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Loan Application Privacy Policy
We have partnered with Interactive Financial Marketing Group, LLC “IFMG” located
at
Interactive Financial Marketing Group, LLC
114 Virginia Street
Richmond, Virginia 23219
privacy@interactivefmg.com
fax: 804-225-1885
UsedCars.com and IFMG believe that privacy is a cornerstone of our customer
relationship. In operating our business, we strive to find methods to guard personal
identity and information by promoting the use of fair information practices. Both UsedCars.com and IFMG maintain physical,
electronic, and procedural safeguards that comply with all state and federal regulations
to guard your nonpublic personal information. We have created this privacy policy
to demonstrate our firm commitment to privacy and to inform you of our practices
concerning the collection and use of the information that you provide to us. UsedCars.com
and IFMG may
amend this policy from time to time. If we make any substantial changes
in the way we use your personal information, we will post an announcement on our
web site.
Gramm-Leach-Bliley Act
UsedCars.com and IFMG comply with the requirements of Title V of the Gramm-Leach-Bliley
Act, 15 U.S.C. §6801 through § 6810 ("GLB Act"), and the Federal Trade Commission's
implementing regulation, Regulation P, 16 C.F.R. Part 313 ("Regulation P"), in particular,
as both related to the disclosure and protection of Non-Public Personal Information
("NPI") for customers with regard to the authorized distribution and intended use
of customers' financial information to other parties. UsedCars.com and IFMG
will substantially comply with the GLB Act and Regulation P for all customer NPI
received, transferred or obtained from the use of this site or from a party.
Collection of Information
UsedCars.com may collect and use personal information to respond to your requests
for an price quote for purchasing a particular vehicle.
Likewise, we may collect and provide personal information to our partner
IFMG to respond to your request for auto financing.
In addition to supplying the information you provided to use, our partner
IFMG collects personal information from a variety of sources, including:
1)
Credit Reports (Information from consumer reporting agencies);
2)
Correspondence (Information provided when communicating in writing,
online or by phone with our customer service representatives); and
3)
Marketing partners and publicly available databases (We receive information
from our marketing partners, e.g., financial institutions, auto dealerships and
other businesses and public databases which we use to help us serve our customers).
IFMG uses this information to evaluate auto loan applications, locate an appropriate
auto dealer and/or lender for you, in order to provide high quality service, prevent
fraud and, with the customer's consent, inform customers of offers of other IFMG
services offered by third parties. IFMG may also use this information to confirm
a customer's identity when they call us to inquire about their account.
Security Safeguard Procedures
Both UsedCars.com and IFMG uses a variety of security safeguards to protect
information from loss, misuse, alteration or destruction. We provide access to personal
information to <Insert Sub Name> and IFMG employees and other authorized parties
on a "need to know" basis. In addition, IFMG requires that all employees attend
a privacy training program and sign a Confidentiality Agreement that indicates that
they are aware of Carloan.com privacy policy regarding the use and disclosure of
information.
Both UsedCars.com and IFMG use Secure Sockets Layer (SSL) technology supporting
up to 128-bit encryption to prevent unauthorized parties from viewing any personal
information transmitted to IFMG or from <Insert Site Name> . We maintain up-to-date
firewalls and use anti-virus software that updates automatically.
Sharing of Information with Third Parties
IFMG may disclose personal information to the following types of third parties:
IFMG partners (auto dealerships that meet customer's criteria and financial
institutions), Credit Bureaus and Service Companies (companies that provide
services to IFMGin order to process auto loan applications). Personal information
is disclosed to the foregoing entities solely for the purpose of locating a vehicle
that meet the customer's criteria and to obtain credit for the purchase of such
vehicle. Outlined below is the information we share with each type of third party.
- IFMG Partners
- IFMG offers its services in conjunction with auto dealerships, financial institutions
and other businesses (collectively, IFMG Partners). When a customer completes a
credit application with <Insert Site Name> for the purpose of locating a vehicle
that meets their criteria and obtains credit for the purchase of such vehicle, the
customer may agree to the sharing of information with that partner. The customer
agrees that IFMG and/or its auto dealers or lending partners may forward their application
to other auto dealers or lenders for consideration. The customer authorizes any
auto dealer or lender who receives their application to retain it, to rely on it
and to obtain such other information as require, including credit reports, to complete
the processing of their request for credit. The customer further authorizes that
any auto dealer or lender who receives this application to inform IFMG and its lending
partners of their credit decision. These relationships are clearly stated in the
application and by completing the application the customer agrees to permit IFMG
to share their information, which may
include the applicant's name, address, phone
number, e-mail address, and other personal financial information with our partners.
In addition, since we do not service auto loan applications, we will sell loan applications
to auto dealerships. The customer will be notified of the auto dealership that will
be servicing their auto loan application.
- Credit
Reporting Agencies - Companies involved in the loan process are a necessary part
of the auto loan process. When a customer applies for credit, he/she agrees that
we may request consumer credit reports from one or more credit reporting agencies
in connection with their application and administration of the application. The
customer may also authorize us to exchange credit information concerning their account
with (and answer questions and requests from) others, such as merchants, other lenders
and credit reporting agencies.
- Service
Companies -- In order to provide quality service, IFMG contracts with service providers
for the essential role of processing loan applications. We may disclose some or
all of the information we collect to these service providers but only in order to
obtain credit for the customer. All of IFMG service providers have entered into
a contract with IFMG that forbids them from using information provided by UsedCars.com
and IFMG for any purpose other
than providing the service for IFMG customers. These
service companies are required by law to adhere to federal and state privacy regulations.
IFMG takes security precautions to monitor the use of the information and prevent
the use of the information for any other purpose. When IFMG contracts with organizations
to provide services to our customers, we will require them to conform to our privacy
standards and to allow us to audit them for compliance.
- Merchants
-- IFMG does not share any information with external merchants for the purpose of
extending offers of goods and services without the customer's consent. IFMG does
NOT use third party advertising companies to provide advertisements or allow third
party advertisers to track web browsing activities on its web sites.
- In addition,
UsedCars.com or IFMG does not knowingly offer its services to minors. Similarly,
UsedCars.com and IFMG does not collect information from children.
Our application
approval process is designed to identify applications submitted by children and
to prevent their use of our websites.
Exercising the Right to Opt-Out of Information Sharing
UsedCars.com provides its customers with the opportunity to opt-out of information
sharing with affiliates and partners. A customer must make their opt-out decision
before completing the auto loan application process. Customers can opt-out by clicking
on the link at the bottom of the auto loan application screen.
Storing of Information
Once you have supplied UsedCars.com with your loan application, the information
is then transmitted via secure connection to IFMG.
IFMG will maintain electronic loan application information and hardcopy data. We
also protect all personal information by storing the information on tapes at an
offsite facility in our Data Warehouse. The Data Warehouse is disconnected from
the production environment and the information is used internally for reporting
purposes.
Privacy Related Issues
Both UsedCars.com and IFMG are committed to customer service and privacy. If
you have any questions, comments or concerns regarding our Privacy Policy and its
implementation, or you would like to report any known or suspected privacy or security
breaches, please do not hesitate to contact our Security Compliance Officer at
privacy@interactivefmg.com
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