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Privacy Policy

Effective as of February 14, 2023.

This Privacy Policy describes how CarPay, Inc. (“CarPay”) handles personal information of consumers who shop for and buy cars from auto dealers that use our platform. CarPay is a service provider to dealers. Our technology helps dealers gather information from consumers that dealers need to qualify the consumer for a loan. After a consumer obtains a loan, they use CarPay to make loan payments. In providing our services, CarPay handles the consumer’s personal information on behalf of the dealer for the purposes set out in our agreement with the dealer.

Personal information we collect

Information you provide to us. Personal information CarPay collects on behalf of dealers includes:

  • Contact information, such as your first and last name, email address, billing and mailing addresses, and phone number.
  • Identification details, such as date of birth, social security number, driver’s license number, and government-issued ID.
  • Financial information, including financial account log-in credentials, account balances and transaction history (which we may obtain via a third-party such as Plaid Inc.), and loan balance and payment details.
  • Vehicle data, such as mileage, make and model, vehicle identification number, and the value for vehicles that you shop for, buy, or want to trade in.
  • Payment data, such as payment card information, bank account number, and other billing information to facilitate loan payments.
  • Data about others with whom you may jointly purchase a vehicle, such as their name and phone number. Please do not share their information with us unless you have their permission to do so.

Automatic data collection. We, our service providers, and our business partners may automatically log information — using cookies, web beacons, SDKs, and similar technologies — about you, your computer or mobile device, and your activity over time on our sites, our mobile application, other sites, and online services, including:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g ., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
  • Precise geolocation data when you authorize our mobile application to access your device’s location.

How we use your personal information

Providing our services. We use the personal information we collect to provide, operate, and improve the services we provide to dealers, including to:

  • Assist the dealer in obtaining your credit report and organizing your personal information for potential vehicle purchases,
  • Facilitate your vehicle loan payments and communicate with you about your payments, including through payment reminders, and
  • Provide support for our services and respond to your requests, questions, and feedback.

Research and development. We may use the information we collect to maintain, improve, and enhance our services and service offerings. We may also create aggregated and/or de-identified data from personal information by removing information that makes the data personally identifiable to you.

Marketing. We may email you marketing communications on behalf of dealers. You may opt-out of these marketing communications as described in the Opt-out of marketing communications section below.

Compliance and protection. We may use your personal information to:

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities,
  • Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims),
  • Enforce the terms and conditions that govern the services, and
  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

How we share your personal information

We may share your personal information with:

Dealers and companies on behalf of dealers at their direction, including financial institutions to facilitate loan payments.

Service providers. Companies and individuals that provide services on our behalf or help us operate the services or our business (such as information technology, hosting, customer relationship management and support, email delivery, marketing, website analytics, payment processing, and credit screening).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquiring and other relevant parties to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, CarPay or our affiliates (including in connection with a bankruptcy or similar proceedings).

Your choices

You have the following choices with respect to your personal information.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us You may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of our services or they may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Mobile location data. Users of our mobile application can disable our access to their device’s precise geolocation in their mobile device settings.

Do Not Track. Some Internet browsers may be configured to send “ Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Third party platforms. If you choose to connect your accounts on other platforms, to our services (for example, your bank account), you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

Our services may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Dealer personnel

We collect personal information from an auto dealer’s personnel (such as their employees and contractors) to provide our services to the dealer, for research and development, and for compliance and protection as described above. We may share the personal information with business transferees as described above.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

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