Privacy Policy

This Privacy Policy shall be effective as of April 7, 2024.

At Auto Trades Direct, we prioritize and safeguard the privacy of our website visitors and clients. We hold our clients’ privacy in high regard and have crafted this Privacy Policy to underscore our dedication to privacy protection. This Privacy Policy, unless specified otherwise, outlines our practices concerning the handling of your information when you engage with our services. This encompasses content found on this website, other websites, pages, features, or content we manage or operate (collectively referred to as the “Sites”), third-party applications relying on API, and any related services (hereinafter collectively referred to as “Services”).

The Sites target a general audience and do not knowingly collect personal or other information from minors below the age of 18 intentionally. If you are below 18, please do not use our sites. Should we determine that any information collected is indeed that of a person under the age of 18, we will promptly undertake to delete, aggregate, or anonymize such information. We encourage the reporting of any known usage of our services by individuals under 18 so appropriate measures to block access can be implemented.

ATD facilitates connections between Automotive Dealerships and utilizes data-driven insights and industry expertise to help dealerships identify opportunities and optimize inventory strategies, as well as, arranges transportation of vehicles between Selling Automotive Dealerships and Buying Automotive Dealership. This Privacy Policy is applicable to all individuals interacting with our Sites.

We advise you to review the Terms of Service associated with ATD. In instances where your consent is necessary for the processing of your personal data, we will solicit your consent for the collection, utilization, and sharing of your personal information as detailed herein. Additionally, We may provide additional “just-in-time” disclosures or information about the data handling protocols of specific Services. These advisories are intended to complement or elucidate our privacy approaches or to furnish you with further options regarding the management of your data by us.

1. Types of Information that is Collected

We collect various types of information about you and your business when you access our Sites.

Our Sites collect information that identifies, relates to, describes, references, is reasonably capable of being connected with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal information does not encompass:

• Publicly accessible information from government records.
• Deidentified or aggregated consumer information.

To set up an account and access our Services, we will ask you to supply us with essential information about you. This information is either mandated by law (e.g., for identity verification), required to provide the services requested, or is pertinent for specific purposes, detailed more comprehensively below. As we introduce new features and Services, you may be prompted to provide more information.

Please be aware that if you opt not to provide certain information, we may not be able to serve you, or the quality of our Services may be affected.

1.1 Information We Collect Directly From You:

We gather information directly from you about you.

• Personal Identification Information: Full name, signature, photographs, phone number, IP Address, and email.
• Transaction Information: Data about the transactions you conduct through our Services, including recipient names, amounts, and timestamps.
• Employment Information: Workplace location, job title, and description of role.
• Business Information: Business type, list of executives, members, or managers.
• Financial and Tax Information: Tax Identification Number (EIN), banking information (such as account and routing numbers), and other financial details required for transactions and compliance.
• Dealer Identification Information: Dealer Identification IDs (e.g., BAC) and any other identifiers required to verify dealership credentials.

The documents and information collected are securely stored and protected. To fulfill our service commitments to you, you grant permission for us to share all information provided to or gathered by ATD on your behalf with other entities for ATD’s business needs, or to fulfill legal and regulatory obligations. We will not disclose, transmit, or share these documents without your explicit consent, unless the disclosure is pursuant to legal and regulatory mandates that prohibit such notification.

1.2 Information We Collect from You Automatically

We gather data regarding your computer’s interactions with our Sites for numerous reasons.

We acquire and save specific types of information by default, like when you engage with the Sites or utilize the Services. This information enables us to address customer support concerns, enhance the functionality of our Sites and applications, offer a seamless and personalized experience, and safeguard your account from fraudulent activities by detecting unauthorized access. Automatically collected information includes:

• Online Identifiers: Geolocation/tracking details, browser fingerprint, operating system details, browser type and version, and/or device IP addresses.
• Usage Data: Authentication data, security answers, click-stream data, content of public social networking posts, and other data collected via cookies and analogous technologies.

For instance, our server logs may automatically record information such as:

• Your navigation path to and usage of the Services;
• Type of device and unique device identifier numbers;
• Device event data (such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request, and referral URL);
• Interaction details between your device and our Sites and Services, including accessed pages and clicked links;
• Geographical location; and,
• Additional technical data collected through cookies, pixel tags, and other technologies that uniquely identify your browser.

We may also employ identifiers to recognize you when you access our Sites through an external link, such as one present on a third-party site.

1.3 Information Collected from Third Parties

Occasionally, we might acquire information about you from outside sources that are legally permissible. These external sources may encompass:

• Public Databases & ID Verification Partners: We retrieve information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law.
• Collaborative Marketing Entities & Distributors: When not restricted by law, such partners may share insights with us so we can better ascertain which of our Services might interest you.
• Promotional Networks & Analytic Service Providers: These providers offer us anonymized details about your discovery of our Sites and your interaction with our digital assets and Services, possibly before you set up an account.
• Business Websites & Vehicle Listing Platforms: We collect publicly available information from your business’s website, vehicle listing platforms, or other online directories to verify dealership details, inventory listings, and related data relevant to our services.

1.4 Anonymization and Aggregation of Data

Anonymized and collective data may be utilized by us for any commercial objective.

Data anonymization is a method that alters or removes personal information so it can’t be linked with an individual. This Privacy Policy’s other sections do not cover anonymized or aggregate customer information (i.e., customer data that we combine, thus it no longer identifies an individual).

ATD may deploy anonymized or aggregate data for business aims, such as understanding customer necessities and behaviors, enhancing our offerings, conducting market research, and security threat identification. We may conduct analytics on anonymized datasets or use third-party analytics services.

Data types we may anonymize encompass transaction details, browsing data, performance metrics, and indicators of fraud. Furthermore, in compliance with applicable laws on personal information deletion, should you request your data to be purged as elaborated in the policies described below, your data will be anonymized or aggregated.

2. How information is gathered

We gather information about you during your use of our services, as well as through your interactions with our Sites.

Where we require your consent to handle your personal information, we will seek your agreement to the gathering, usage, and sharing of your personal information as outlined further below. We may offer additional “just-in-time” notices or details about the data handling practices of particular Services. These notices may supplement or clarify our privacy policies or may offer you more choices regarding how we process your information. If you disagree with or are uncomfortable with any aspect of this Privacy Policy, you should immediately stop accessing or using our Services.

We gather the types of personal information listed below from the sources indicated:

• Directly from you: For example, from forms you fill out or through our Products and Services.
• Indirectly from you: For example, by observing your activities on our Sites.
• Third Parties: For example, from third-party services that you link to as part of using our Services.

Emails and telephone calls:

We ask for an email address from you when you sign up for our services. We use your email for transactional (e.g., updates, confirmation, etc.) and promotional (e.g., newsletters, new offerings, event notices) purposes. Email messages we send may include code that enables our database to track your interaction with the emails, including whether the email was opened and what links (if any) were clicked. If you prefer not to receive promotional emails from us, please refer to the section below labeled “Choice/Opt-Out”. We reserve the right to send you certain communications related to the ATD services, such as service announcements and administrative messages, without offering you the chance to opt out of receiving them. We may also contact you via telephone or text message (including to any wireless number you may provide to us) solely in connection with ATD’s services. If you prefer not to receive telephone calls or text messages from us, you can change or delete your number from your account preferences page(s), or request to be removed from our contact list if you receive a call or text message from us. We fully adhere to the U.S. CAN-SPAM Act, the Telephone Sales Rule, and the Telephone Consumer Protection Act (TCPA).

Log files:

Each time you visit any of our Sites, our servers automatically collect information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and click count) to analyze trends, administer the Sites, prevent fraud, track visitor movement in the aggregate, and collect broad demographic information. For instance, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This helps us understand which parts of our sites users are visiting. We do not share the log files externally.

Cookies and Similar Technologies:

“Cookies” are pieces of information that may be placed on your computer by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes.  We may use cookies (and similar items such as clear gifs, web beacons, tags, etc.) on our Service to customize your visit and for other purposes to make your visit more convenient or to enable us to enhance our Service.  We may also use and place cookies (and similar items) on your computer from our third party service providers in connection with the Service, such as an analytics provider that helps us manage and analyze Service usage, as described more fully below.  In addition, our advertisers and business partners may set cookies and similar items on your computer when you use our Service.  You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Service, but it may interfere with some of its functionality. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your computer without your knowledge.

If you delete your cookies, change browsers or use a different cookie, our cookie (or an opt-out cookie) may no longer work and you will have to reinput (or opt-out) again.

Analytics and Conversion Tracking:

We may use analytics services that use cookies, javascript and similar technologies to help us analyze how users use the Sites. The information generated by these services about your use of the Sites (including your IP address or a truncated version of your IP address) is transmitted to and stored by analytics service providers on their servers. Those service providers will use this information for the purpose of evaluating your, and other users’, use of the Sites, compiling reports for us on website activity and providing other services relating to website activity and Internet usage.

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For example, we use cookies on our sites for Google Analytics (the “Analytics Service”). The Analytics Service is a web-based analytics tool that helps website owners understand how visitors engage with their website. The Analytics Service customers can view a variety of reports about how visitors interact with their website so that they can improve it.

Like many services, the Analytics Service uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our sites. We then use the information to compile reports and to help us improve our site.

Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.

The Analytics Service collects information anonymously. They report website trends without identifying individual visitors. You can opt out of the Analytics Service without affecting how you visit our sites. For more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.

We may also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Sites.

3. How your information is utilized

We utilize your information for several purposes, all of which support ATD’s Sites and Services.

• Provide ATD services: We process your personal and/or dealership data to deliver the Services to you. We are unable to offer you Services without this information.
• To deliver Service communications: We send administrative or account-related messages to keep you informed about our Services, notify you of relevant security issues or updates, or provide other transaction-related information. Without these communications, you might not be aware of important updates regarding your account that could impact how you use our Services. You may not opt out of receiving essential service communications, such as emails or mobile notifications sent for legal or security reasons;
• To offer Customer service: We process your personal data when you contact us to address any questions, disputes, collect fees, or to troubleshoot issues. Without processing your personal data for such purposes, we can’t respond to your requests and ensure your seamless use of the Services;
• For research and development: We process your personal data to better understand how you use and interact with ATD’s Services. Furthermore, we use such information to tailor, measure, and enhance ATD’s Services, and to develop new services. Without this processing, we can’t guarantee your continued satisfaction with our Services;
• To improve your experience: We process your personal data to provide a customized experience, and implement the preferences you express. For example, you might choose to grant us access to certain personal data held by third parties. Without such processing, we may be unable to ensure your complete enjoyment of part or all of our Services;
• To facilitate corporate transactions: We may process any data related to your account and usage of our Services as necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option to close your account if you prefer not to have your personal data processed for these purposes.
• To maintain legal and regulatory compliance: Our core Services often fall under laws and regulations requiring us to collect, use, and store your personal data in specific ways.
• To enforce our terms in our user agreement and other agreements: We actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect breaches of our posted user agreement or agreements for other Services;
• To detect and prevent fraud: We process your personal data to help detect, prevent, and mitigate fraud and misuse of our services and to protect you against account compromise or information loss;
• For Quality control: We process your personal data for quality control and staff training to ensure we continue to offer you accurate information. Without processing personal data for quality control purposes, you might encounter issues with the Services;
• To ensure network and information security: We process your personal data to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks, and to comply with applicable security laws and regulations. The constantly evolving threat landscape on the internet underscores the importance of having accurate and up-to-date information about your use of our Services. Without processing your personal data, we might not be able to secure our Services;

4. Disclosure of information to third parties

We may share your personal information as required by law, to deliver the Services, and for valid business reasons.

We share your personal information by disclosing it to a third party for a legitimate business purpose. These disclosures for business purposes are made under written agreements that outline the uses, mandate the confidentiality of the personal information, and forbid the use of the disclosed information for any purpose other than executing the contract.

4.1. Disclosure By Law:

You acknowledge and agree that we may share information you provide if necessary by law, at the request of a third party, or if we, in our sole judgment, determine that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is mandated by applicable law); and (2) protect or defend ATD’s, or a third party’s, rights or property.

4.2. Service Providers

With service providers under contract who assist with parts of our business operations. Our contracts demand these service providers to use your information only in relation to the services they provide for us and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (aside from those mentioned above) include:

• Network infrastructure
• Cloud storage
• Payment processing
• Transaction monitoring
• Security
• Document repository services
• Customer support
• Internet (e.g., ISPs)
• Data analytics
• Information Technology
• Marketing

4.3. Other Companies

With companies or other entities that we plan to merge with or be acquired by. Notice of any changes in applicable policies will be provided in advance.

4.4. Third party advertising sites and providers

We may share certain personal information with, or make certain personal information available to, third-party advertising sites and providers, such as Usage Data and Online Identifiers, when you visit certain of our Sites or specific portions of our Sites.

4.5. Professionals

With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services to complete third-party financial, technical, compliance, and legal audits of our operations or otherwise comply with our legal obligations.

4.6. Miscellaneous

We may disclose your personal information for any purpose with your consent.

5. Updating, accessing, retaining, and deleting your information

You may choose to update, access, or delete your data; however, we may be legally required to retain your information to comply with the law.

You may update or access your contact information at any time by submitting a request to ATD.

You may delete your account from ATD under certain conditions by submitting a request to ATD to delete your account. In specific situations, ATD is legally obligated to maintain the information in your account. Under these conditions, ATD will place your account into a deactivated status, opt you out of all communications, and disable your access to the account.

In cases where ATD can fulfill your request to delete your account, the data you provided to ATD will be retained in a commercially reasonable manner and in compliance with relevant laws. After your account is deleted, ATD will not share your information and will use your data solely for internal research and ATD marketing purposes. Data retained by ATD will be kept for a commercially reasonable period as determined by ATD in accordance with applicable law.

We store your personal information securely for the duration of your ATD Account. We will retain your personal information only as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements or to resolve disputes. While retention periods vary by jurisdiction, information about our typical retention periods for different aspects of your personal information is described below.

1. Personal data collected to adhere to our legal requirements may be preserved following account termination for the duration mandated by such statutes.
2. Your contact details, including name, email, and phone number, utilized for marketing activities, are maintained indefinitely until you opt out. Following your unsubscribing, your information will be placed on our suppression list to prevent accidental outreach
3. The content you contribute to our sites, such as comments on support desks, photos, videos, blog entries, and other materials, may be stored post-account deactivation for auditing and fraud prevention objectives (for instance, to deter a previously identified fraudulent individual from establishing a new account).
4. Recordings of our telephone calls with you may be kept for a period of up to six years.

Information collected via technical means such as cookies, webpage counters, and other analytics tools is kept for a period of up to one year from the expiry of the cookie.

Opting out of receiving electronic communications from us. If you no longer wish to receive promotional email communications from us, please follow the instructions provided in Section 7 below.

Your California privacy rights. In addition to the above, if you are a California resident, please review our California Privacy Notice to learn more about the personal information we collect, use, and disclose, as well as your privacy rights related to your personal information under the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA), as well as other state laws.

6. Security

We have implemented measures to safeguard your information in a manner that is considered commercially reasonable.

We employ comprehensive security protocols to prevent the loss, misuse, and alteration of the information under our care. These protocols include the application of industry-standard encryption techniques and restricted administrative access to site data, along with other proprietary security measures enforced across all storage and transmission channels for user data. We are committed to ensuring the secure transfer of information between your computer and our servers. However, it must be acknowledged that no transmission over the Internet can be deemed entirely secure, and thus we cannot guarantee or warrant the absolute security of any information transmitted to us online, leading to our non-liability for any unintentional disclosure. For additional details, please consult our Terms of Service.

Should there be a data breach at ATD, we will inform you as promptly as is feasible. We will advise you that a breach has occurred and provide any other pertinent details necessary to meet our obligations under applicable breach notification statutes and regulations.

It is crucial not to share your account login and/or password with others. The confidentiality of your account login and/or password is imperative, and disclosing your account details may increase the risk of unauthorized access to your account.

7. Choice / Opt out of Marketing

You have the option to cease using our services.

You may decide not to receive our newsletter or marketing emails by following the unsubscribe instructions included in these emails, or you can contact us at [email protected].

Choosing not to share specific information with us may result in an inability to access certain features of the sites and secure the services and products you seek. Generally, it’s advised not to share personal information in public forums. You bear the sole responsibility for any personal information you choose to disclose in such settings.

Should you choose to discontinue our services after registration, and wish to no longer receive communications from lenders, brokers, or other third parties your information has been shared with, you can cancel your account as outlined herein. Once your account is canceled, we will no longer forward your information to third parties. However, this does not ensure that these entities will stop contacting you or using your information. It’s important to directly contact all third parties to request they stop contacting you.

Due to specific federal and state laws, we are required to keep a record of your information for predetermined periods. Because of these regulations, we might be unable to entirely remove your data from our records until these legal storage durations have been met.

8. California Privacy Notice

Along with the rights outlined earlier, the information in this section is specifically for individuals residing in the State of California. This notice is created in adherence to the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively referred to as the “CCPA”), and any terms defined in the CCPA hold identical meanings in the context of this Policy.

Starting January 1, 2020, in accordance with the California Consumer Privacy Act of 2018 (“CCPA”), residents of California are granted certain rights regarding their personal information, though there are a few exceptions. Any terms defined by the CCPA retain their defined meanings when applied within this California Privacy Notice.

CATEGORY	EXAMPLES
Identifiers	Includes an individual’s full name, electronic mail address, contact number, residential address, social security number, driver’s license, passport, or other identification issued by a government body; login and account information; Employer Identification Number (or an analogous identifier assigned by a governmental entity); alongside additional contact and identity verification details.
Personal information types as outlined in the California Civil Code § 1798.80(e)	Encompasses an individual’s full name, contact number, residential address, signature, social security number, driver’s license, passport, or other documentation issued by a government; financial transaction instruments information; banking details.
Internet or other electronic activity information	Includes digital identifiers like cookies, pixel trackers, integrated scripts; identifiers such as IP address, device ID, type of device, types of internet browsers and their versions, screen resolution, operating system details including name and version, device manufacturer and model, language preferences, as well as plugins; additionally, geographical location data, browsing patterns including duration on the Sites, pages viewed, links engaged with, language selections, usage trends, and the sources that directed or referred you to our Sites including specific Websites and Applications.
Protected classification characteristics under California or federal statutes	Date of birth; demographic details including nationality and gender among others.
Commercial information	Details on payment histories; account standings and activities; records of products and services purchased, acquired, or under consideration; utility billing information; profit and loss statements; income declarations; credit ratings and other credit-related details; data on transactions conducted through the Services; and/or other purchasing or consumption histories, tendencies, and preferences.
Geolocation data	Location information determined through the Global Positioning System (“GPS”) based on your IP address.
Audio, electronic, or visual data	Imagery; audio recordings from interactions with our customer support.
Professional or employment-related details	Worksite location, position title, and/or job responsibilities.
Inferences drawn about you	Assumptions made from data regarding an individual to compile a profile about a consumer reflecting the consumer’s preferences, traits, psychological trends, predispositions, behavior, attitudes, intelligence, capabilities, and aptitudes.

Sensitive Personal Information. A portion of the personal information we collect, as outlined previously, may be classified as “sensitive personal information” under the laws of California, encompassing:

• Driver’s license, state identification card, and/or passport numbers.
• Account login details in conjunction with any necessary security or access codes, passwords, or other credentials enabling account access.
• Exact geographic location.
• Racial and/or ethnic background.
• Data related to sex life or sexual orientation.

The particular categories of personal information we gather are elaborated upon in Section 1 of this Privacy Policy. Personal information does not encompass data that the CCPA does not cover.

ATD commits to not holding onto any information we collect from you for a duration exceeding what is considered reasonably necessary for the purposes disclosed for using such information. Our decision on specific retention periods is influenced by (i) the duration of our ongoing relationship with you; (ii) any legal obligations we must adhere to; and (iii) whether retention is deemed prudent in view of our legal standing (for example, relating to applicable statutes of limitations, legal proceedings, or regulatory inquiries).

8.2 Utilization of Personal Information

ATD may gather, employ, or reveal personal information regarding California residents for purposed enumerated in Section 3 of this Privacy Policy.

The sensitive personal information gathered as delineated above may be utilized for any of these outlined purposes.

8.3 Acquisition of Personal Information

ATD may accumulate personal information concerning California residents from the categories of sources indicated in Sections 1.3 and 2 of this Privacy Policy.

8.4 Sharing of Personal Information

We may share your personal information to the categories of service providers and third parties specified in Section 4 of this Privacy Policy, following the methodologies described therein.

This encompasses the sharing of your personal information with service providers for a business purpose. Whenever we share personal information for a business purpose, we enter a contract that delineates the purpose and obligates the recipient to maintain the confidentiality of that personal information and prohibits its use for any purposes other than fulfilling the contract. In the previous twelve (12) months, we have disclosed each category of personal information listed in Section 8(a), including the sensitive personal information noted, for a business purpose.

Moreover, ATD “sells”/”shares” specific personal information, as those terms are interpreted by the CCPA, for the aims of cross-contextual behavioral advertising, as defined by the CCPA. Similar to many online entities, ATD collaborates with third-party advertising platforms and similar providers to manage our promotional/marketing efforts of ATD on other platforms, where such advertising is predicated on your historical interactions with our Sites and Services. These third-party collaborators might employ technologies like cookies and pixels to collect data about your activities on the Sites and Services for the purpose of presenting such advertising when you navigate their platforms. For additional insights regarding this activity, kindly consult our explanations in Sections 1.2, 2, and 5 of our Privacy Policy.

The CCPA mandates the disclosure of the types of personal information we have “sold”/”shared” as defined under the CCPA in the preceding twelve (12) months. Over the last twelve months, we have “sold”/”shared” the following categories of personal information with advertising partners for cross-context behavioral advertising objectives:

• Identifiers
• Internet or other similar network activity data
• Personal information types as specified in the California Civil Code § 1798.80(e)
• Internet or other electronic activity data

8.5 Your California Privacy Rights

The California Consumer Privacy Act (CCPA) grants California residents specific rights regarding their personal information. This section outlines your rights under the CCPA and provides guidance on how to exercise them.

As a California resident, under applicable California legislation, you possess the right to make requests concerning your personal information, with some exceptions:

• Right to Know: Up to twice in a 12-month period, you may request details about the personal information we collect, utilize, disclose, and/or sell, including to whom it is disclosed or sold. You can request either a general report of the categories of personal information we collect or a detailed report of the specific pieces of personal information.
• Right to Delete: Under certain conditions, you may request the deletion of your personal information that we have collected.
• Right to Opt-Out of Sale or Sharing: You may opt-out of the sale or sharing of your personal information, as defined under California law.
• Right to Limit Use and Disclosure: You can request that the use or disclosure of your sensitive personal information be limited to necessary purposes for providing our products and services to you or for other authorized purposes. We will not use or disclose your sensitive personal information post-exercise of this right unless further consent is provided for additional uses.
• Right to Correct: You may request corrections to your inaccurate personal information.
• Right to Non-Discrimination: You are entitled to not receive discriminatory treatment for exercising the privacy rights described herein.

How to Submit a Request

You can exercise your rights by completing by submitting a request to [email protected].

Your request will undergo an identification and residency verification process as allowed by the CCPA. We will not fulfill your request without adequate verification of your identity. Verification requires providing your first name, last name, and email address.

Requests by Authorized Agents: If you are a California resident, you may designate an authorized agent for making requests on your behalf, they must provide proof of their authorization or evidence of power of attorney per the California Probate Code sections 4000 to 4465. Requests from agents without sufficient proof of authorization or unable to verify their identity will be denied.

Household Data: We do not collect household data. Requests submitted by all members of a household will be addressed individually. Requests from household members under the age of 18 will be declined, as we do not collect information from minors.

Responses: We aim to respond within forty-five (45) days following receipt of a Verifiable Consumer Request, applicable for requests covering up to a twelve-month period and limited to two occasions per year. We reserve the right to extend the response period by an additional forty-five (45) days when necessary, with timely notification of such extension.

These rights are subject to certain exclusions and exceptions under both California law and other relevant laws. If we cannot verify your identity with a reasonable degree of certainty as required by the CCPA, we will provide a written explanation and the reasons for our inability to verify.

Direct Marketing by Third Parties: ATD does not share personal information with third parties for their direct marketing purposes. Nonetheless, California residents have additional rights to request information about such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please email [email protected].

We will continue to update our practices in alignment with direct regulatory guidance as it becomes available.

8.6 Notification of Right to Opt-Out

As elaborated in Section 10.4 above, ATD engages in the “sale”/”sharing” of personal information with third parties for the aim of cross-context behavioral advertising, in accordance with the definitions provided by the CCPA.

Should you prefer to opt-out of the “sale”/”sharing” of the specific personal information collected during your interactions with our Sites and Services for the purpose of cross-context behavioral advertising, you may do so by submitting a request to [email protected].

9. Notice to Vermont Residents

Residents of Vermont are entitled to extra restrictions on the sharing of their personal information, with certain exceptions in place.

Under Vermont law, there are further restrictions on the dissemination of information regarding Vermont residents, provided they continue to reside in Vermont. In line with Vermont regulations, we will not share information we gather about Vermont residents with external organizations apart from ATD, except: (1) As the law allows; (2) With entities conducting marketing or providing services on our behalf; (3) Names, contact details, and information related to transactions and experiences with other financial institutions under joint marketing agreements; or (4) Upon receiving the explicit approval or consent from the Vermont resident. Furthermore, we will not divulge non-transactional data about Vermont residents obtained from our affiliates without the Vermont resident’s explicit consent.

10. Notice to Nevada Residents

Under Chapter 603A of the Nevada Revised Statutes, residents of Nevada have the right to opt out of the sale of certain personal information.

ATD, which does not traditionally sell personal information, offers Nevada residents the option to prevent any potential sale of their personal information by submitting a request to [email protected]. Like our approach for Vermont residents, we ensure not to share Nevada residents’ information with external parties except as law allows, with entities performing marketing or services on our behalf, under joint marketing agreements, or with the resident’s explicit consent. Furthermore, ATD commits to not disclosing non-transactional information about Nevada residents obtained from affiliates without explicit consent from the resident, ensuring a protective stance on privacy in compliance with Nevada law.

11. Amendments to the Privacy Policy

We reserve the right to modify this Privacy Policy and will inform you should such updates occur; nonetheless, we advise you to regularly check this policy for the most current updates.

We may revise this privacy policy to mirror adjustments in our data handling practices. If there are any significant changes, we will inform you via email (sent to the email address listed in your account) or through a notice on the Sites. We recommend you review this page periodically for the most recent information on our privacy practices. Any alterations to this Privacy Policy will be indicated by updating the revision date at the top of the Policy.

12. Contact Us

Should you have queries regarding this Privacy Policy or wish to exercise your privacy rights, please reach out to us at:

Email: [email protected]