| Category of personal data |
Source(s) |
Purpose(s) for collection |
Disclosure to third parties |
| Identifiers, such as:
Name, postal address, email address, IP address, identification numbers (e.g., social security number, driver’s license number, state identification number, military identification number or passport number) |
• Directly from consumers
• Indirectly from consumers (e.g., from observing consumers’ actions on our Services)
• Third-party service providers, including advertising companies, analytics providers, and websites or companies that provide information regarding vehicles or provide listings of vehicles available for sale/lease, that forward identifiers provided by consumers
|
• To respond to consumers’ requests and inquiries
• Communicate with consumers regarding our products or services
• Enter into and process transactions with consumers
• Send marketing communications
• Complete government forms
• Confirm consumers’ identity and that they are at least 18 years old
• Confirm consumers are licensed to drive our vehicles or take delivery of a vehicle purchased or leased from us |
• Disclosure for business purposes to internet service providers, analytics providers, payment processors and warranty, insurance or service contract administrators, if applicable to transaction
• Disclosure for marketing purposes to advertising companies
• Disclosure for safety and warranty purposes to vehicle manufacturer, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
• Disclosure to state or federal agencies, when required by law
• Disclosure to vehicle manufacturer for marketing and analytical purposes, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership [Note – if this bullet point is included, information sharing for this purpose amounts to a “sale” of information, and requires the dealer to have a “Do Not Sell My Information” button on its website – see Section II.] |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as:
Phone number; insurance information; bank account number, credit card number, debit card number, or other financial information, including information relating to consumers’ vehicle financing or lease terms, along with vehicle information; and/or signature(s). |
• Directly from consumers
• Third-party service providers, including advertising companies and analytics providers
|
• To respond to consumers’ requests and inquiries
• Communicate with consumers regarding our products or services
• Enter into and process transactions with consumers
• Send marketing communications
• Complete government forms
• Confirm insurance coverage
• Confirm identity
• Obtain authorization to collect payments
• Collect payments
• Confirm acknowledgement of receipt of documents we provide to consumers |
• Disclosure for business purposes to internet service providers, delivery services and payment processors
• State or federal agencies, when required by law
• Disclosure to vehicle manufacturer for marketing and analytical purposes, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership [Note – if this bullet point is included, information sharing for this purpose amounts to a “sale” of information, and requires the dealer to have a “Do Not Sell My Information” button on its website – see Section II.]
|
| Protected classification characteristics under California or federal law, such as:
A photocopy/scan of government issued identification reveals personal information. For example:
• Driver’s license/state identification card – includes image, date of birth, physical description and gender
• Permanent resident card – includes image, date and place of birth;
• Social security card – includes social security number
• Passport – includes image, date and place of birth and nationality
• Military ID – includes image and rank
Completion of a Translated Contract Acknowledgement or signing of translated documents reveals a consumer’s primary language |
• Directly from consumers
• Government’s Military Lending Act website |
• To confirm identity
• Confirm consumers are licensed to drive our vehicles or take delivery of a vehicle purchased or leased from us
• Confirm eligibility for a manufacturer or lender rebate and to apply for and process any such rebate
• Determine coverage under the Military Lending Act in connection with a financed vehicle transaction
• Provide consumers with copies of certain documents written in the language in which their finance or lease transaction was primarily negotiated, as required by law
• Complete government forms |
• Disclosure to manufacturer or lender for processing applicable rebate
• Disclosure to state or federal agencies, when required by law |
| Commercial information, such as:
Vehicle information, ownership information, and current lease or finance terms |
• Directly from consumers
• Third parties, such as vehicle manufacturer and/or advertising companies
|
• Enter into and process transactions with consumers
• Appraise consumers’ vehicles
• Send informational and marketing communications
• Retain records of transactions as required by law
• Fulfill the terms of a written warranty or product recall
• Process warranty, insurance or service contract claims
• Share information with state agencies as required by law |
• Disclosure for business purposes to payment processors, delivery services and warranty, insurance or service contract administrators, if applicable to transaction
• Disclosure for safety and warranty purposes to vehicle manufacturer, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
• Disclosure to state or federal agencies, when required by law |
| Biometric information
Consumers who finance/lease vehicles may be asked to complete a “Thumbprint form” |
• Directly from consumers
|
• To confirm identity
|
N/A |
| Internet or other similar network activity information, such as:
IP address, browsing history, and search history |
• Indirectly from consumers (e.g., from observing consumers’ actions on our Services)
|
• To communicate with consumers regarding our products and services
• Improve user experiences by making our website easier to use and navigate, and more personalized based on the profile we create about consumers |
• Disclosure for business purposes to internet service providers
|
| Geolocation information, such as:
IP address and vehicle location (using GPS, as permitted by law) |
• Indirectly from consumers (e.g., from observing consumers’ actions on our Services)
• From vehicles equipped with GPS tracking (as permitted by law)
|
• To respond to consumers’ requests and inquiries
• Enter into and process consumers’ transactions with you
• Send marketing communications
• Track vehicles as permitted by law |
• Disclosure for business purposes to internet service providers
|
| Sensory data, such as
Audio information from voicemail messages and/or recorded phone calls (with consumers’ consent) |
• Directly from consumers
|
• To communicate with you; some phone calls are recorded (with your consent) for training our staff and for quality assurance purposes |
N/A |
| Professional or employment-related information, such as:
Information regarding current occupation |
• Directly from consumers
|
• To confirm eligibility for a manufacturer or lender rebate and to apply for and process any such rebate
• To confirm eligibility for employee discount pricing
• Complete government forms, as required |
• Disclosure to manufacturer or lender for processing applicable rebate
• Disclosure to state or federal agencies, when required by law |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such as:
Information regarding whether a consumer is or will soon be a college graduate |
• Directly from consumers
|
• To confirm eligibility for a manufacturer or lender rebate and to apply for and process any such rebate
|
• Disclosure to manufacturer or lender for processing applicable rebate
|
| Inferences drawn from personal information to create a profile, such as:
Information regarding consumers’ vehicle preferences and needs |
• Indirectly from consumers (e.g., from observing consumers’ actions on our Services)
• Third-party service providers, including advertising companies and analytics providers |
• To market our products and services to consumers |
N/A |
