Last Update: January 1, 2020
This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all consumers, customers and others with whom we have a business relationship who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
PERSONAL INFORMATION
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or customer of ours (“personal information”). Personal information does not include any information that is publicly available from government records or other unrestricted public sources, and does not include de-identified (non-specific) or aggregated (bulk) consumer information.
TYPES OF INFORMATION WE COLLECT
We may have collected the following categories of personal information from you within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Source: Obtained directly from the consumer or customer, as well as from third parties in connection with the services we provide to you, such as dealership partners, service providers, such as print or payment vendors, and third parties authorized by you, such as credit reporting agencies, in connection with products or services we provide to you. |
Yes |
| Personal information categories listed in the California Customer Records statute (C.C.C. § 1798.80) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Source: Obtained directly from the consumer or customer, or the consumer or customer’s device, as well as from third parties in connection with the services we provide to you, such as dealership partners, service providers, such as print or payment vendors, and third parties authorized by you, such as credit reporting agencies, in connection with products or services we provide to you. |
Yes |
| Protected classification characteristics | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Source: Obtained directly from the consumer or customer, from public records obtained from government entities, as well as from third parties in connection with the services we provide to you, such as dealership partners, service providers, such as print or payment vendors, and third parties authorized by you, such as credit reporting agencies, in connection with products or services we provide to you. |
Yes |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Source: Obtained directly from the consumer or customer, from public records, as well as from third parties in connection with the services we provide to you, such as dealership partners, service providers, such as print or payment vendors, and third parties authorized by you, such as credit reporting agencies, in connection with products or services we provide to you. |
Yes |
| Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Source: We do not collect this information. |
No |
| Geolocation data | Physical location or movements.
Source: Physical location information is obtained directly from the consumer or customer, from public records, as well as from third parties in connection with the services we provide to you, such as dealership partners, service providers, such as print or payment vendors, and third parties authorized by you, such as credit reporting agencies, in connection with products or services we provide to you. Movement information is not collected. |
Yes |
| Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information.
Source: We do not collect this information. |
No |
| Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Source: We do not collect this information. |
No |
| Professional or employment related information | Current or past job history or performance evaluations.
Source: Current and past job history information is obtained directly from the consumer or customer, from public records, as well as from third parties in connection with the services we provide to you, such as dealership partners, service providers, such as print or payment vendors, and third parties authorized by you, such as credit reporting agencies, in connection with products or services we provide to you. Performance evaluation information is not collected. |
Yes |
| Non-public education information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Source: We do not collect this information. |
No |
| Inferences drawn from other personal information | Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Source: We do not collect this information. |
No |
We may not collect information in all of the categories on every consumer or customer of ours.
PURPOSES FOR COLLECTING PERSONAL INFORMATION ABOUT YOU
We collected the personal information described above for one or more of the following reasons:
- To evaluate your request for credit and to perform services involving the credit transaction you entered into for the financed purchase of your vehicle, and to continue servicing the account you have with us for the financed purchase of your vehicle.
- Performing services to you, directly or through a service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling requests from you, verifying customer information, processing payments, providing financing, and providing analytic services or providing similar services. This includes using the information to provide you products or services that you request from us.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity and prosecuting those responsible for that activity.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.
SHARING YOUR PERSONAL INFORMATION
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers who perform services related to our administration of your account with CIG Financial, including print vendors, payment processors, telephony vendors, etc.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
We do not sell personal information to any party for any purpose. We do not collect, use, disclose or sell personal information about individuals under 18 years of age.
YOUR RIGHTS AND CHOICES
- You have a right to notification about our Privacy Policy. If we change any of our policies or practices about the information we collect about you, we will notify you about those changes.
- You have a right to know the categories of your personal information we have collected about you.
- You have a right to access to the information we collect about you by submitting a verifiable request.
- You have a right to know the specific personal information we have collected about you by submitting a verifiable request.
- You have a right to opt out of your information being sold to another party. We do not sell any information about our customers to anyone for any purpose, but you may opt out by either calling us at (877)244-4442 or clicking here: Do Not Sell My Information. You will need to enter your CIG Financial account number in order to submit a Do Not Sell request online.
- You do not have a right to request deletion of the personal information we have collected about you (CCPA § 1798.105(d)). We use this information to complete and facilitate the existing transaction we have with you, or have had with you.
- We will not discriminate against your because you exercised any of these rights. We will only use the information submitted in your verifiable request for the purpose of verification. To exercise these rights or submit a verifiable request you do not need to create any type of account with us. In certain instances, we may not be required to provide requested information to you more than twice in a twelve (12) month period.
WHY YOU DO NOT HAVE A RIGHT TO REQUEST DELETION
Our holding and using your personal information qualifies as an exception under the California Consumer Privacy Act, for the reasons provided below:
TITLE 1.81.5. California Consumer Privacy Act of 2018, California Civil Code §1798.105(d):
A business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to:
(1) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
(8) Comply with a legal obligation.
(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
REQUESTS FOR INFORMATION WE HAVE COLLECTED ABOUT YOU
We will attempt to provide a response to your request within forty-five (45) days from the date we receive your request. If we need additional time to respond to your request, we will notify you in writing of the extended time period needed to respond, but in no case will we take more than ninety (90) days to respond to your request. In order to verify your request we need to collect some identifying information to match it with the information within our systems. The accuracy of the information you provide has a direct impact on our ability to verify your identity and fulfill your request. Please complete all applicable sections of the verifiable request form, and sign the declaration where you must affirm, under penalty of perjury, that you are the individual whose personal information is the subject of the request. We will not process requests for information if the information you provided is incomplete, or if you do not sign the declaration.
Our response will be delivered to you by regular US mail to the current address you provide us on the verifiable request form. You must mail this form to us at the address provided on the form. We will not accept or process your request if submitted via fax or email.
Individual Request
You can submit a verifiable request to us you by either (1) calling us at the following toll-free number (877)244-4442, or (2) printing, completing, signing and mailing the request form found by clicking here: CCPA Verifiable Request. If you call us to submit a verifiable request, we will mail you the verifiable request form which you must complete, sign, and mail back to us.
Each party to a multi-party account must submit a separate verifiable request. If your account with us has more than one individual associated to it (a joint account or a cosigner account), we will only provide the personal information of the individual submitting the verifiable request.
Any personal information collected from you in connection with your verifiable consumer request will solely be used for the purpose of complying with your request.
Authorized Agent Request You may designate an authorized agent to make requests under the CCPA on your behalf. If you wish to designate an authorized agent to make requests under the CCAP on your behalf, you or your agent may call us at (877)244-4442 and request the necessary form(s) for making a CCPA request as an authorized agent.
Applicability
The CCPA applies solely to California residents. If you are not a current California resident we will not process your request. Any disclosure we provide will cover personal information that CIG Financial has collected from you in the twelve (12) month period immediately preceding the date we receive your request.
Your rights as stated under this Privacy Policy and the California Consumer Privacy Act may be impacted by our obligations and duties imposed by federal, state, or local law, to comply with any civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities, and to cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law. Your rights may also be impacted by and shall not restrict our ability to exercise or defend any legal claim, to collect, use, retain, sell, or disclose consumer information that is de-identified or is aggregate consumer information, or to collect or sell a consumer’s personal information if every aspect of that commercial conduct takes place wholly outside of California.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services than we provide to consumers who do not exercise a CCPA right.
- Suggest or infer that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
AMERICANS WITH DISABILITIES ACT
If you need us to provide you with this policy in an alternative format, or support any of the interactive functionality on this page in an alternative format, please contact us at (877)244-4442.
CONTACT US
If you have any questions or comments about this policy, the ways we collect and use your personal information, your rights and choices about how we use your personal information, please contact us at:
Toll-free at (877)244-4442, Monday – Friday, 6:00AM to 6:00PM Pacific Time
| Mail to: | CIG Financial Privacy PO Box 19795 Irvine, CA 92623 |