collection practices of the third party’s website may differ from Retail Automotive’s. The privacy notice of the third party site will govern how information collected from you is used by the owner of the website. You can always know what website you are on by checking the Uniform Resource Locator (URL) in the location bar within your browser.

How We Protect the Security of Personally Identifiable Information

The security of PII is important to us. We exercise reasonable care in implementing generally accepted standards of security to protect PII from loss, misuse and unauthorized access, disclosure, alteration or destruction, such as firewalls and Secure Socket Layer (SSL) encryption for some of your more sensitive PII. It is our policy to retain PII for as long as we believe appropriate for the purposes for which the PII was collected or as required by applicable law.

Unfortunately, “perfect security” does not exist on the Internet, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, we cannot guarantee that PII stored on our servers, or transmitted to or from a user, will be free from unauthorized access. By using our Apps or Websites and corresponding with us, you acknowledge that you understand and agree to assume these risks.

You are responsible for maintaining the strict confidentiality of your account passcode, membership numbers and pin numbers, and you will be responsible for any access to or use of our Websites by you or any person or entity using a passcode provided to you, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. In the event of the unauthorized use of your passcode, account, or membership number, or any other breach of security involving your information as it pertains to Retail Automotive, you agree to immediately notify us. It is your sole responsibility to ensure that you exit from your account at the end of each session, control the dissemination and use of your passcode, control access to and use of your account and membership number, and notify us when you desire to cancel your account on our Websites. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

In addition, some PII will be stored on your mobile device if you choose to use our App.  In this case, you are solely responsible for protecting the security and integrity of all such PII, and we are not responsible for any disclosure of PII or for any use of your account that someone may make using the App on your mobile device, even if such use is not authorized by you.

It is our policy that we will never request your sensitive PII, such as your credit card number, passcode, membership number or pin number, in an e-mail, text or on a website that is not located at the domain name used by Retail Automotive or an affiliate. If you receive an e-mail or other correspondence requesting that you provide any such information via e-mail or to a website that is not on such domain name, please do not provide such information, and report such request to our privacy officer at privacy@silvercar.com.

In the unlikely event that we believe that the security of PII in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your current e-mail address, we may notify you by e-mail.

 

How to Correct or Update Personally Identifiable Information that Retail Automotive Maintains

If you have provided PII to us, you can update the PII we hold about you. You play an active role in assisting Retail Automotive maintain the accuracy of your PII. Your prompt notification to us of any changes to your PII will assist us greatly in keeping your information accurate and up-to-date. If we don’t agree to make the changes, you may challenge our decision.

If you wish to contact us to access or correct your PII we have, or to inquire or provide feedback about our privacy practices, you can email us directly at privacy@silvercar.com.

We will respond to any access requests within 30 days of our receipt of the request.

For customer service issues, please email us at support@silvercar.com.

 

Applicable Law and Jurisdiction

This Privacy Notice will be governed by the laws of the State of Texas, without regard to its conflict of law principals. By providing any PII to us, you fully understand and unambiguously consent to the transfer of such PII to, and the collection and processing of such PII in, the United States and other countries or territories. You agree that any cause of action that may arise under this Privacy Notice will be commenced and be heard in the appropriate court in Travis County in the State of Texas. You agree to submit to the personal and exclusive jurisdiction and exclusive venue of the courts located within Travis County in the State of Texas or the United States District Court for the Western District of Texas.

 

Changes to this Privacy Notice

This Privacy Notice applies to all information we collect or receive, on or after the effective date of this Privacy Notice, from individuals who provide us with such information for the purpose of obtaining products and services from Retail Automotive or for using our Apps or Websites.

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice. If we materially change the way your personal information will be used, we notify you by way of either prominent posting on our Website(s), e-mail and/or mail. We encourage you to periodically review this Privacy Notice in order to keep apprised of any changes.

© 2017 Retail Automotive. All rights Reserved

Retail Automotive, LLC – February 13, 2017. –