What information do we collect?

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• email addresses
• phone numbers

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

When you visit or use our website, view any of our electronic communications, or interact with one of our targeted ads, we may collect information from your computer(s) and your smartphone(s), tablet(s) or other mobile device(s) (together referred to as “mobile devices”). This information does not reveal your specific identity (like your name or contact information) but may include:

• The make and model of the computer(s) or mobile device(s) you use to visit, use, view or interact with our online services, browser version, hardware and operating system;
• Your mobile phone number, mobile country code, unique device identifier, mobile advertising identifier (assigned by your mobile platform), information about the screen size of your mobile device(s), the date and time of your device use, and other mobile device-related information;
• Your Internet Protocol (IP) address and related information, such as your internet service provider and general location and MAC address;
• The precise location of your mobile device(s), if enabled on your device(s) 
• Your browsing habits on online services provided by us or third parties, such as search terms you entered on our websites, what websites and pages you visit, how long you stay and what actions you take;
• Search terms that directed you to our websites and mobile apps, which websites you came from, and which websites you visit right after leaving one of our websites;
• Which of our ads or other online content you view, access or click on; and
• Any actions you take in response to electronic communications that we send to you, such as opening the message or clicking an embedded link.

Our service providers may also collect information about your browsing habits on online services offered by third parties and use it for the purposes described below.

Third-party information

We may also collect information about you from additional online and offline sources, including other third-party sources as permitted by law. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. 

How do we process and share your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

We may use the information discussed above in a number of ways, to:

• Deliver products and services to you, which includes:
• Advertise and market our products and services, including:
• Posting ads through our or third-party websites or mobile apps that may be of interest to you 
• Contacting you with ads, promotions and offers that may be of interest to you (as permitted by law and consistent with any marketing preferences that we offer and you have registered with us);
• Prevent and detect fraud and enhance the security of your account and our online services;
• Conduct market research, reporting and development, including to better understand our customers, website visitors and mobile app users, improve our online services, and improve our products and services; and
• In other ways as required or permitted by law or with your consent.

When and with whom do we share your information?

F&I Sentinel does not explicitly sell or share information in specific situations described in this section and/or with the following categories of third parties.

• Vendors, Consultants, and Other Third-Party Service Providers. F&I Sentinel does not explicitly sell or share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. F&I Sentinel does not explicitly sell or share share your personal information in the following situations:
• Business Transfers. F&I Sentinel does not explicitly sell, share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. F&I Sentinel does not explicitly sell or  share your information with our affiliates. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. F&I Sentinel does not explicitly share your information with our business partners to offer you certain products, services, or promotions.

How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Code, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Use of cookies and other tracking technologies

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice, below.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

Information from minors

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

Your privacy rights

You may review, change, or terminate your account at any time. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Online advertising

We may advertise our products and services and personalize content through online services offered by us, our affiliates and third parties that are not affiliated with us, by using cookies, the mobile advertising identifier of your device and other tracking technologies. Some of our advertising partners may collect data from your mobile device, such as your website and app browsing habits and your mobile advertising identifier, and use it for “online behavioral advertising” (also referred to as “OBA” or “interest-based advertising”). We subscribe to the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (DAA), which promotes consumer awareness and choice about how consumers’ information is used for OBA. To learn more about OBA, please visit http://www.aboutads.info/choices.

Our personalized or tailored ads and content may include:

• Relationship-based ads (e.g., “promoted posts”) on social media, search engine and webmail sites, based upon your contact information in our files; and
• Ads on search engine websites based upon search terms that you enter on the search engine websites.

If you click on one of our ads, a cookie, the mobile advertising identifier of your device and other tracking technologies may be used to track the effectiveness of our advertising and to display tailored ads for our products or services.

Opt-Out Options: We do not respond to “do not track” signals transmitted by web browsers or similar mechanisms. However, several opt-out options are available to you:

• Ads based upon your web browsing habits: Click the AdChoices icon on the ad and follow the instructions, or visit http://www.aboutads.info/choices; and
• Ads based upon your app browsing habits: Click the AdChoices icon on the ad and follow the instructions, or change the advertising settings offered by your mobile provider via your mobile device.
• Other Opt-Outs: Some search engine websites and social media platforms (e.g., Facebook) that display our search-based ads or relationship-based ads offer their own opt-outs. Please visit those sites and platforms for more information.

Opting out through any of these means may not stop advertising from appearing in your browser or apps, but it may make the ads you see less relevant to your interests. If you erase cookies from your browser, use a different browser, or reset the ad identifier on your device, you may need to renew your opt-out choice. In addition, we may still collect data in browsers and apps for other purposes such as market research, reporting and development of our products and services.

We or our advertising partners may use non-cookie technologies to recognize your computer or mobile device and collect and record information about your web surfing activity including your activities on our websites. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and browser settings that block cookies may have no effect on such technologies.

Social media

F&I Sentinel participates in social media platforms, such as Facebook®, and LinkedIn®, which enable online sharing and collaboration among their users. Any information or other content you post on these platforms, such as pictures, opinions or personal information, is subject to the platforms’ terms of use and privacy and security policies; please refer to their policies to better understand your rights and obligations with regard to such content.

California residents privacy rights

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).