USA Drives Group Privacy Policy

Last Updated: Feb 10, 2020

Your privacy is important to USA Drives Ltd., and its corporate affiliates (collectively, “USA Drives Group” and each a “USA Drives Company”). This Privacy Policy explains how USA Drives Group collects, uses, discloses and retains personal information, including information collected by USA Drives Group through websites and telephone calls and when providing products or services.

1. Your Consent

By providing a USA Drives Company with your personal information, you consent to the collection, use, disclosure and retention of that information by the USA Drives Company and other members of the USA Drives Group in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to USA Drives Group, but then you might not be able to proceed with your intended interactions or transactions with USA Drives Group or otherwise receive the full benefit of USA Drives Group’s products and services.

2. Personal Information

In this Privacy Policy, unless otherwise specified in this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.

3. Information That USA Drives Group Collects

(a) Information You Provide

You may be asked to voluntarily give your personal information to a USA Drives Company when you interact, orally, in writing or by electronic transmission, with the USA Drives Company, including when you apply for an account or membership, subscribe to a newsletter, register to receive information, apply or register for or order a product or service offered by a USA Drives Company or use a product or service provided by a USA Drives Company. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with the USA Drives Company or otherwise receive the full benefit of the desired product or service. Telephone calls between you and the USA Drives Company will be recorded to ensure accuracy and quality assurance, and may be disclosed to third parties to verify the USA Drives Company is compliant with its contractual obligations to third parties. You can choose not to have the telephone call recorded, and communicate by writing or electronic transmission.

(b) Automated Collection

A USA Drives Company may automatically collect certain information regarding your use of the USA Drives Company’s website or online service, such as the dates and times that you access the website or online service, the browsers, operating systems, software and devices that you use to access the website or online service and details of your use of the website or online service.

A USA Drives Company’s websites, online services, email messages and advertisements may use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists the USA Drives Company to improve its products, services, customer communications and advertising and to prevent fraud. A USA Drives Company may use information that it collects through technological means to recognize you as a user of the USA Drives Company’s websites or online services, to facilitate and improve your use of the USA Drives Company’s websites or online services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website or online service. More information about cookies used for interest-based advertising is set out in section 4. (c) below.

Much of the information that is automatically collected by technological means is non-personal information (because the information does not identify you), and USA Drives Group will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

(c) Credit Reports

When you apply or register for, order or use certain products or services from a USA Drives Company (e.g. a referral to a car dealer for a financed car purchase), the USA Drives Company may obtain your credit score and related information from a credit reporting agency to process or fulfill the transaction. The USA Drives Company may continue to periodically obtain your credit score and related information from a credit reporting agency to update your confidential profile for use by USA Drives Group as set out in this Privacy Policy.

Upon your request we will inform you if we have ordered such a report or reports, and will give you the name and address of the credit reporting agency that furnished the report or reports.

You also acknowledge and agree that any dealers or other persons or organizations to which we have disclosed your personal information in accordance with this Privacy Policy, may request a credit report for any legitimate purpose associated with your application for credit, extending credit, modifying the terms of your credit agreement, collection on your account, or similar service or product.

(d) Information Regarding Referred Transactions

If a USA Drives Company refers you to an independent business (e.g. a car dealer, lender or credit card company) for a proposed transaction (e.g. a car purchase, loan or credit card), then the USA Drives Company may collect from that independent business information regarding the transaction to update your confidential profile for use by USA Drives Group as set out in this Privacy Policy.

4. How USA Drives Group Uses Personal Information

(a) General

Each USA Drives Company uses your personal information collected by the USA Drives Company for purposes relating to or arising from your relationship and transactions with the USA Drives Company and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

  • to administer your relationship with USA Drives Group, including to create and manage your account or membership with USA Drives Group and to contact and correspond with you regarding those matters;
  • to facilitate your interactions and transactions with USA Drives Group, including to process your applications, requests, orders and payments;
  • to provide products and services to you;
  • to process and respond to your inquiries, requests and other communications;
  • to provide you with information (including by email and other electronic messages) regarding USA Drives Group and its products and services and related products and services offered by other businesses, to the extent permitted by applicable law;
  • to administer and facilitate your participation in contests and promotions related to USA Drives Group;
  • to maintain, protect and improve USA Drives Group’s products and services and to develop new products and services;
  • to protect and enforce USA Drives Group’s legal rights, interests and remedies and to protect the business, operations and customers of USA Drives Group or other persons; and
  • to assist other USA Drives Companies to collect, use, disclose and retain your personal information in accordance with this Privacy Policy.

(b) USA Drives Group

A USA Drives Company may share your personal information with the entire USA Drives Group, and the USA Drives Group may develop, maintain and share a confidential profile for you for use by each USA Drives Company to provide information, products and services to you, to facilitate your dealings with each USA Drives Company and as otherwise set out in this Privacy Policy.

(c) Interest-Based Advertising

The USA Drives Group may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google and Facebook) to display advertisements on third party websites and social media sites visited by users of a USA Drives Group website. Advertising vendors (such as Google and Facebook) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses USA Drives Group websites – to display ads based on the computer’s past access to USA Drives Group websites. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page.

5. How USA Drives Group Discloses Personal Information

(a) General

Each USA Drives Company discloses your personal information for purposes relating to or arising from your relationship and transactions with the USA Drives Company and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents

A USA Drives Company may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with the USA Drives Company.

(c) Referred Transactions

If a USA Drives Company refers you to an independent business (e.g. a car dealer, lender or credit card company) for a proposed transaction (e.g. a car purchase, loan or credit card application), then the USA Drives Company may disclose your personal information (including your credit score and related information) to the independent business to facilitate the proposed transaction. USA Drives Group has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the independent business, and the use, disclosure and retention of the disclosed information by the independent business is not subject to this Privacy Policy.

(d) Suppliers and Service Providers

A USA Drives Company may disclose your personal information to its suppliers and service providers (including fraud prevention services and payment processors) to assist the USA Drives Company in the provision of information, products and services to you, to provide services to the USA Drives Company, to assist the USA Drives Company to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(e) Law Enforcement/Legal Disclosures

A USA Drives Company may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. A USA Drives Company may disclose your personal information to law enforcement agencies or other independent organizations if the USA Drives Company reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if the USA Drives Company reasonably believes the disclosure is necessary or appropriate to protect and enforce the USA Drives Company’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of the USA Drives Company or other persons (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of the USA Drives Company’s products or services). A USA Drives Company has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom the USA Drives Company discloses the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

(f) Business Transactions

A USA Drives Company may disclose your personal information in connection with a proposed or actual business transaction in which the USA Drives Company is involved (such as a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of the USA Drives Company’s business or assets), but the USA Drives Company will require the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

6. Location of Personal Information

USA Drives Group and its service providers may process, store and use your personal information at facilities in various countries, including the USA, Canada and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to a USA Drives Company, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.

7. Retention of Personal Information

USA Drives Group retains your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with USA Drives Group’s legal obligations or enforce or protect USA Drives Group’s legal rights, or a longer period required or permitted by applicable law. USA Drives Group will delete or dispose of your personal information when USA Drives Group is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.

8. Protection of Personal Information

USA Drives Group uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in USA Drives Group’s possession or under USA Drives Group’s control to help protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks cannot be eliminated and USA Drives Group cannot guarantee that your personal information will not be used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

9. Accuracy and Access to Personal Information

USA Drives Group will rely on you to ensure that your personal information that you provide to USA Drives Group is as accurate, complete and up to date as necessary for the purposes for which USA Drives Group uses the personal information. You will promptly notify USA Drives Group of any changes to your personal information using the procedures made available for that purpose by USA Drives Group or by contacting USA Drives Group’s customer service.

You may reasonably request access to your personal information collected by USA Drives Group and information about USA Drives Group’s use, disclosure and retention of that personal information by submitting a written request to USA Drives Group’s Chief Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. You may be required to pay a reasonable fee for access to your personal information. USA Drives Group may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

10. Non-Personal Information

USA Drives Group creates and collects non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. USA Drives Group may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then USA Drives Group will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined.

11. Other Websites and Businesses

USA Drives Group’s websites and correspondence (including emails and messages) may include advertisements for products and services (e.g. car sales, personal loans and credit cards) offered by independent businesses (that may have a financial relationship with a USA Drives Company) or links to websites operated by independent businesses (e.g. car dealers, lenders and credit card providers). USA Drives Group has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

12. Other Matters

(a) Disclaimers, Liability Exclusions/Limitations and Disputes:

The agreements (including any subscription agreement, membership agreement or terms of service or use) that you accept when you apply, register for, order or use USA Drives Group’s products or services contain important provisions, including provisions disclaiming, limiting or excluding the liability of USA Drives Group and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or USA Drives Group’s collection, use, disclosure and retention of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

(b) Information Collected from Other Websites, and USA Drives Group’s Do Not Track Policy

Through cookies we place on your browser or device, USA Drives Group may collect information about your online activity after you leave the online services, just like any other usage information USA Drives Group collects, this information allows us to improve the online services and customize your online experience, and otherwise as described in this Privacy Policy.

Your browser may offer a “Do Not Track” option, which allows you to signal to operators of websites and mobile applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites and mobile applications and services. The online services do not support Do Not Tract requests at this time, which means that we collect information about your online activity both while you are using the online services and after you leave the online services.

(c) Children

Our online services are not intended for children under 13 years of age. We do not knowingly collect personal information from an individual under age 13. If you are under the age of 13, please do not submit any personal information through the online services. If you have reason to believe that we may have accidentally received personal information from an individual under age 13, please contact us immediately at [email protected]

(d) California Residents

This section 12. (d) applies to California residents. When used in reference to California residents, “personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. (Cal. Civ. Code 1798.80. (e)).

If there is any inconsistency or conflict between the provisions of this section 12. (d) and other provisions of this Privacy Policy, for California residents the provisions of this section 12. (d) shall be controlling and govern, except to the extent such provisions are expressly superseded by the other provisions of this Privacy Policy.

  1. Categories of personal information

    USA Drives Group may collect or has collected (within the last 12 months) from you the following categories of information:

    1. personal information as defined above;
    2. financial materials – for example, credit reports;
    3. identifiers – for example, alias, unique personal identifier, online identifier, internet protocol address, email address, social security number, and passport number;
    4. network (including internet) activity information – for example, browsing and searching history, and information regarding your interaction with a website, application, or advertisement;
    5. employment-related and professional information – for example, occupation, location of job, and duration at position; and
    6. profile information - inferences drawn from any of the information collected reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
  2. Sources of personal information

    Personal information is collected from the following sources:

    1. directly from you – for example, when you submit an application through USA Drives Ltd.’s website;
    2. directly and indirectly – for example, from cookies and other technologies to track information; and
    3. directly and indirectly from advertisements.
  3. Use of personal information

    Each USA Drives Company uses your personal information collected by the USA Drives Company as described in section 4. of this Privacy Policy.

  4. Personal information “Sold” to Third Parties

    A USA Drives Company may sell information about you, such as personal information, identifiers and employment-related and professional information (refer to section 12. (d)(I) of this Privacy Policy). The information may be sold for the purposes as described in section 4. (a) of this Privacy Policy.

    As of the date of this Privacy Policy, in the preceding 12 months, USA Drives Company has not sold any of your personal information.

  5. Sharing of personal information

    Each USA Drives Company may share/disclose and has shared/disclosed (in the preceding 12 months) information about you, such as personal information and employment-related and professional information (refer to section 12. (d)(I) of this Privacy Policy). The information may be shared/disclosed and has been shared/disclosed (in the preceding 12 months) as described in section 5. of this Privacy Policy.

  6. Right to Delete

    You have a right to request your personal information be deleted, subject to certain exceptions – for example, to:

    1. comply with a legal obligation;
    2. detect security incidents;
    3. complete your transactions with USA Drives Group;
    4. identify and fix bugs and errors that impair functionality; and
    5. undertake ethical public interest research.
  7. Right to Opt-Out

    Your personal information may be sold to a third party and you have a right to opt-out of the sale of the personal information, subject to certain exceptions under the California Consumer Privacy Act (“CCPA”).

    To opt-out of the sale of your personal information, you (or a person authorized by you) go to the link “Do Not Sell My Personal Information” on USA Drives Ltd.’s homepage.

  8. Right to Access and Data Portability

    You have a right to access the categories and specific pieces of personal information that USA Drives Group has collected from you. Once a USA Drives Company receives a verifiable request from you to access personal information, the USA Drives Company will promptly take steps to disclose and deliver, free of charge to you, the personal information (as required by the CCPA). The information may be delivered by mail or electronically, and if provided electronically, the information will be in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.

    USA Drives Group may provide personal information to you at any time, but shall not be required to provide personal information to you more than twice in a 12-month period.

  9. Right Not to Be Discriminated

    USA Drives Group shall not discriminate against you because you exercised any of the rights in the CCPA, including:

    1. denying goods or services to you;
    2. charging different prices or rates for goods or services, including through use of discounts or other benefits or imposing penalties;
    3. providing a different level or quality of goods or services to you; and
    4. suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

    A USA Drives Company may charge a California resident a different price or rate, or from providing a different level or quality of goods or services to the California resident, if that difference is reasonably related to the value provided to the USA Drives Company by the California resident’s data.

  10. Exercise Rights

    You may exercise your right to delete, access, and data portability as described in this Privacy Policy, by submitting a verifiable consumer request at [email protected]

    A USA Drives Company will take steps to determine whether your request is a verifiable consumer request, but this will not extend the USA Drives Company’s duty to disclose and deliver the information within 45 days of receipt of your request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary, provided you are provided notice of the extension within the first 45-day period.

    You are required to provide suitable information for USA Drives Group to reasonably verify that you are the consumer whom USA Drives Group has collected personal information on or an authorized representative.

    The disclosure pursuant to a verifiable consumer request will cover the 12-month period preceding USA Drives Group’s receipt of the verifiable consumer request and will be made in writing and delivered through your account with USA Drives Group, if you maintain an account with USA Drives Group, or by mail or electronically at your option if you do not maintain an account with USA Drives Group, in a readily useable format that allows you to transmit this information from one entity to another entity without hindrance.

(e) Nevada Residents

This section 12. (e) applies to Nevada residents. In accordance with SB 220, if you are Nevada resident, you may opt-out of the sale of your personal information to third parties. If you reside in Nevada and you have provided us with your personal information, you may choose to opt-out of the sale of such personal information by filling out our Contact Form or by emailing us at [email protected] with “Nevada Privacy Right” in the subject line. We may request for additional information from you in order to verify your identity and/or the authenticity of your request.

If there is any inconsistency or conflict between the provisions of this section 12. (e) and the other provisions of this Privacy Policy, for Nevada residents the provisions of this section 12. (e) shall be controlling and govern, except to the extent such provisions are expressly superseded by the other provisions of this Privacy Policy.

(f) Changes to this Policy:

A USA Drives Company may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on the USA Drives Company’s website. A USA Drives Company’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with a USA Drives Company after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

Contacting USA Drives Group's Chief Privacy Officer:

If you have any comments or questions about this Privacy Policy or how USA Drives Group deals with your personal information, please contact USA Drives Group’s Chief Privacy Officer by mail or email at: USA Drives Group – Chief Privacy Officer, Suite 600, Two Bentall Centre, 555 Burrard Street, Vancouver, British Columbia, USA, V7X 1M8; email: [email protected]

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