Effective Date: FEBRUARY 10, 2019

This Privacy Policy describes the data protection practices of Dealer Consulting Services, Inc. (“Dealer Consulting Services, Inc.,” “DCS,” “we,” “us,” or “our”). DCS provides services to users living the United States. If you live in the United States, DCS is the data controller for your information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES. IF YOU HAVE PURCHASED SERVICES SUBJECT TO THIS PRIVACY POLICY, PLEASE DISCONTINUE THE SET-UP OF YOUR SERVICES AND CONTACT US USING THE CONTACT INFORMATION BELOW.

This Privacy Policy contains the following sections:

The Information We Collect; How We Use Your Information; Legal Bases for Use of Your Information; Cookies and Similar Technologies; Online Analytics and Advertising; How We Share and Disclose Your Information; Retention of Your Information; Data Subject Rights and Your Choices; Information for Employment Applicants; How We Protect Your Information; Employment Applications; Changes to Our Privacy Policy; DCS Contact Information; 

THE INFORMATION WE COLLECT

This Privacy Policy applies to the information that we collect and use about you when you:

Access or use any DCS-affiliated website (including when you make purchases online), mobile application, software, or other online or mobile service that links to or otherwise presents this Privacy Policy to you; Visit a DCS location; or Participate in a DCS research survey or study.

We refer to these products and services collectively as the “Services”.

We obtain information about you through the means discussed below when we provide the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.

Information You Provide to Us
DCS collects a variety of information that you provide directly to us. For example, DCS collects information from you through:

Processing your orders; Requests or questions you submit to us via forms or email; Your communications and dealings with us (including on our websites, in stores, at special events, over the phone, on third-party social media sites, and by mail or email); The Services that you use; Employment applications; Account and product registration and administration of your account; Uploads or posts to the Services; Requests for customer support and technical assistance; 

Information about you.
While some of the Services may not require you to provide any information that can directly identify you by name, the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:

Name, address, telephone number and email address (and company name, address, contact information, and other company details if you are using a DCS website or Services); Log-in credentials, if you create a DCS account; Billing information, such as shipping address, credit or debit card number, verification number, and expiration date; Information about purchases or other transactions with us; Information about your customer service and maintenance interactions with us; Demographic information such as your gender; Any other information you choose to directly provide to DCS in connection with your use of the Services.; 

Information We Collect Through Automated Means
When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

Websites.
When you use our websites, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services and upload or post content, error logs, and other similar information.

Location Information.
When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user’s general location.

HOW WE USE YOUR INFORMATION

We, or our service providers, use your information (including any information that we collect, as described in this Privacy Policy) for various purposes depending on the types of information we have collected from and about you and the specific DCS Services you use, in order to:Complete a purchase or provide the Services you have requested, including invoicing and accounting; Respond to your request for information and provide you with more effective and efficient customer service; Provide you with updates and information about products you have purchased from us; Contact you by email, postal mail, or phone regarding DCS and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you; Customize the advertising and content on the Services; Help us better understand your interests and needs, and improve the Services; Synthesize and derive insights from your use of different Services; Engage in analysis, research, and reports regarding use of our Services; Provide, manage, and improve the Services and their performance, and test and create new products, features, and services; Secure our websites, products, software, applications, or DCS locations Understand and resolve app crashes and other issues being reported; Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others; Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.; Aggregate/Anonymous Data. We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

LEGAL BASES FOR USE OF YOUR INFORMATION

The legal bases for using your information as set out in this Privacy Policy are as follows:

Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you); or

Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our websites, products, software, applications, or DCS locations; operate our business and our Services; ensure safe environments for our staff and visitors; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services).

COOKIES AND SIMILAR TECHNOLOGIES

To collect the information in the “Information We Automatically Collect” section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

A web server log is a file where website activity is stored.

An SDK is a set of tools and/or code that we embed in our applications and software to allow third parties to collect information about how users interact with the Services.

A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.

Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookies.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website.

For more information on the cookies we use and the purposes for which we use them, please refer to our Cookies Notice. By continuing to use our websites and/or our Services, you are agreeing to our use of cookies as described in our Cookies Notice.

ONLINE ANALYTICS AND ADVERTISING

Analytics
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. We may also use Adobe Analytics to analyze and optimize the performance of our websites, advertising, and content. To learn more about Adobe’s privacy practices and to make choices regarding Adobe’s tracking activities, please click here.

If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

Third parties, whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

Notice Concerning Do Not Track.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

DCS will share your information in the following ways:

Affiliates and Subsidiaries.
We may share information we collect within the DCS family of companies to assist in deploying services to you, ensure a consistent level of service across our products and Services, and enhance our products, services, and your customer experience.

Service Providers.
We provide access to or share your information with select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, advertising, analytics, research, customer service, shipping and fulfillment, data storage, security, fraud prevention, payment processing, and legal services.

Protection of DCS and Others.
By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of DCS, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

DATA SUBJECT RIGHTS AND YOUR CHOICES

You have certain rights with respect to your information as further described in this section.

Your Legal Rights
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact” section at any time. Your local laws may permit you to request that we:

provide access to and/or a copy of certain information we hold about you; prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling); update information which is out of date or incorrect; delete certain information which we are holding about you; restrict the way that we process and disclose certain of your information; transfer your information to a third party provider of services; revoke your consent for the processing of your information; 

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

Marketing Communications and Sharing
You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

HOW WE PROTECT YOUR INFORMATION

DCS takes technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access to a DCS account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

EMPLOYMENT APPLICATIONS

The Services may contain careers sections that link to websites where you can apply for employment at DCS. These linked employment websites are not hosted by DCS. These websites collect a variety of information, including your contact information and your job qualifications. They also use cookies and other means of collecting information, but such information is used only for analytics purposes and to enable you to complete your application. Any information that DCS collects from any employment services in connection with the employment websites is handled consistent with this Privacy Policy. DCS will use and share your information only for employment purposes, such as evaluating you for a job opportunity or communicating with you about your interests, and where sharing is required by law.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review the Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

DCS CONTACT INFORMATION

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please email us at support@dcs-network.com