Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice will inform you as to how ClearVin looks after your data and tell you about your privacy rights. If you object to anything in this Privacy Policy, or otherwise do not understand or agree to be bound by the terms of this Privacy Policy, do not use ClearVin’s services. By using ClearVin’s services, you agree to be bound by the terms of this Privacy Policy. You may print a copy of this Privacy Policy by using the print button or feature in your browser. We suggest retaining a copy for future reference.

Our websites are not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy notice supplements the other notices and is not intended to override them,

This Privacy Policy is incorporated into and is part of the ClearVin Terms of Use. Any terms not specifically defined herein shall have the meanings set forth in the Terms of Use. For the purposes of this Privacy Policy, “ClearVin” means and includes ClearVin, LLC and its affiliates, related entities, subsidiaries, investors, owners, members, shareholders, officers, directors, employees, agents, representatives, and assigns.

CONTACT DETAILS
Our full details are:
ClearVin, LLC
8 The Green, Ste A
Dover, DE 19901-3618


CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

If our Privacy Policy changes, we will post the changes to our site with the date of revision. Your continued use of our site will constitute your agreement with our revised Privacy Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, company name, title, date of birth, driver’s license information and copy, Passport information and copy, gender information, and other information provided.


• Contact Data includes billing address, delivery address, email address and telephone numbers.


• Financial Data includes bank account, payment processing information, payment system details.


• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.


• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform; log files; beacons; bugs; tags; pixels; scripts; and other technology on our websites and or the devices you use to access our websites.


• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.


• Usage Data includes information about how you use our websites, products and services, username, and password.


• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your emails to and from us, emails to third parties related to our services, SMS messages, other messaging platform messages, and your communication preferences as indicated to us.


• Third Party Data includes data received from third party beacons, bugs, tags, and scripts, third party links, data received from social media services, and your use of other sites which are not owned or controlled by us, or via links or ads on our site not owned or controlled by us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).

3. HOW IS YOUR DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  
  
  • Visit our websites and or create an account on our websites;
  • Contact us about our products or services;
  • Participate in any geolocation service we or third parties offer;
  • Purchase a product or service from us;
  • Provide financial information related to our services;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.


• Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.


• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

4. HOW WE USE YOUR DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To perform services provided by our company or other parties related to our services.


• To comply with a legal or regulatory obligation.


• To promote our services, and those of our affiliated entities, to you or other members of the public.


• To provide to third parties, based on your consent.


• To third parties who provide services to us, such communications providers, advertising services, and payment processing systems.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer, including verifying your account, providing account security, and verifying your identity	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interest (fraud prevention and other misuse)
To process and deliver our services or provide you with more information about our services, including: (a) Manage payments, fees and charges, (b) Collect and recover money owed to us, and (c) Provide you with customer support.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile (g) Usage (g) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us or otherwise enforce the agreements between the parties)
To manage our relationship with you, including: (a) Notifying you about changes to our terms or privacy policy, and (b) Asking you to leave a review or take a survey.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, conduct security and risk assessments, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of our websites and our advertising and or personalize our content or services for you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about your transactions with us, your potential transactions with us, and goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

THIRD PARTY MAREKING PROVIDERS AND SYSTEMS
We may use third party marketing provides and systems to publish ads on our websites. When you view or click on an ad, a cookie will be set to help better provide advertisements that may be of interest to you on our websites and other websites.

SOCIAL MEDIA CONNECTIONS OR OTHER OPEN ID PROVIDERS
You can register and log in to our websites using third-party sign-in services. These services will authenticate your identity and provide you the option to share certain personal information with us to pre-populate our registration forms. Services like these may give you the option to post information about your activities on our websites to your profile page to share with others within your network.

SOCIAL MEDIA WIDGETS
Our websites may include social media features and other widgets. These features may collect your personal information including without limitation your IP address and which page(s) you are visiting on the websites and may set a cookie to enable the feature(s) to function properly. Social media features and widgets are either hosted by a third-party or hosted directly on the websites. Your interactions with these features are governed by the privacy policy of the company providing it and not by this Privacy Policy.

COOKIES AND TRACKING TECHNOLOGIES
As is true of most websites, our websites automatically collect certain personal information from you and your devices (including mobile devices) and stores it in log files. Categories of personal information that we collect in this manner include without limitation: (a) internet protocol (IP) addresses, (b) browser type, (c) internet service provider (ISP), (d) referring/exit pages, (e) operating system, (f) date/time stamp, and (g) clickstream data. We use this personal information and technologies such as beacons, tags and scripts to analyze trends, to administer our services, to track your movements around the websites, and to gather demographic information about user base as a whole.

We may place a text file called a “cookie” in the browser files of your computer. The cookie itself does not contain personal information, but it will enable us to relate your use of our websites to personal information that you have specifically, voluntarily, and knowingly provided to us. But the only personal information a cookie can contain is information that you supply yourself. A cookie cannot read data off your hard disk or read other cookie files created by other websites. We may use cookies to track your traffic patterns (as described above). In addition, we use encrypted cookies to authenticate your identify on each page after you log on to our websites.

The use of cookies by third parties is not covered by this Privacy Policy. We do not have access to or control over these third-party cookies. These third parties use session ID cookies to make it easier for you to navigate our websites.

Our third-party partners employ clear gifs (a.k.a. web beacons/web bugs), images, tags, and scripts that help them better manage content on our websites. We tie the information gathered by these third-party partners to your personal information.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

THIRD-PARTY LINKS
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.

6. INFORMATION SHARING AND DISCLOSURE

We do not share your personal information with third-parties or non-affiliated entities except in the following circumstances: (a) when we have your permission or pursuant to your request; (b) to process or facilitate the purchase and or the shipment of any vehicle through our services or that of any related party; (c) to state, federal, or other regulatory and or administrative agencies as part of the title or ownership transfer process; (d) in response to subpoenas, court orders, or other legal, administrative, regulatory, arbitration, or similar process; (e) to establish or exercise our, or an affiliate, vendor, or related third party’s rights or defend against claims; or (f) if we believes that doing so is required or is in our best interest to protect its rights or the rights of others affiliated with or related to us.

If we are acquired by or merges with another company, wish to purchase or dispose of any assets, or otherwise restructure the company, to the extent permitted by applicable law, you agree that we may transfer your personal information to such company. In this event, we will notify you by email/or a prominent notice on our website of any choices you may have regarding your personal information before your personal information is transferred and becomes subject to a different privacy policy.

7. DATA STORAGE AND RETENTION

We will retain your information as long as it is necessary and relevant to provide you with our services and in compliance with our data retention policies. Additionally, we will retain personal information from closed or cancelled member accounts to comply with legal and regulatory obligations, resolve disputes and claims, prevent fraud, collect any fees owed, assist with any investigation, and enforce this Privacy Policy and the ClearVin Terms of Use and take any other actions permitted by law.

8. CONFIDENTIALITY AND SECURITY

We take your security seriously and take reasonable steps to protect your personal information. We use Secure Socket Layer (“SSL”) encryption when transmitting certain kinds of personal information, such as financial and other sensitive information. An icon resembling a padlock is displayed on the bottom of most browser windows during SSL transactions that involve credit cards and other forms of payment. Any time we ask you for driver’s license number or a credit card number for payment or for verification purposes, it will be SSL encrypted. The personal information you provide will be stored securely on servers utilized by us. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using our services or otherwise providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our services. We may post a notice on the website if a security breach occurs. We may also send an email to you at the email address you have provided in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

9. COMMUNICATIONS

If you no longer wish to receive our emails or other promotional communications, you may opt-out by following the instructions included in each communication. We reserve the right to send you certain communications relating to our services, including without limitation notifications, service announcements, and administrative messages. Generally, you may not opt-out of these communications, which are not promotional in nature. If an opt-out option is available, you may opt-out by following the instructions included in each communication.

10. ERASURE OF DATA

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You can request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal or service fulfilment reasons, which will be notified to you, if applicable, at the time of your request, or there may be a delay in doing so.

If you wish to request erasure of some or all of your data, please contact salesServiceEmail. You will not have to pay a fee to request reassure of some or all of your data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right request erasure of some or all your data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.