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Privacy Policy

Great Western Leasing and Sales Privacy Policy

Updated as of July 1, 2020

Privacy Policy

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Introduction

Welcome. You have arrived at a website provided by Great Western Leasing and Sales, LLC (“Great Western Leasing,” “Company” or “we,” “our” or “us”). We respect your privacy and want to protect your personal information.

This Privacy Policy governs www.greatwesternleasing.comwww.gwleasing.com, their subdomains, and all portals, applications, products, goods, services, events, and any interactive features, applications, or other services that post a link to this Privacy Policy (the “Site”). This Privacy Policy also applies to information (including the “Personal Information” defined below) that we may collect from you in person at our physical locations (each “Location”), via phone calls or other communications with our personnel or in any other instance when you contact us. We refer to all of the above as our “Services.”

We are required by law to tell you what information we collect from you, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that information, and how you may opt out of the sale of that information. As a preliminary matter, we handle all information you provide us with the utmost confidentiality. At times, we may need to disclose your personal information to third parties outside the company who may be assisting us with providing Services to you, as set forth in this Policy. If you have questions about this Privacy Policy, contact us at privacy@gwleasing.com.

Please note that if you voluntarily provide your information in the course of interacting with our Site, visiting our Locations, or otherwise using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy. This Privacy Policy is incorporated into our Terms of Use which govern your use of this Site.

By using our Site, contacting us to inquire about our Services, or visiting our Locations, you consent to our Privacy Policy and agree to our Terms of Use.

This Privacy Policy does not apply to any products, goods, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies.

1.       What Information We Collect

(a)                 Information You Provide to Us

In connection with the Services we provide, we may ask you to provide us with certain information, including:

  • your first and last name, email address, home or business address, telephone number, mobile number, username, credit card or debit card number, bank account and other financial information, your birthdate, your payment and/or service history, current or past employment information, educational information;
  • social media information, such as social media handles, content and other data shared with us through third-party features that you use on our Site and other service (such as apps, tools, payment services, widgets and plug-ins offered by social media services like Facebook, Instagram, LinkedIn and Twitter) or posted on social media pages (such as our social media page or other pages accessible to us); and/or
  • other information that could reasonably be used to identify you personally or identify your household or device.

The above are collectively referred to hereinafter as “Personal Information.”

Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services.

(b)                  Information That Is Automatically Collected

In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site(s). Usage Information may include:

  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier
  • Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within our Site that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
  • Your Device characteristics; and
  • Certain other Device data, including the time of day you visit our Site.

For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you.

If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

(c)                 Use of Cookies and other Tracking Technologies

We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site), include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

  • Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
  • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
  • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

 We may use Tracking Technologies for a variety of purposes, including:

  • To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality;
  • To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
  • To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
  • To deliver content relevant to your interests on our Site and third‑party sites based on how you interact with our content.

You can get more information about Cookies and Tracking Technologies, and instructions on how to opt out of cookies and certain tracking technologies, in our “Ads and Information About You” section below and in our Cookie Policy.

(d)            Sources of Personal Information

Additionally, we may obtain Personal Information from you where you expressly provide us with the information. Examples of sources from which we collect information include interviews and phone calls with you, letters, e-mails or other communications from you, information provided via web forms or inputs/uploads into our Site, documents you have provided to us, references and referrals provided to us in connection with your request, and employment applications.

(e)                 Information We Collect When You Interact with Third-Party Sites

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Site to facilitate sending a communication from the Site or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools on our Site. Please also see our Terms of Use for further information.

(f)                  Information from Third Parties

In addition, we may collect information about you from other sources, including consumer credit reporting agencies and state or federal agencies. We may also obtain information about you from marketers and market research firms. We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services.

2.       Why We Collect Information

We may use your information for various purposes, including:

  • Responding to your requests for information;
  • Providing products or Services to you;
  • Analyzing your request for credit;
  • Verifying your identity and for fraud prevention;
  • Processing your payments;
  • Evaluating your employment application;
  • Providing you with updates and information about products and services we provide;
  • Sending you marketing information about Great Western Leasing and our affiliated entities;
  • Sending you email communications such as electronic newsletters about our Services and events and promotions which may be of interest to you;
  • Improving the effectiveness of our Site, our marketing endeavors, and our product and service offerings;
  • Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional information, products and services that may be of interest to you;
  • Helping us address problems with and improve our Site and our products and services, including testing and creating new products, features, and services;
  • Providing mobile marketing messages and other communications and messages;
  • Protecting the security and integrity of the Site, including understanding and resolving any technical and security issues reported on our Site;
  • Administering employee benefits, such as medical, dental, commuter and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management, rewards or discount programs offered to employees;
  • Engaging in analysis, research, and reports regarding the use of our Site and Services;
  • For internal business purposes;
  • Complying with the law and protecting the safety, rights, property or security of Great Western Leasing, the Services, and the general public; and
  • For other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

3.       When We Disclose Information

We may aggregate, de-identify, and/or anonymize any information collected through the Site or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

As a general rule, we do not disclose Personal Information about our customers to anyone. However, to the extent permitted by law and any applicable state Code of Professional Conduct, certain nonpublic information about you may be disclosed in the following situations:

  • To comply with a validly issued and enforceable subpoena or summons.
  • In the course of a review of our company’s practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry or complaint from such a licensing board of organization.
  • In conjunction with a prospective purchase, sale, or merger of all or part of our practice, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.
  • As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
  • To provide information to affiliates of the company and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. Examples of such disclosures include using a payment processor, reservations maker, merchandise store, customer service provider, email marketing provider, or food delivery service.

Finally, we also may share your information, including your Personal Information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. (If you are a California resident, you have the right to request additional information regarding the “sale” of your information. Please see the Section entitled “Your California Privacy Rights” below about these rights.) In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Privacy Policy.

4.       Ads and Information About You

You may see certain ads on our Site because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site(s), such as the pages you have viewed. This collection and ad targeting takes place both on our Site(s) and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts. You can find additional information in our Cookie Policy, including ways to opt-out of certain Tracking Technologies.

5.       Your Choices About the Information We Collect

If you would prefer that we not share your name and mailing address with third parties (other than with our affiliates) to receive promotional offers, you have the option to opt out of such sharing. To do so, please email us at privacy@gwleasing.com. Your choice will not affect our ability to share information in the other ways described in this Privacy Policy.

If you do not wish to receive e-mails about special offers, events, and other promotions from us, email us at privacy@gwleasing.com to opt out or click the link in the email to “unsubscribe.” If you do not wish to receive other marketing materials by regular mail from us, please write us at:

Great Western Leasing and Sales
2505 McCabe Way, Suite 200 
Irvine, CA 92614

 

Please note that certain of your personal information, such as your name or other identifying information, may remain in our database even after a deletion request in order to maintain the integrity and historical record of our database and systems, or to comply with applicable laws and regulations.

6.       Children’s Privacy

The Site is not intended for use by children under the age of 16. We do not request, or knowingly collect, any personally identifiable information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us at privacy@gwleasing.com to request the deletion of that information.

7.       Do Not Track Disclosures

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

8.       Visitors to the Site Outside of the United States

If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.

9.       Updating Personal Information

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at privacy@gwleasing.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

10.   Links

For your convenience, the Site(s) and this Privacy Policy may contain links to other websites. Great Western Leasing is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site(s) should be deemed to imply that Great Western Leasing endorses or has any affiliation with the links. Please see our Terms of Use  for more information.

11.   Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.

12.   International Data Transfers

Because Great Western Leasing works with global companies and technologies, we may transfer your Personal Information outside of the country in which it was originally provided. This may include transfers to third parties, such as service providers or affiliated entities who are location outside the United States or the European Union, where data protection laws may not offer the same level of protection as those in the United States. When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your Personal Information.

13.   Your California Privacy Rights

This section of the Privacy Policy applies solely to California residents. We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Section.

Great Western Leasing collects certain types of personal information about you during your relationship with us, as stated above. In particular, our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category

Collected

A. Identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

YES

C. Protected classification characteristics under California or federal law.

YES

D. Commercial information.

YES

E. Biometric information.

YES

F. Internet or other similar network activity.

YES

G. Geolocation data.

YES

H. Sensory data.

NO

I. Professional or employment-related information.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

NO

K. Inferences drawn from other personal information.

YES

 

Under California law, if you are a resident of California, under certain circumstances, you have the right to request certain information that we collect about you, including:

  1. The categories of Personal Information we have collected from you;
  2. The categories of sources from which we collected the Personal Information;
  3. The business purpose we have for collecting or selling that Personal Information;
  4. The categories of third parties with whom we share such Personal Information;
  5. The specific pieces of Personal Information we have collected about you;
  6. The categories of Personal Information about you that we sold, and the categories of third parties to whom the personal information was sold, by category or categories of Personal Information for each category of third parties to whom the information was sold;
  7. The categories of Personal Information that we have disclosed about you for a business purpose;
  8. The category or categories of consumers’ Personal Information that we have sold, or if we have not sold consumers’ Personal Information; and
  9. The category or categories of consumers’ Personal Information that we have disclosed for a business purpose, or if we have not disclosed that information for a business purpose.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. At this time, we do not sell consumers’ personal information to third parties. We can, however, process your request to opt out of any marketing emails or correspondence.

You may make a request to us at the contact information below. We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice a year. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity.

Email Address:  privacy@gwleasing.com

Toll-Free Number: (888) 236-7121

14.   Your Nevada Privacy Rights

If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. This applies only if you have made a purchase for personal, family, or household purposes, not for business purposes. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from Great Western Leasing, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).

As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to privacy@gwleasing.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out.

We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.

15.   Questions / Changes in Privacy Policy

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@gwleasing.com. We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates.