Effective: June 1, 2021
INFORMATION WE OBTAIN
We may obtain personal information about you in various ways, such as when you visit our Websites. The types of information we obtain include:
In addition, when you visit our Websites, we may obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server.
We may use these automated technologies on our Websites to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our Websites, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Websites. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Websites; (3) tailor the Websites around your preferences; (4) measure the usability of our Websites and the effectiveness of our communications; and (5) otherwise manage and enhance our services, and help ensure they are working properly.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Websites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
HOW WE USE THE INFORMATION WE OBTAIN
We may use the information we obtain about you to:
We also may use the information in other ways for which we provide specific notice at the time of collection.
We also use third party web analytics services on the Websites, such as those of Hotjar. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Websites. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the Websites. To learn more about Hotjar and how to opt out, please visit https://www.hotjar.com/opt-out.
Our Websites are not designed to respond to “do not track” signals from browsers.
INFORMATION WE SHARE
We may share the information we obtain about you with our affiliates and subsidiaries. We also may share the information we obtain about you with third-party vendors and other entities to perform certain services on our behalf, such as website hosting, data analytics, payment processing and other services. We also may share your information with (1) credit reporting agencies and services in connection with credit underwriting or to report debts owed to VFS; and (2) to financing sources, including individuals or entities involved in securitization, sales, assignment, or financing of our transactions.
We may share your information with REIN Connected Insurance Agency, LLC or other insurance brokers or with insurance carriers to evaluate your eligibility for potential insurance options. Please note that these entities will use your information in accordance with their own privacy policies.
We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent or as directed by your representative (including other institutions with which you apply for credit).
We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or as part of the diligence process for such a transaction.
YOUR RIGHTS AND CHOICES
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Our Websites are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of 13, or such other age as may be stipulated by applicable law.
EXTERNAL ONLINE SERVICES AND FEATURES
For your convenience and information, our Websites may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by VFS, we are not responsible for these third parties’ information practices.
HOW TO CONTACT US
Effective: June 1, 2021
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
1. Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
2. Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
3. Sale of Personal Information
We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Site in exchange for non-monetary consideration. We share the categories of personal information listed below to serve you content and advertisements that may be of interest to you. You have the right to opt out of this disclosure of your information, which may be considered a “sale” under California law.
During the 12-month period prior to the effective date of this Statement, we may have sold the following categories of personal information to the following categories of third parties:
Category of Personal Information
Category of Third Party
We do not have actual knowledge that we sell personal information of minors under 16 years of age.
4. Sharing of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.
We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
Category of Personal Information
Category of Third Party
Additional Data Subject to Cal. Civ. Code § 1798.80 Law
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with government entities, such as in response to a request from law enforcement authorities.
5. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
How to Submit a Request. To submit an access or deletion request please contact us at firstname.lastname@example.org or call us at 877.865.8623, extension 3905. To opt-out of the sale of your personal information in connection with third-party advertising cookies and similar technologies on our Site, click here or email us at email@example.com.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you do not have an email address or other direct contact information on file with us (e.g., if you passively visit our website), then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that VFS historically has not linked IP addresses, device identifiers or other information collected through automated means to named actual persons. Accordingly, if you do not have an email address or other direct contact information on file with us, and you request access to or deletion of your personal information, we will not be able to process your request at this time.
If you have an email address or other direct contact information on file with us, and request access to or deletion of your personal information, we may require you to provide any of the following information: last four digits of SSN, billing address, business phone number, guarantors/co-makers listed on the account, and/or name of customer’s dealer. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.