CarLife (“CarLife”) complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. CarLife has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In certain situations, CarLife may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. CarLife remains liable for the onward transfer of personal data to third parties acting as CarLife’s agents, unless CarLife can prove it was not a party to the events giving rise to the damages. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Introduction

CarLife is a provider of live chat and digital marketing software and services for automotive dealerships. This privacy policy will help you understand what information we collect and use on behalf of an automotive dealership (the “Dealership”) at CarLife, and the choices you have associated with that information. This privacy policy concerns your use of websites with CarLife services and software that comprise the communications platform (the “Platform”) that CarLife operates for Dealerships. For information about the use of your credit history, score, rating or related credit information that you may make available to the Dealership when you inquire about your credit eligibility or apply for financing, please carefully review the Hard Credit Pull and Soft Credit Pull Disclosures and Consents provided to you when have the option to permit a Dealership to access and use your credit information. In operating the Platform for the Dealership, CarLife is a service provider for the Dealership and all communications you have through the Platform are processed by CarLife for the Dealership. Your communications with CarLife are on behalf of the Dealership.

If you have any questions about this privacy policy or our practices, please contact us. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may submit a claim by following the instructions at https://www.jamsadr.com/eu-us-privacy-shield.

Collecting User Behavioral Information and Personal Information.

When you visit a website (the “Website”) with CarLife services and software, CarLife may collect, retain and use information pertaining to your click and viewing behavior on the website (“Behavioral Information”). If you also submit your Personal Information (as defined below), either in a web form submission, live web chat, sms, or other form of digital conversational medium, your Personal Information may be collected, retained, used and linked to your Behavioral Information that we have collected. “Personal Information” means personally identifiable information that includes your name and contact information (your phone number, address or email address). We may also obtain and use data and information about your online activity or metadata about you (such as geo-location data) either on or off the Website from third party sources in order to improve your experience with CarLife or the Website and to provide the services. If you engage in any live web chat or sms conversation using our services, we may also store any transcripts (“Transcripts”) from such conversations and link those Transcripts to your Personal Information and Behavioral Information. Some additional examples of services that may require use of Personal Information include using your address for delivery of products that you have requested (e.g., vehicles), using credit card information to process a payment that you have authorized, and submitting a credit application to lending institutions with your consent.

How your Behavioral Information is collected and used.

To enhance your experience and provide more personalized service, we may use a feature called a cookie and/or other similar methods to track your behavior on the Website. Cookies are small files that your web browser places on your computer’s hard drive. They are used for a variety of purposes, such as tracking click behavior. Data that is tracked through these mechanisms may include, but are not limited to: (i) your domain name; (ii) your IP address; (iii) the type of web browser, device and operating system being used; and (iv) the pages of a Website that you visit or the files that you request. Most internet browsers enable you to block cookies in the preferences or settings of the internet browser. Please refer to your browser’s documentation for instructions on how to block cookies in your browser’s settings.

We use Behavioral Information to better understand how visitors use the Website in order to deliver a more personalized experience for you on the Website and in the Website owner’s physical store, and to improve our services to better meet your needs. We may also use cookies in order to help us or third parties display advertising to you when you visit the Website or third-party sites based on your interest displayed by your behavior on the Website.

The CarLife website (www.CarLife.com) uses technologies of third-party partners to help us recognize your device and understand how you use our site so that we can improve our services to reflect your interests and serve you advertisements about the products and/or services that are likely to be of more interest to you. Specifically, these partners collect information about your activity on our site to enable us to: (i) measure and analyse traffic and browsing activity on our site; and (ii) show advertisements for our products and/or services to you on third-party sites. We may share data, such as hashed email derived from emails or other online identifiers collected on our site with our advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by our partner and their cross-device capabilities please refer to the privacy policy at https://www.nextroll.com/. Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest based advertising:
The NAI’s opt-out platform: https://www.networkadvertising.org/choices/
The EDAA’s opt-out platform: https://www.youronlinechoices.com/
The DAA’s opt-out platform: https://optout.aboutads.info/?c=2&lang=EN

Linking Behavioral Information to Personal Information.

If you voluntarily provide CarLife with your name and contact information through a web chat or web form submission, we may link your Behavioral Information to your Personal Information. We may provide this linked information to the company whose Website you have submitted your Personal Information on, as well as use this data to improve your service and experience on the Website.

To whom your information is disclosed.

We will not share your Personal Information, Behavioral Information and Transcripts with any third parties except for (a) CarLife’s third-party service providers, (b) the company or companies whom CarLife is providing services to (or such company’s third-party service providers) and whose Website you have submitted your Personal Information on; or (c) to other third parties that you consent to (for example, a finance company, bank, or other financial institution when you request credit eligibility or apply for financing through a Dealership). Anonymous or aggregated Behavioral Information, meaning Behavioral Information that does not include Personal Information, may be shared with third-parties in order to improve your overall internet experience, display more relevant internet advertisements to you based on your interest in and behavior on the Website, or provide aggregated statistical data for reporting and analytics purposes.

We also may share your Personal Information, Behavioral Information and Transcripts as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.

Communication.

CarLife or the Website owner may need to communicate with you for a variety of reasons, including but not limited to:

• If you submit a contact form with your Personal Information
• If you have a live chat or sms conversation or similar interaction and submit your Personal Information
• If you request credit eligibility information or apply for financing

Consent.

Your knowledge and consent are generally required before we may collect, use or disclose your Personal Information. BY USING THE WEBSITE, YOU HEREBY CONSENT TO THE COLLECTION AND USE OF BEHAVIORAL INFORMATION AND PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. If you would like to request credit eligibility or apply for financing, you will need to provide your consent separately, through the Hard Credit Pull and Soft Credit Pull Disclosures and Consents provided to you when have the option to permit a Dealership to access and use your credit information.

Protection of Personal Information.

Your Personal Information is stored in CarLife’s databases (or CarLife’s service providers’ databases) using security practices in accordance with industry standard practices. In some cases, your Personal Information may be stored in the Website owner’s databases (or the Website owner’s service providers’ databases). Please refer to the Website owner’s privacy policy for more information.

How a Customer Accesses their Personal Information.

If you want access to your Personal Information, you may make a request to CarLife at the contact address below. In some cases, CarLife may direct you to contact the Website owner to help you with your request.

How long we retain Behavioral Information and Personal Information.

We retain records of your Personal Information in our databases until you request us to delete such records or as otherwise required by applicable law. Your Behavioral Information may be retained for up to seven years.

Withdrawing Consent.

You may withdraw your consent to the collection, use and/or disclosure of your Personal Information that is linked with your Behavioral Information at any time on reasonable notice by contacting us. If you withdraw your consent, we may still provide your Personal Information (that is not linked with your Behavioral Information) to the company whose Website you have voluntarily submitted your Personal Information on, as well as collect and use your Behavioral Information to provide the services. Please refer to the Website owner’s privacy policy for more information.

Your rights with respect to Personal Information and Behavioral Information.

You may also ask us to provide you with your Personal Information and any linked Behavioral Information that we have collected at any time, or to destroy any record of your Personal Information in our database by contacting us. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, you may invoke binding arbitration in the event of dispute between us.