Privacy Policy

Effective date: October 2018

 

This Privacy Policy explains the policies and procedures relating to the use of information collected through our websites, mobile apps, or our physical business location (collectively “Site”) from visitors to or users of our Site, potential customers, and customers (collectively “Customers”, “you,” or “your”), whether through the Internet or otherwise, by https://www.efpd.org/ (collectively “Company”, “we”, “us” or “our”). Because Company’s products and services are not directed to or intended for (a) individuals under the age of (18) nor (b) individuals located or residing outside of North America, we ask that individuals in those categories not submit any information to us and not use our Site. By visiting or using our Site or using our services, you consent to the collection, use, disclosure, retention, and protection of information as described in this Privacy Policy.

 

This Privacy Policy does not apply to:

  • Credit-related products, which are covered by the issuing bank or financial institution’s privacy notices that appear on credit applications or that you receive with your credit accounts;

  • Your interactions with third parties or their websites that are linked to or accessible from our Site or that are operated by unaffiliated third parties; amd

  • Our employment-related records.

 

Information That We May Collect About You

  • Identification information that can be used to identify you, such as your name, alias, address, phone number, email address, phone number, payment information, signatures, or other identifiers. We may also collect online identifiers, such as your IP address, when you browse or use our Site. For the purposes of facilitating some sales transactions, we may collect information from your government-issued ID, your social security number, insurance policy information, or bank account information, but please only provide this information if requested by us. We may also collect information about any automobile you sell, offer for sale, or purchase through our site, including the make, model, trim, model year, mileage, color, options, vehicle identification number (VIN), license plate number. When you apply to see if you pre-qualify for auto financing through one of our participating lenders, that lender may require you provide additional information, but that financing information is not captured or retained by us;

  • Commercial information, such as goods or services you purchased or considered purchasing, including automobile sales information such as advertised price, purchase offers, actual sale price, and sale location;

  • Protected class information under state or federal laws, such as age, gender, and family status;

  • Online activities information, such as browsing history, search history, and other information when you interact with our Site, advertisements, and emails;

  • Geolocation data, including precise geolocation data if the settings on the device you use to access our Site grants permission to obtain this information;

  • Audio, electronic, or visual information, such as audio or video recording when you call us or when you visit our physical business location;

  • Professional or employment information, such as when you provide us this information via a survey;

  • Education information, such as when you apply for a job with us or respond to a customer survey;

  • Inferences or preferences we learn or infer about you; and

  • Other personal information, if it identifies, relates to, and can be reasonably associated with or linked to you or your household.

 

Sources of Collected Information

We collect different types of information about you from a variety of sources, including information you provide to us, information we automatically collect, information we obtain from other sources (see below), and information we derive or infer about you.

 

Information You Provide. You may choose to provide us with information when you interact with us, including:

  • Identification information. We may collect and retain any information provided to us by you or your devices when you visit our Site, including when you register for an account, use our services, communicate with us, complete sales transactions, and subscribe to our email newsletters or other content we offer. When completing sales transactions, we may collect your payment information (e.g., credit/debit card information), signature, and, in some cases, government-issued ID information and date-of-birth.

  • Commercial information. You may provide us or generate commercial information regarding your purchases from or involving our Site and any related transactions.

  • Protected class information. You may provide us your protected demographic information, including age, gender, family status, such as when you complete a user profile or consumer survey.

  • Your preferences and inferences. You may indicate your preferences when you complete our surveys, submit reviews and comments, or participate in our contests, promotions, or sweepstakes.

  • Professional or employment-related information. You may also provide information related to your profession or employment when you complete our surveys, submit reviews and comments, or participate in our contests and promotions.

  • Education information. You may provide information relating to your education when applying for a job with us or when responding to our customer surveys.

  • Other information. When you apply to see if you pre-qualify for auto financing through one of our participating lenders, that lender may require you provide additional information, but that financing information is not captured or retained by us.

 

Automatically Collected Information. We may collect and retain your personal information automatically when you visit our Site. When using our website or mobile applications or when interacting with our emails, we and our partners may collect certain information by using first and third-party cookies, pixel tags, and similar technology that may exist today or that may be developed in the future. We may allow third parties to use these tools on our Site, and the information collected through these tools may be used on our Site or on other websites or services, including third-party sites. We may automatically collect the following information:

  • Identification information, such as your IP address, device ID, cookie ID, mobile advertising identifier, pixel identifier, or phone number.

  • Online activities, such as browse and search history, vehicles you view or configure, interactions with our websites, applications, or other information about your online interactions. When you use social networks to access our Site, information from those social networks may be made available to us. By associating a social network account with our Site, you agree that we may access and retain that information in accordance with the policies of the social network and this Privacy Policy.

  • Geolocation data. If permitted by your browser, app, or device settings, we may collect certain information about your precise location to help you locate us, provide you with information relevant to your geographic area, or determine geographic information relevant to sales transactions.

  • Audio, video, and electronic information, such as audio or video recording of telephone or online conversations between you and our customer support personnel for purposes of quality control, training, security, and analytics. We may also use video monitoring at our physical location to protect against theft and other crimes, although this information may not be capable of association with you.
     

Information Collected From Other Sources.

  • Identification information. We may collect your contact information or information relating to your sales transactions from our affiliates, acquired businesses, partners, public sources, or other individuals.

  • Commercial information. We may obtain your commercial information, such as your purchase history and information relating to your sales transactions, from our affiliates, partners, public sources, or other individuals, including individuals involved in sales transactions with you facilitated by our Site.

  • Inferences or preferences about you, protected class information under federal and state law, professional or employment-related information, education background, and geolocation information may be collected from our affiliates, partners, public sources (e.g., a publicly available customer review), or other individuals.

 

Information We Generate

  • Inferences or preferences. We may generate or derive some information about you based on other information we collect. We may also conduct analyses based on aggregated or de-identified information.

 

Use of the Collected Information

We generally use the information collected about you to provide and improve our services. We may use this information to:

  • Provide and deliver services to you, process transactions, and send related information such as confirmations and invoices, and revise, update and develop new services;

  • Send you communications including technical and support notices, administrative messages, and inquiry/customer support responses;

  • Communicate with you about products, services, offers, and promotions offered by us and certain third parties, and provide you with information that may be of interest;

  • Personalize our services and present you with advertising, content, or features of interest to you;

  • Allow you to participate in contests, sweepstakes, or similar promotions and to administer them;

  • Link or combine with information we get from third parties to help understand your needs and provide you with better service;

  • Monitor and analyze trends, usage, and activities in connection with our services;

  • Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect our rights and the rights of third parties;

  • Respond to law enforcement requests or as required in connection with court orders, government regulations, or litigation; and

  • Carry out any other purpose described to you at the time the information was collected.

 

Sharing of Collected Information

We may use or share (i) your personal identifiable information (PII) and (ii) de-identified and pseudonymized information based on your PII, for any purpose including marketing, research, and product and service development and improvement. We may share your PII with our affiliates, service providers and business partners, third parties that are not affiliated with us for business purposes, with other third parties as required by law, and also:

  • With our service providers and business partners to perform services on our behalf or on your behalf, including email delivery and other communications with you, credit card and other payment processing, marketing, advertising, data analytics, website hosting, customer service, and similar services;

  • With other automobile dealers, manufacturers, and similar businesses that may be unaffiliated with us, including to facilitate communications between these businesses and you;

  • With lending companies and other financial institutions for purposes of determining your creditworthiness and facilitating financing, and for marketing their financial services to you;

  • We may share information relating to the offering for sale and sale of automobiles on and through our Site, including make, model, year, VIN, listing price, sale price, sale date, and sale location with unaffiliated third parties for purposes of compiling, analyzing, marketing, selling, and publishing automobile sales data;

  • With appropriate authorities or third parties to enforce our rights and those of our affiliates, customers, and members of the public, and to apply with applicable laws and legal processes, and for preventing fraud, theft, and injury to you or others;

  • When we are involved in a business merger, acquisition, liquidation, valuation or similar business transaction;

  • Unaffiliated third-party businesses so that they may market goods or services that may be of interest to you; and

  • At such other times and for such other purposes as you may authorize us to disclose the information.

 

Your Privacy Choices and Rights

  • You may have the right to opt out of the disclosure of personal information about you to third parties for monetary or other valuable consideration. To request to opt-out, please email hello@growingsales.com with a subject of “Opt Out Request”. Please include your name and email address in your correspondence so we can identify your records in our system.. Note this will not affect the collection, storage, compilation, use, transfer, or sale of de-identified or pseudonymized information that may have been derived in part from your personal information (e.g., sales information).

  • You may also have the right to request that we delete personal information about you that we have collected from you or through other sources, and you may request we do so by emailing us at hello@growingsales.com with a subject line of “Deletion Request”. Please include your name and email address in your correspondence so we can identify your records in our system. Please be aware that you are not able to opt out of receiving communications about your account, the provision of our services to you, or related transactions with us.

  • If you would like to opt-out of receiving email marketing communications from us, you may click the “Unsubscribe” link found at the bottom of our marketing emails.

  • Please note that like many websites our Site does not make any modifications or otherwise respond to Do Not Track signals generated by your browser or device.

  • Most major web browsers provide users the option to accept or reject cookies. If you delete cookies, use a different device, or change web browsers, you may need to repeat the steps to accept or reject cookies on the new device or browser. If you use your browser settings to block all cookies you may not be able to access parts of our Site. The “Help” future on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookies, or how to disable cookies altogether. If you block or otherwise reject our cookies, you may not be able to utilize certain features on our Site including services requiring you to sign in.

  • A pixel tag (i.e., tracking pixel, web beacon, clear GIF, 1x1 pixel) is an invisible tag or small graphic placed on certain pages of our Site or in emails but not on your computer. When you access these pages or emails, the pixel tags help maintain a record that you visited a webpage or received or opened an email. When such a message is opened in an HTML-capable email program, the recipient’s computer or device will communicate with our server to retrieve the pixel tag file, allowing us to record and store the date and time the email was viewed, the fact that the email client is capable of receiving HTML-encoded email, other standard logging information, and the recipient’s email address. These pixel tags help us analyze our customers’ online behavior and measure the effectiveness of our marketing. You can disable the pixel tag feature by changing the settings on your email client to prevent the automatic downloading of images, changing your browser settings to omit images, disabling Javascript, or utilizing commercially available software that can omit pixel tags and most advertisements.

  • Where applicable, the California Consumer Privacy Act (CCPA) affords you the right to request that we disclose to you the personal information we collect, use, or disclose, and information about our data practices; the right to request that we delete your personal information that we have collected from you; and our assurances that we will not discriminate against you for exercising these rights.

 

Policy Changes

We reserve the right to modify and revise this Privacy Policy from time to time. If we make material changes to this policy, we will notify you of such changes by posting them on our Site or by sending you an email or other communication, and we will notify you of the effective date of the changes. By continuing to access or use our Site or our services after these changes become effective, you are agreeing to be bound by the revised Privacy Policy.

 

Contacting Us

You can contact us with questions or comments about privacy practices or this Privacy Notice by emailing us at info@efpd.org or by calling us at 636-938-5505.