Privacy Policy

PRIVACY POLICY / NOTICE TO CALIFORNIA CONSUMERS

This policy describes the personal information that Rockledge Securities collects, maintains, uses, and discloses about its California consumers when you visit or interact with our website or when you interact, communicate or transact any business with the Dealership.

The Dealership collects the following categories of personal information about you based on your specific transactions and interactions with the Dealership or its website. For each category of information, the business purposes for which we use the information and the third parties with whom we have shared the information in the last 12 months are referenced by a number that coincides with the number in the lists that follow below in this policy.

Category	Scenarios in which info is collected	Examples	Business Purpose	Sources	Shared in Last 12 Months With
Personal Identifiers	When you submit a request for credit information or credit score online or in store	Name, alias, address, email address, social security number	1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11	From you the consumer	A, B, E, F, G, H
Protected Classifications	When you submit a request for information related to gender, or indicate English is not your preferred language	Gender, ethnicity, language	1, 3, 4, 11, 12	From you the consumer	A, B, E
Commercial Data	Any purchase or request for credit approval	Records of products or services provided, purchasing history	1, 3	From you the consumer	A, B, D, E, G, H
Biometric Data	When you call a store, we may record the conversation for training or quality assurance purposes	Voice recordings	11	From you the consumer	Not shared
Internet Activity	Whenever you navigate, access or use any of our websites via computer or mobile device	IP Address, browsing history, search history, type of browser used, cookies, device used to access the site, domain name from which our site was accessed	12, 13		G
Geolocation Data	When you create an account on our website	IP address	11, 12, 13		Not Shared
Mobile Device Data	Whenever you navigate, access or use any of our websites via computer or mobile device	Device type, software type	12, 13		G
Financial / Employment Data	When you complete a credit application	Company name, role, salary, dates of employment, bank accounts, income sources	1	From you the consumer	B

The Dealership uses your personal information and shares it with various service providers and third parties for the following business purposes:

#	Business Reason
1	The Dealership uses your personal information and shares it with various service providers and third parties for the following business purposes:
2	For security and insurance purposes, a copy of the driver’s license is obtained to permit a customer to test drive a vehicle
3	To process, complete, and maintain records on transactions including vehicle purchase, service, products, parts or accessories
4	To provide complete warranty coverage on vehicles, products, parts, service, and accessories
5	We retain your selection for Text opt in/opt out to ensure customers who opted out are not sent any text messages
6	To provide and communicate recall notifications to customers
7	To reserve a vehicle that a customer expressed interest in and requested that it be reserved
8	To schedule, manage and keep track of customer appointments
9	To complete a vehicle appraisal
10	To maintain records of when customers decline a service or sale
11	To respond to consumer inquiries, including vehicle interest, request for information, Customer Support online, phone calls, and in-store inquiries
12	To provide interest-based advertising and improve user experience on our website
13	To understand the demographics of our website visitors

The Dealership shares your personal information with the following categories of service providers or third-party businesses depending on your transactions or interactions with the Dealership:

A. Vehicle OEMs
B. Financial Institutions
C. Lead providers
D. Product manufacturers/administrators
E. Government agencies
F. Promotional or other fulfilment vendors
G. Marketing support vendors
H. Transaction support vendors (e.g., check guaranty, rental car, payment processors)

The Dealership does NOT sell your personal information, including the data of any minors, except as follows. If you were referred to the Dealership by a third-party website and we happen to have a contract for that third-party to provide us with leads and referrals, our contract with that party may require us to then report to them whether you ended up conducting business with the Dealership and the type of transaction. Other than this sole exception, we do not and will not disclose your personal information to any third party in exchange for monetary or other valuable consideration.

Notice of Right to Opt-Out

While Rockledge Securities does not sell your personal information – including the data of any minors – the Dealership may disclose your personal information to a third party in exchange for monetary or other valuable consideration. That disclosure may happen if you were referred to the Dealership by a third-party website and we happen to have a contract for that third-party to provide us with leads and referrals, our contract with that party may require us to then report to them whether you ended up conducting business with the Dealership and the type of transaction. This is the only circumstance where your personal information may be disclosed in exchange for monetary or other valuable consideration. You have the right to tell the Dealership NOT to disclose your personal information. You have full and free right to opt-out of the Dealership’s disclosure of your information to any third parties. You may exercise your right to opt-out without fear of discrimination for doing so. To opt-out of the Dealership’s disclosure of your information, meaning, the Dealership will not disclose your information to third parties for any monetary or other valuable consideration, you can do any of the following:

Click HERE to be taken to an online opt-out submission form.

Visit the Dealership’s website at www.rockledgesecurities.com. Click on “Do Not Sell My Information” to be taken to an online submission form.

·Visit any Dealership location to request a paper opt-out submission form.

If you are unable to submit an opt-out through any of the above methods, please call the Dealership’s toll-free privacy line at 844-634-9378 for assistance and a Dealership representative will assist in meeting your needs.

You can have an Authorized Agent submit a request on your behalf if you both come into a California store and provide proof of identity with a driver’s license or passport and provide your consent via mail in form for the Authorized Agent to complete your verifiable consumer request.

To submit an opt-out through use of an authorized agent you must provide that agent with written permission to submit an opt-out on your behalf. The Dealership maintains the right to deny any request from an authorized agent that does not submit sufficient proof that they have been authorized by you to act on your behalf.

In order to verify your identity and respond to your request, the Dealership will need you to provide your name, address, email, phone number, last 4 of your SSN and your date of birth. In addition, our third-party identity verification provider may require your authorization to access your credit report.

Your Rights as a California Consumer:

If you are a California resident, you have the following rights:

The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;

The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;

The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions; and

The right to opt-out of the sale of your personal information to third parties;

The right to designate an authorized agent to submit one of the above requests on your behalf.

The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

Notice of Financial Incentive:

A succinct summary of the financial incentive or price or service difference offered;
A description of the material terms of the financial incentive or price of service difference, including the categories of personal information that are implicated by the financial incentive or price or service difference;
How the consumer can opt-in to the financial incentive or price or service difference;
Notification of the consumer’s right to withdraw from the financial incentive at any time and how the consumer may exercise that right; and
An explanation of why the financial incentive or price or service difference is permitted under the CCPA, including:
1. A good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and
2. A description of the method the business used to calculate the value of the consumer’s data.

If You Have an Authorized Agent:

Consumers with Disabilities

This policy is in a form that is accessible to consumers with disabilities. For more information on our website accessibility, CLICK HERE.

**This policy was last updated December 19, 2019.