This Privacy Notice for California Residents supplements the information contained in Accu-Trade, LLC’s (“Accu-Trade” “we” “us” or “our”) general Privacy Notice (“Privacy Notice”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). If you are a California resident, California law provides you with additional rights regarding our use of your Personal Information. We provide this notice in accordance with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. References to “Site” shall mean the Accu-Trade website located at www.accu-trade.com and “Services” shall refer to the services offered by Accu-Trade on the Site, and other services used to service our products and Service.
Information We Collect.
Please see our Privacy Notice for a description of the Personal Information we collect.
In particular, we have collected the following categories of Personal Information from or about consumers within the last twelve (12) months:
|Category||Examples||Collected: Dealerships||Collected: Consumers|
|A. Identifiers.||Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||YES||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). ||Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law. ||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO||NO|
|D. Commercial information. ||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO||Vehicle information (eg VIN and/or vehicle’s year/make/model/trim, details about the vehicle eg color, odometer, condition of vehicle)|
|E. Biometric information. ||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO||NO|
|F. Internet or other similar electronic network activity. ||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES||YES|
|G. Geolocation data. ||Physical location or movements.||YES||YES|
|H. Sensory data. ||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||NO|
|I. Professional or employment-related information. ||Current or past job history or performance evaluations.||YES||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). ||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO||NO|
|K. Inferences drawn from other personal information. ||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO||NO|
|L. Sensitive Information||Government identifiers (social security, driver’s license, state identification card, or passport number); Complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password); Precise geolocation; Racial or ethnic origin; Religious or philosophical beliefs; Union membership; Genetic data; Mail, email, or text messages contents; Unique identifying biometric information; Health, sex life, or sexual orientation information.||YES||NO|
We obtain the categories of Personal Information listed above:
Use of Personal Information.
Please see our Privacy Notice for a description of how we use your Personal Information.
Sharing Personal Information.
We may share the Non-Personal Information we collect and obtain for any lawful business purpose without any duty or obligation of accounting or otherwise to you, provided that the information remains Non-Personal Information. This will include, by way of example, sharing that Non-Personal Information with third parties.
We may share your Personal Information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may disclose personal information that we collect or that you provide as described in our Privacy Notice:
We may also disclose your personal information:
Disclosures of Personal Information for a Business Purpose.
In the preceding twelve (12) months, Accu-Trade has disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment related evaluations.
Category L: Sensitive Information
We have disclosed your Personal Information for a business purpose to the following categories of third parties:
Opting Out of the Sale and Sharing of Personal Information.
California residents may opt out of the “sale” or “sharing” of their Personal Information. While Accu-Trade does not exchange Personal Information for payment, we share information with businesses who provide cross-platform advertising and related tracking and analytics for our products in a way that falls under the CCPA’s broad definition of “sale” or “share.” Under the CCPA, “sale” is defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising related to the services. “Sharing” is defined as any disclosure, transfer, or other communication of Personal Information to third parties for purposes of advertising that is targeted based on a consumer’s activities on third-party and distinctly branded digital platforms, whether or not for monetary gain. Accu-Trade does not knowingly sell the information of minors under the age of 18 without affirmative consent.
If you would like to opt out of the use of your Personal Information for such purposes that may be considered a “sale” or “sharing” under California law, you may do so by emailing email@example.com.
Your Rights and Choices.
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Please note that we may limit the information we provide you, or deny your request, if the access request for information is governed by a superseding federal regulation (ie: GLBA, FCRA, etc).
You have the right to request that we limit the use and disclosure of certain Personal Information, opt-out of the use of certain Personal Information, as well as disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Please note that the rights below are not unqualified, we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply You may request that we:
You have the right to request that we delete your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your consumer rights request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:
You have the right to request that we correct any inaccurate Personal Information we hold about you. Upon receipt and verification of your request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct your Personal Information as directed by you, pursuant to the law and applicable regulations.
To exercise the access, use limitation, data portability, and deletion rights described above, please submit a consumer rights request to us by any of the following methods:
Only you, or someone legally authorized to act on your behalf, may make a consumer rights request related to your Personal Information. To designate an authorized agent, please contact us through the methods noted above. Only the consumer or authorized agent may make a consumer rights request related to their personal information. An “authorized agent” is a person (or a business entity registered with the California Secretary of State) that consumers have authorized to act on their behalf, or an individual granted authority under a written power of attorney issued pursuant to California Probate Code sections 4000 to 4465.
If you are an authorized agent who wishes to submit a request to know, a request to limit use, a request to delete, or a request to opt-out on behalf of another consumer, please submit to us sufficient information to allow us to verify your identity to a reasonably high degree of certainty and either:
We may deny a request from an authorized agent who does not submit adequate proof that they have been authorized by the consumer to act on the consumer’s behalf. We may also contact the consumer directly to confirm their identity and that they provided you permission to submit the request on the consumer’s behalf.
You may only make a consumer rights request for deletion, access, or data portability twice within a 12-month period. The consumer rights request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a consumer rights request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a consumer rights request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a consumer rights request within thirty (30) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your consumer rights request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights.
California Do Not Track Disclosure.
Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. We do not currently support DNT browser settings and do not currently recognize or respond to DNT signals.
California Shine the Light.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
Changes to this Privacy Notice.
We reserve the right to update and periodically amend this Privacy Notice at our discretion and at any time. If we make changes to this Privacy Notice, amendments will be posted online, and the date of update will be included. Your continued use of Accu-Trade and its affiliated sites after any such update indicates your agreement to the same.
If you have any questions or comments about this notice, the ways in which Dealer Inspire collects and uses your information, or your choices and rights regarding such use, please do not hesitate to contact us at:
You may also mail us with general questions at:
300 S. Riverside Plaza, Suite 1000
Chicago, IL 60606
Effective Date: January 1, 2023