Effective Date: June 2021
Collection of Information
Use of Information
Sharing of Information
Advertising and Analytics
Your California Privacy Rights
COLLECTION OF INFORMATION
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, make a purchase, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of information we may collect about you include your name, contact information (such as email address, postal address, and phone number), product or service searches, and any other information you choose to provide. For example, if you purchase a vehicle through our Services, we may also collect your payment method information, employment information, social security number, date of birth, insurance policy information, and driver’s license information. Additionally, if you apply for a job with Lithia, we may also collect your resume or CV and information about your previous employment.
Information We Collect Automatically When You Interact with Us
When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:
- Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product or service details, vehicle information, price, and other information about the transaction, such as the date and location.
- Device Information: We collect information about the device you use to access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and mobile app version.
- Usage Information: We also collect information about your activity on our Services, such as product or service searches, access times, pages viewed, links clicked, and the web page you visited before navigating to our Services.
- Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and web beacons, to collect information about your activity on our Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.
Information We Collect from Other Sources
We obtain information from third-party sources. For example, we may collect information about you from credit bureaus. Additionally, if you create or log into your Lithia account through a third-party platform (such as Facebook, Google, or Twitter), we will have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.
When customers apply for financing with us, they may provide us with the name, address, and phone number of another person to use as a reference.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or we may infer your purchasing interests based on your vehicle searches and past purchases.
USE OF INFORMATION
We use the information we collect to:
- Provide, maintain, and improve our products and services, including to process transactions, provide customer support, and debug to identify and repair our Services;
- Personalize your experience on our Services;
- Send you technical notices, security alerts, receipts, customer support responses, and other transactional or relationship messages;
- Communicate with you about products, services, and events offered by Lithia and others and send advertisements, surveys, or other information that we think will interest you, such as price change alerts;
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Deliver personalized advertisements through third-party platforms (for more information, see the Advertising and Analytics section below);
- Review and assess your application for employment;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Lithia and others;
- Facilitate your participation in contests or other promotions;
- Comply with our legal and financial obligations; and
- Carry out any other purpose described to you at the time the information was collected.
SHARING OF INFORMATION
We share personal information in the following circumstances or as otherwise described in this policy:
- We share personal information with vendors that perform services for us, such as professional advisors or companies that assist us with web hosting, credit checking, email services, verification of sales, shipping and delivery, payment processing, fraud prevention, customer service, marketing and advertising services, and other services relating to the purchase, sale, or lease of a vehicle.
- If you submit personal information for a vehicle financing decision, including through a dealership, we may share that information with dealership financial services partners for the purposes relating to your vehicle financing, such as loan evaluation.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process.
- We may share personal information if we believe that you have violated the law or if we believe it is necessary to protect the rights, property, or safety of Lithia or others.
- We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is shared between and among Lithia and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We share personal information with your consent or at your direction.
We also share aggregated or de-identified information that cannot reasonably be used to identify you.
ADVERTISING AND ANALYTICS
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
You may opt out of receiving marketing emails from us by following the instructions in those communications, by emailing us at firstname.lastname@example.org, or by calling us at 888-416-9006. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.
California Consumer Privacy Act
In the preceding 12 months, we have collected the categories of personal information described in the table below. For details about the precise data points we collect and the categories of sources of such collection, please see the
Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
Categories of Personal Information
- Identifiers (like name or contact information)
- Internet or other electronic network activity (like browsing or other usage data)
- Commercial information (like products or services purchased)
- Geolocation data
- Professional or employment-related information
- Education information
- Inferences (like purchasing interests or approximate location)
- Other personal information in the event of purchase or financing (like driver’s license, insurance policy number, bank account number and social security number)
Categories of Recipients with whom Information May Be Shared
- Payment processors
- Web hosting and cloud storage providers
- Customer support services providers
- Customer feedback services providers
- Credit bureaus
- Advertising services providers
- Data analytics providers
- Software development and information technology services providers
- Third parties when compelled by law, such as to law enforcement or other governmental authorities
Lithia does not sell your personal information. We do allow our advertising partners to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Advertising and Analytics section above.
Subject to certain limitations and exceptions, you have the right to (1) request to know more about the categories and specific pieces of personal information we process, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by calling 888-416-9006 or emailing us at email@example.com. We will verify your request by asking you to provide information related to your recent interactions with us.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please call (888-416-9006) or email us (firstname.lastname@example.org).