Privacy Policy

1. Introduction

Secure Private Sale Solutions LLC (“us”, “we”, or “our”) operates https://secureprivatesale.com Our Privacy Policy governs your visit to our website, products and services (collectively, the “Service”), and explains how we collect, use, share, transfer, store, retain and otherwise process information that results from your use of our Service. This Privacy Policy does not apply to any third-party website or service that we do not own or control.

We respect the privacy of our users when they use our Service, and do not sell your data. However, we do use your data to provide and improve our Service. By using our Service, you agree to the collection and use of information in accordance with this policy. Capitalized terms not defined in this Privacy Policy have the meanings given to them in our Terms of Use (“Terms”) which govern all use of our Service and together with this Privacy Policy and any Bill of Sale we may enter into with you constitute your agreement with us (“Agreement”). In agreeing with this Privacy Policy, you also agree that we may make changes to it as provided in Section 19 below, and that the modified Privacy Policy will become part of the Agreement. With that said, we will never modify our commitment to not sell your confidential and private data.

2. Types of Data Collected

We receive information from and on behalf of customers when they use the Service, including but not limited to Personal Data, Usage Data, Tracking Cookies Data and data from other sources (all defined below and collectively referred to as “Data”). For such Data, the customer is the “data controller” (for purposes of GDPR) or the “business” (for purposes of the CCPA).

(a) Personal Data

‍‍While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession), including” (i) “Contact Data” (such as your name, company name, address, city, state, zip code, telephone numbers, and email addresses); (ii) “Profile Information” used to access the Service (such as username and password); (iii) “Financial Data” (such as your credit card number, expiration date, and verification code or bank account information; (iv) “Legal Data (such as your tax identification number, employer identification number and/or social security number); and (v) “Demographic Data” (such as your zip code and gender). Personal Data does not include de-identified or aggregate information, or public information lawfully available from governmental records.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

(b) Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a computer or mobile device (“Usage Data”). Such Usage Data is collected and aggregate through automated means.

This Usage Data may include information such as your computer’s Internet Protocol address (IP address), internet service provider (ISP) information, operating systems, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, general location information, and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers and other diagnostic data.

We may use Usage Data to analyze website traffic to the Service, and to diagnose problems with our server, administer the website, or display content according to your preferences.

(c) Data From Other Sources

We may obtain information about you from other sources, including third-party services and organizations (including third parties you use to interact with the Service) to supplement information provided by you. This additional information allows us to verify information that you have provided to us for fraud prevention, marketing, underwriting, risk management, business intelligence and other internal purposes.

(d) Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service, including Google Analytics features, or employ internally developed cookies, clear GIFs, pixel tags, tracking codes and other technologies that allow us to store data on your computer or other device used to access the Service.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies may also be used such as local shared objects (also known as flash cookies, which store your preferences or display content based on what you have viewed on various websites to personalize your visit), web beacons (also known as tags), and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  1. Session Cookies: We use Session Cookies to operate our Service.
  2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
  3. Security Cookies: We use Security Cookies for security purposes.
  4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

(e) Videos

We may target and track the videos that you view on our website. You consent to our tracking of your video viewing through the site or third party social media for up to two years or as permitted by applicable law. You also consent to the sharing of your information in relation to viewing certain video content to third parties, including social media companies.

(f) Location Information

When you use our Services, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“Location Information”). We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as advertising and search results, and to evaluate and improve our Services.

3. Use of Data

We use the collected Data for various purposes:

  1. To register you as a user of the Service;
  2. To establish and maintain your user account;
  3. To provide and maintain the Service;
  4. To process and collect payments;
  5. To notify you about changes to our Service;
  6. To allow you to participate in interactive features of our Service when you choose to do so;
  7. To provide customer support;
  8. To gather analysis or valuable information so that we can improve our Service;
  9. To enforce our Terms of Service, and our Agreement with you;
  10. To monitor the usage of our Service;
  11. To detect, prevent and address technical issues with the Service;
  12. To fulfill any other purpose for which you provide Data;
  13. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for fees and collection;
  14. To provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  15. To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  16. To improve the Service, to develop new products or features, and to enhance its quality;
  17. To help prevent, detect, investigate and report fraud or security incidents related to your use of the Service;
  18. To deliver content (including advertising) correlating to your interests and browsing and usage history, both within our website and on other sites and applications;
  19. To comply with applicable legal requirements and our policies;
  20. To contact you via telephone, text or chat when and in the manner required by law; and
  21. for any other purpose with your consent.

4. Applications, Widgets and Social Media

We may include in our website applications or widgets from social media providers that allow interaction or content sharing by their users. These widgets (such as a “Share” or “Like” button on Facebook or YouTube, for example) are visible on the webpage you visit. Integration between between our website and social media networks in which you participate may allow those networks collect information about you, even when you do not specifically activate the network’s application or widget. Please visit any applicable social media network’s privacy policy to review their data collection practices and the choices they make available to you.

5. Third-Party Service Providers

We may employ or engage third party companies and individuals to facilitate our Service (“Service Providers”, e.g., business communication and collaboration tools, hosting service providers, ad networks, sales and marketing tools, and/or government entities), to perform Service-related functions or to assist us in analyzing how our Service is used, including but not limited to:

  1. To manage, improve and optimize the Service;
  2. To automate the development of the Service (including CI/CD Tools);
  3. For the performance of obligations arising from our Agreement with you;
  4. To process payments and requests for services;
  5. To provide you targeted advertising based on your interests;
  6. To provide you with products, services, offers, newsletters, promotions, etc.; and
  7. To monitor and analyze the use of our Service

These third parties have access to your Personal Data only to perform these tasks on our behalf, and are not authorized by us to disclose it or use it for any other purpose.

6. Retention of Data

‍We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods. We are under no obligation to store Personal Data indefinitely, and disclaim any liability arising out of, or related to, the destruction or deletion of such Personal Data.

7. Information Shared with Buyers, Sellers, Dealers and Manufacturers

Information about you, including Personal Data and Usage Data, may be shared with buyers, sellers, dealers and manufacturers, and their agents and third-party service providers, who will use that information in accordance with their own privacy policies. For example,

  1. If you express or indicate interest in a certain listing of vehicle for sale on our website, information about you may be shared with the buyer or seller of that vehicle or dealers of similar vehicles in your area;
  2. If you are seeking to trade in a vehicle, we may provide information about you to dealers who participate in our trade-in program;
  3. We may provide manufacturers, their agents or third party service providers with information about you when you access our website via our branded advertising or functionality found on their websites.

8. Disclosure of Data as Required or Permitted by Law

We may disclose personal information that we collect, or that you provide as may be required pursuant to judicial or governmental subpoenas, warrants, or orders, or to protect us from legal liability. We reserve the right to use, disclose and/or share your Personal Data in the following circumstances, without limitation:

  1. Disclosure for Law Enforcement.
    Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
  2. Business Transaction.
    If we or our subsidiaries are involved in a merger, acquisition or asset sale, all information we have collected and stored, including but not limited to Personal Data, may be transferred to the party or parties involved in the transaction.
  3. Investigation.
    ‍Under certain circumstances, we disclose your Personal Data to prevent or investigate possible wrongdoing in connection with the Service.

9. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors). These payment processors are obligated to adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, to help ensure the secure handling of payment information.

10. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

11. Security of Data

The security of your Data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security, and you provide this information at your own risk.

ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING THE SERVICE. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.

To the maximum extent allowed by applicable law, you agree and acknowledge that we will not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. You agree that you will contact and notify us immediately if you have reason to believe that the security of your Personal Data has been compromised.

12. Protected Health Information – HIPAA

We are not a health plan, healthcare clearinghouse or healthcare provider, or otherwise a “covered entity” as defined or contemplated by The Health Insurance Portability and Accountability Act of 1996, as amended (HIPAA). You acknowledge and agree we are not obligated to comply with HIPAA rules requirements regarding privacy and security of “Protected Health Information” (ePHI) that we may be provided pursuant to your use of the Service. You are solely responsible for ensuring that your use of the Service complies with all applicable laws and regulations, including HIPAA. If we become aware that you have transmitted ePHI in any manner through the Service in violation of this Agreement or HIPAA, you acknowledge and agree that: (a) we may delete the ePHI without notice to you and without us incurring any liability to you, and (b) you agree to pay any costs or fees associated with that ePHI deletion.

13. For Residents of the EU and EEA — Your Data Protection Rights Under GDPR

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by General Data Protection Regulation (GDPR). – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj , In certain circumstances, you have the following data protection rights:

  1. The right to access, update or to delete the information we have on you;
  2. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
  3. The right to object. You have the right to object to our processing of your Personal Data;
  4. The right of restriction. You have the right to request that we restrict the processing of your personal information;
  5. The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
  6. The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at privacy@secureprivatesale.com.

14. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3

According to CalOPPA we agree to the following:‍

  1. Users can visit our site anonymously;
  2. Our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the homepage of our website;
  3. Users are able to change their personal information by emailing us at privacy@secureprivatesale.com;

By using the Service, you acknowledge and agree that we do not recognize or respond to browser-initiated Do Not Track signals, as the internet industry is currently still working on Do Not Track standards, implementations, and solutions.

15. For Residents of California — Your Data Protection Rights under the California Consumer Privacy Act (CCPA)‍

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. To exercise your data protection rights pursuant to the CCPA, you can make certain requests and ask us:

  1. What personal information we have about you. If you make this request, we will return to you:
    1. The categories of personal information we have collected about you.
    2. The categories of sources from which we collect your personal information.
    3. The business or commercial purpose for collecting or selling your personal information.
    4. The categories of third parties with whom we share personal information.
    5. The specific pieces of personal information we have collected about you.
    6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
    7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

    Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

  2. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
  3. To stop selling your personal information. If you are a California resident, you may opt-out of the sale of your personal information.
  4. To stop sharing your personal information. If you are California resident, you may opt-out of the “sharing” of your personal information (defined as the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across websites).

Please note, if you ask us to delete or stop selling your personal information, it may impact your experience with us, as you may not be able to participate in certain aspects of the Service which require the usage of such Data to function. However, we will not discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by email to: privacy@secureprivatesale.com.

16. For Residents of California — California Shine the Light Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents, one time per calendar year, to request information regarding the disclosure of your Personal Data (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. To exercise your rights under this section, please send your request by email to: privacy@secureprivatesale.com.

17. Privacy Notice for Connecticut Residents

Pursuant to Connecticut General Statutes Section 42-471, it is our policy to protect the privacy of your personal information by doing the following: Safeguarding any data, computer files and documents containing your personal information from any misuse by third parties; Destroying, erasing or making unreadable any data, computer files and documents containing your personal information prior to their disposal; Protecting the confidentiality of your Social Security number and other personal information; Prohibiting the unlawful disclosure of your Social Security number and other personal information; Limiting and/or restricting access to your Social Security number and other personal information to other third parties; and Limiting the access of your Social Security number and other personal information only to our employees who need access to your personal information to allow us to provide services to you, limiting the access of these employees to the extent needed, and otherwise imposing restrictions and reasonable safeguards on our employees to prevent them from accessing your personal information.

18. Other State Privacy Rights

If your state has enacted a consumer privacy law, you may have the following rights with regard to your Personal Data, subject to certain conditions and restrictions. Capitalized terms used in this section shall have the same meaning as under applicable law.

  1. Right to Access. You may have the right to know the Personal Data we may hold about you and to access such Personal Data.
  2. Right to Correct. You may have the right to request that we correct inaccuracies in your Personal Data.
  3. Right to Delete. You may have the right to request that we delete all Personal Data that we have collected from or obtained about you.
  4. Right to Opt-Out of Sales. Insofar as some of the ways that we share Personal Data could constitute a “Sale” under applicable state law, you may have the right to opt-out of the Sale of Personal Data.
  5. Right to Opt-Out of Targeted Advertising. You may request that we stop disclosures of your Personal Data for Targeted Advertising.
  6. Right to Opt-Out of Profiling. You may have the right to opt-out of our processing of Personal Data for the purposes of profiling.
  7. Right to Appeal. If you are unsatisfied with our actions related to the exercise of one or more of your privacy rights, you may have the right to appeal our decision.
  8. Sensitive Data. Our processing of any Sensitive Data will be based on your consent. For example, in the course of using our Service, you may allow us access to your precise geolocation. You may be able to limit or disallow this use of location by adjusting your device’s privacy settings.

You may submit requests related to these rights by email to privacy@secureprivatesale.com.

19. Children’s Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”). We do not knowingly collect personally identifiable information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we will delete the personal information to the extent required by COPPA.

We do not knowingly process Personal Data of EU residents under the age of 16 without the consent of a parent or legal guardian. If we become aware that we have collected Personal Data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as is practicable.

20. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

21. Contact Us

If you have any questions about this Privacy Policy, please contact us by email, at privacy@secureprivatesale.com.