Effective Date: January 1, 2020
Overview of Information Collection Policy
In general, you can visit our Website without revealing any personally identifiable information about yourself to us. We do not collect, or require individuals to transmit, any personally identifiable financial information (as defined under Federal Regulation P (12 C.F.R. § 1016.3(q)), social security numbers (SSNs), or driver’s license numbers through our Website. However, some forms made available by Dealers through this Website may request that consumers provide personally identifiable financial information, SSNs or driver’s license numbers. We do not collect or use this information on our own behalf. We also do not automatically collect any other personally identifiable information about you through our Website.
Our Website automatically collects non-personally identifiable information about our Website users through our server logs, cookies, web beacons, and analytics tools, including:
The technical information we automatically collect does not enable us to personally identify you and is used to better understand our Website traffic, analyze the interests of our Website users, improve our Website and diagnose technical errors, and for business or marketing purposes. The only personally identifiable information we collect is information you choose to provide us through voluntary forms and features on our Website.
Cookies, Web Beacons, and Server Logs
Our Website may also use web beacons or pixel tags and other similar technologies, which are not placed on your computer but instead are embedded on certain pages of our Website or in emails. When you visit a page or read an email with a pixel tag, web beacon, or other similar technology, a generic notice of your interaction is generated.
How We Use Non-Personally Identifiable Information
Opting Out of Cookies, Web Beacons, and Similar Technologies
You can manage cookie preferences and opt out of having cookies and other similar collection technologies used by adjusting the settings on your web browser. If you do not want cookies stored on your computer, you can change the settings on your browser to notify you when a cookie is about to be saved or block cookies entirely. How to access these settings, which settings are available, and how to turn on these settings varies by browser type and we encourage you to further investigate your browser’s privacy settings if you wish to opt out or adjust these settings in any way. If you choose to decline or block cookies, you may not be able to fully utilize all of the interactive features of the Website.
You cannot decline web beacons; however, setting your browser to decline cookies or to prompt you for a response, or installing an ad-blocker, may keep web beacons from tracking your activity.
Do Not Track Signals
Collection of Personally Identifiable Financial Information and Other Personally Identifiable Information
We do not collect, or require individuals to transmit, any personally identifiable financial information (as defined under Federal Regulation P), social security numbers (SSNs), or driver’s license numbers in connection with your use of this Website. While Dealers may make forms available on this Website that request consumers provide personally identifiable financial information, SSNs, or driver’s license numbers, we do not collect or use this information on our own behalf. We do not collect other personally identifiable information through our Website unless you affirmatively and voluntarily provide this information to us through our Website features. For example, you may provide us personally identifiable information by completing contact forms, registering for or updating an account, signing up to sell your vehicle(s), creating an alert, replying to an ad on our Website, providing your billing information, or taking advantage of other voluntary services and features available through the Website.
If you use certain Website features, we may ask for personally identifiable information about you, including, but not limited to:
Personally Identifiable Information Sharing
We will use the personally identifiable information that you provide to us in any way that is legally permissible, including, without limitation, to provide services requested by you, to contact you regarding products and services, to conduct research and surveys, and to otherwise enhance your user experience. We may disclose your personally identifiable information if we believe it is necessary or useful to provide services to you or to inform you of other products or services available from us and our affiliates.
If you are not a Dealer, the personally identifiable information you provide us may be shared with Dealers. For example, if you ask for more information on a vehicle, set an inventory alert, participate in Live Chat, or comment on a vehicle, we will share this information with Dealers. We may provide Dealers with your personally identifiable information if we believe, in our sole discretion, that you may be interested in any products or services offered by that Dealer based on your interactions with our Website. We may also serve as a conduit for messages, chat, emails, and other communications between Dealers (or other third parties) and you.
We may store any of the information that you provide us indefinitely, including your personally identifiable information. This specifically includes, but is in no way limited to, the information you provide about yourself or a vehicle. Please see the “Personally Identifiable Information Security” section for more information about the security of your information and the “Changing Personally Identifiable Information” section for how you can change your personally identifiable information in our records.
Personally Identifiable Information Security
We use information technology security measures to protect your personally identifiable information that is transmitted through our Website. We also use information technology security features to protect the personally identifiable information stored by us. However, in spite of our security efforts and protocols, we cannot guarantee that information sent to us through our Website will be secure. Therefore, we make no warranties or representations regarding the security of your information.
Email Addresses and Phone Numbers
We and our third party service providers use e-mail addresses collected through the Website to uniquely identify and communicate with users of our Website and services. If you provide your e-mail address to us, we may share that information with third parties to contact you at your provided email address. Www.upbfs.com may also use your e-mail address to contact you regarding: new features, ad status, confirmation of registration, and other service-related notices.
Phone Calls with www.upbfs.com or a Dealer through this Website
You further agree and knowingly accept that any call you make to www.upbfs.com or a Dealer through this Website may be recorded for business purposes by www.upbfs.com. Additionally, you agree and consent that any call that you accept from www.upbfs.com may be recorded for business purposes. To cease additional recording, you can end your telephone call at any time. Voice recordings may be stored for an indefinite period of time.
Imports and Exports
DEALERS: We may share or export your information to third parties with whom you have opted in to having your listing or inventory shared. We may import a listing or your inventory from third parties with whom you have opted in to sharing. From time to time, we may import or export your inventory in connection with a third party from or to whom you have not opted in. You agree that we may rely on any third party import or export sharing, request, or receipt as being authorized by you, and we are under no obligation to verify the authorization of any import or export sharing, request or receipt received from a third party.
NON-DEALERS: We may share your information with third parties with whom you have opted in to having your listing shared. We may import a listing from a third-party with whom you have opted in to sharing. From time to time, we may import or export your listing in connection with a third party from or to whom you have not opted in, including through the For Sale feature. You agree that we may rely on any third party import or export sharing, request, or receipt as being authorized by you, and we are under no obligation to verify the authorization of any import or export sharing, request or receipt received from a third party.
Your California Privacy Rights
California Civil Code section 1798.83 requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personally identifiable information to third parties for the third parties’ direct marketing purposes. California residents who provide personally identifiable information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing purposes. In compliance with this law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, a copy of Www.upbfs.com ®‘s Information Sharing Disclosure Notice about the customer information we shared, if any, with other businesses for their own direct marketing purposes in the previous calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information on behalf of www.upbfs.com ®, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address. Please be aware that not all information sharing is covered by the “Shine the Light” law requirements and only information on covered sharing will be included in our response to your request.
Changing Personally Identifiable Information
It is important that we keep the most accurate, up-to-date information about you in our records. You may contact us to change the personally identifiable information we have collected about you through Back Office or Account Center or your account User Profile on our Website. We may require you to verify your identity before we change our records. Dealers may also call Customer Support at (330)-956-0336 to change their personally identifiable information.
We reserve the right in our sole discretion to disclose information about you without notice, including personally identifiable information, if it is necessary or appropriate to comply with applicable law, respond to legal claims and the legal process (including subpoenas), protect our rights, interests, or property, or if we believe in good faith that it is necessary to protect the personal safety of any person, including but not limited to: your safety, the safety of other Www.upbfs.com ® users or employees, the safety of the public, or the safety of any third party.
Personally Identifiable Information of Children
Our Website is not directed to anyone under the age of 18, and by using this Website, you are confirming that you are 18 years of age or older, or are over the age of 13 and using this Website with the consent and supervision of a parent or guardian. If a parent or guardian is aware or becomes aware that his or her child has provided us with personally identifiable information without consent, please contact us at: firstname.lastname@example.org, so we can remove the unauthorized information from our records.
This Website does not knowingly contact or collect personally identifiable information from children under the age of 13. This Website is not intended to solicit information of any kind from children under the age of 13. We do not knowingly collect or store information of children under 13, even in aggregate form. It is possible that through fraud or deceit we may receive information pertaining to children under the age of 13. Parents or guardians may report unauthorized use of our Website by a child under age 13 by contacting us at email@example.com. If we are notified of unauthorized use by a child under 13, upon verifying the information, we will immediately delete the unauthorized information from our servers and records.
This Website is not directed to anyone located outside of the United States, and this Website is controlled, operated, and administered by us from our offices within the United States of America. We do not knowingly offer goods or services to data subjects outside of the United States or monitor the behavior of persons (data subjects) located outside of the United States. By using or continuing to use this Website, you are confirming that you are located within the United States, and agree that you will not provide personal information on, or otherwise use, this Website if you are located outside of the United States. While this Website does not knowingly solicit, collect, or store the personal information of international users, through fraud, deceit, or other unauthorized or inadvertent disclosure, we may receive personal information pertaining to individuals located outside of the United States. If a person located outside of the United States becomes aware that he or she has provided us personal information, as defined in Article 4 of the General Data Protection Regulation (GDPR), please contact us at: firstname.lastname@example.org and, upon verifying the information, we will immediately delete the unauthorized information from our servers and records.
Links, Widgets, Embeds, Social Media, and Other Third Party Features
If we undergo any type of business transaction, including but not limited to an asset sale, merger, acquisition, bankruptcy, or restructuring, your personally identifiable information and/or technical information we obtain from you through this Website may be disclosed to any potential or actual purchasers and may be transferred to the new owners.
Opt-Out & Unsubscribe from Communications
We respect your privacy and give you an opportunity to opt-out of receiving certain communications from us. Users may opt-out of receiving certain email communications from www.upbfs.com by clicking on the unsubscribe link in any marketing or promotional email that you receive from us. Your receipt of certain communications and alerts from www.upbfs.com may also be altered through Back Office or Account Center.
How to Contact Us