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Tuesday, September 22, 2020

BuyingAdvice Privacy Policy

TRUSTe

Your Privacy is Our Concern

Date Last Revised: 12/31/2019

Empower Direct, LLC (collectively referred to as “we”, “us” or “Buying Advice”), who owns www.buyingadvice.com, is committed to protecting and respecting your privacy. We do not share your personally identifiable information with any third party that is not an affiliate or service provider as described in this privacy policy. Therefore, our privacy policy is straightforward.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

We collect and retain information about you to communicate with you and to process your requests for products and services. Except as explained here in our Privacy Policy, we do not share non-public information about our customers or former customers with anyone other than our affiliates and service providers. The examples in this Privacy Policy are illustrative only and are not intended to be exclusive.


Information We Collect

We collect the following types of public and non-public personally identifiable information about you on our site which is then transferred to our affiliates (such as dealer networks):

  • Information obtained from you on applications and other forms, and from other sources used to process your request for one or more of our products or services (e.g., your name, address, date of birth, employment history, income, credit balances, property insurance coverage and other representations made by you).
  • Information arising from your transactions with us or our affiliates (e.g., your payment history, account balance and other transactional information) to fulfill the service you have requested such as auto buying, financial services providers, such as mortgage and life insurance agencies, and auto finance services.

Other Information We Collect

  • We collect name, email address, and comments in our BLOG area of the site if you choose to make a comment. See “BLOG” section below.


User Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:

  • Your credit score
  • Your employment and residence records
  • Your criminal records
  • Local business names, phone numbers and addresses (particularly car dealerships)
  • Marketing data from third parties that is combined with information we already have about you, to create more tailored advertising and products


Who We Share Your information With and Why

Except as discussed herein (sharing with our affiliates and service providers), we will only share non-public personally identifiable information about you with non-affiliated third parties as permitted by law or with your consent. We will share your personally identifiable information with third parties only in the ways that are described in this privacy policy. We do not share your information with our affiliates for unknown or unrelated purposes.

To provide you with superior service, inform you of product and service opportunities that may be of interest to you that you have requested to receive, and for other business purposes, we may disclose all of the information we collect, as described above, to the following types of affiliated companies: auto buying services, financial service providers, such as mortgage and life insurance agencies, and auto finance companies. If you do not want us to share this information with our affiliated companies, do not use our site. The primary purpose of this site is to facilitate the interaction between you and our affiliated companies.

You may be contacted for sales purposes by participating auto dealers including 1800CARSHOW, Detroit Trading, DriveTime and other third parties.


Service Provider Disclosure

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.

These services may include:

  • Providing an accurate quote for the products you choose
  • Providing customer service
  • Sending marketing communications
  • Conducting research and analysis
  • Providing communication relevant to your requests or transactions


Access to Personally Identifiable Information

If you wish to have a blog posting removed you may do so by contacting [email protected]. See “BLOG” below.

Upon request Empower Direct, LLC will provide you with information about whether we hold any of your personal information. If your personally identifiable information that we have transferred to an affiliate changes, you may correct, update, or delete your information by contacting us through email: [email protected] or by post: 822 Guilford Ave #102, Baltimore, MD 21202. We will respond to your request within a reasonable timeframe. Please contact our affiliated company at the same time to make the changes in accordance with their access policies.


Security of Your Personally Identifiable Information

We use industry standard practices to safeguard the confidentiality of your personal identifiable information, including “firewalls”, and Secure Socket Layers (SSL) encryption of sensitive data such as your social security number. We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside or outside the company. However, “perfect security” does not exist on the Internet so we encourage our users to use discretion when sharing personally identifiable information on the Internet and always read the privacy policy of the sites that you visit.


U.S. Patriot Act of 2001 Disclosure

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. When you apply for or open an account, we will ask for your name, address, date of birth and other information that will allow our Financial Institution Partners to identify you.


Log Files

As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We link this automatically-collected data to personally identifiable information. We use this information to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.


Tracking Technologies

Empower Direct, LLC and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.


Behavioral Targeting

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.


Blog

The information that you post to our BLOG will be displayed publicly. Please do not post your full name or any personally identifiable or sensitive information. If you wish to have a blog posting removed you may do so by contacting [email protected].


Email or Newsletter Preferences

You may sign-up to receive emails or newsletters or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at [email protected].


Links to Other Sites

This Web site contains links to other sites that are not owned or controlled by Buying Advice. Please be aware that we are not responsible for the privacy practices of such other sites.

We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.

This privacy statement applies only to information collected by this Web site.


Choice/Opt-out

We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes, when we ask for this information. For example, if you leave a comment in our blog but do not wish us to retain your e-mail address, you can indicate your preference on our comments form.

You will be notified when your personally identifiable information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.


Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Legal Disclaimer

In certain situations, Empower Direct, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site. If Empower Direct, LLC is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information, and to any other third party with your prior consent to do so.


Our Former Customers

We treat information about our former customers in the same manner as we treat information about our current customers.


Social Media Widgets

Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

Notice to California Residents—Your California Privacy Rights


The California Consumer Privacy Act (“CCPA”) provides eligible California residents with specific rights with respect to our collection, retention, and use of Personal Information. This California Privacy Rights section supplements this Privacy Policy and applies solely to eligible residents of California as of January 1, 2020. Any terms not defined in this section have the same meaning as defined in the CCPA.


Right to Request and Obtain Information Regarding Personal Information. The California Consumer Privacy Act of 2018 (Cal. Civ. Code Section 1798.100 et.seq) (“CCPA”) entitles California residents to request information about the consumer’s Personal Information collected by the business in the 12 months preceding the request and concerning the categories of Personal Information; the categories of sources from which the Personal Information was collected; the business or commercial purpose for collecting or selling the Personal Information; the categories of third parties with whom the business shares Personal Information; and the specific pieces of Personal Information that a business has collected about the individual consumer. If the business also sells or discloses the Personal Information for a business purpose, in addition to the foregoing information, the consumer has the right to obtain the categories of Personal Information that the business sold about the consumer in the 12 months preceding the request and the categories of their parties to whom the personal information was sold (by category or categories of Personal Information for each third party to whom the Personal Information was sold); and the categories of Personal Information that the business disclosed about the consumer for a business purpose. These requests for information must be made by a “verifiable request” (as defined by the CCPA and the rules and regulations thereunder). California residents who wish to request the foregoing information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us by email.


Right to Have Personal Information Deleted. The CCPA entitles California residents to request that a business delete all Personal Information about the consumer that the business has collected, subject to certain exceptions set forth in the CCPA. These requests for information must be made by a “verifiable request” (as defined by the CCPA and the rules and regulations thereunder). California residents who wish to request the foregoing information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us by email.


Right to Have Personal Information Deleted. The CCPA entitles California residents to request that a business delete all Personal Information about the consumer that the business has collected, subject to certain exceptions set forth in the CCPA. These requests for information must be made by a “verifiable request” (as defined by the CCPA and the rules and regulations thereunder). California residents who wish to request the foregoing information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us by email.


Right to Opt-out From the Sale of Your Personal Information to Third Parties. The CCPA entitles California residents to direct that a business that sells Personal Information about the consumer to third parties not to sell the consumer’s Personal Information. California residents who wish to exercise this right in compliance with this law or have questions or concerns about our privacy practices and policies may contact us by email. In addition, consumers may exercise this opt-out right by clicking the “Do Not Sell My Personal Information” button below.


No Discrimination Against Persons Exercising Rights Under the CCPA. BuyingAdvice will not discriminate against any Consumer because the Consumer exercised any of the Consumer’s rights under the CCPA. Unless permitted by applicable law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We do not currently offer any financial incentives with respect to the collection of your Personal Information. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.   Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. 


Information Regarding Collection and Sale of Personal Information and Requests.The following information regarding Personal Information collected and sold by BuyingAdvice and Consumer requests can be accessed, including:

  • A list of the categories of Personal Information collected by BuyingAdvice during the preceding 12 months and for each such category (i) the categories of sources from which the Personal Information was collected; (ii) the business or commercial purposes for which the Personal Information was collected; and (iii) the categories of Third Parties with whom the Personal Information was shared.
  • We sold or disclosed Personal Information to Third Parties for a business or commercial purpose during the preceding 12 months. The Twelve-Month Personal Information Categories Lists contain a list categories of Personal Information sold or disclosed for a business or commercial purpose during the preceding 12 months.
  • Metrics for the preceding 12 months regarding the following:
    • The number of requests to know about Personal Information collected that We received, compiled with in whole or in party, and denied.
    • The number of requests to delete Personal Information that We received, compiled with in whole or in party, and denied.
    • The number of requests to opt-out from the sale of Personal Information that We received, compiled with in whole or in party, and denied.
    • The median number of days within which We substantively responded to requests to know, requests to delete and requests to opt-out. 


Other California Privacy Rights. Right to Request Information Regarding Sharing of Personal Information With Third Parties for Direct Marketing Purposes . The California “Shine the Light Law” (Cal. Civil Code Section 1798.83) entitles California residents to request information concerning whether a business has disclosed certain Personal Information about the consumer during the immediately preceding calendar year to any third parties for the third parties’ direct marketing purposes. California residents who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us by email.


Children and Minors. Section 22581 of the California Business and Professions Code permits a resident of California who is both under the age of 18 and a registered user of any site on which this Privacy Policy is posted to request and obtain removal of content that the user has publicly posted. Please be aware that such requests do not ensure the complete removal of the content posted, and there may be circumstances in which the law does not require or allow removal, even if requested. To request removal of content under Section 22581 of the California Business and Professions Code, please contact us by email. We do not sell personal information that if we have actual knowledge that we collected or maintain for minors under the age of 16 without the affirmative consents required by the CCPA. 


Updates to Our Privacy Policy

As long as you remain a customer, we will provide you with an annual notice of this policy. We will provide this notice to current customers and those consumers whose non-public personally identifiable information we share as described above. We reserve the right to change this policy at any time. If we decide to make a material change to our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it prior to the change becoming effective.


For Vermont Residents

The information-sharing practices described above are in accordance with federal law. Vermont law places additional restrictions on sharing information about Vermont residents, for as long as they remain Vermont residents. In accordance with Vermont law:

  • We will not share consumer credit reports with our affiliates without your consent, and
  • We will only disclose your name, contact information and our own transaction and experience information to other financial institutions with which we have joint-marketing arrangements. Otherwise, we will share information in accordance with all of the practices described above

For any other issues, please contact our customer service department at [email protected]. Our mailing address is: 822 Guilford Ave #102, Baltimore, MD 21202

TRUSTe

In compliance with the California Consumer Privacy Act (CCPA), you have the option to enter your email address to ensure that your personal information will never be re-sold. In the interest in clarity, we do not re-sell consumer information, regardless of whether you opt out here.

DO NOT SELL MY PERSONAL INFORMATION