Privacy Policy

Effective as of August 3rd, 2020.

This Privacy Policy describes how CarPay, Inc. (“CarPay”) handles personal information of consumers who shop for and buy cars from auto dealers that use our platform. CarPay is a service provider to dealers. Our technology helps dealers gather information from consumers that dealers need to qualify the consumer for a loan. After a consumer obtains a loan, they use CarPay to make loan payments. In providing our services, CarPay handles the consumer’s personal information on behalf of the dealer for the purposes set out in our agreement with the dealer.

Personal information we collect

Information you provide to us. Personal information CarPay collects on behalf of dealers includes:

Automatic data collection. We, our service providers, and our business partners may automatically log information -- using cookies, web beacons, SDKs, and similar technologies -- about you, your computer or mobile device, and your activity over time on our sites, our mobile application, other sites, and online services, including:

How we use your personal information

Providing our services. We use the personal information we collect to provide, operate, and improve the services we provide to dealers, including to:

Research and development. We may use the information we collect to maintain, improve, and enhance our services and service offerings. We may also create aggregated and/or de-identified data from personal information by removing information that makes the data personally identifiable to you.

Marketing. We may email you marketing communications on behalf of dealers. You may opt-out of these marketing communications as described in the Opt-out of marketing communications section below.

Compliance and protection. We may use your personal information to:

How we share your personal information

We may share your personal information with:

Dealers and companies on behalf of dealers at their direction, including financial institutions to facilitate loan payments.

Service providers. Companies and individuals that provide services on our behalf or help us operate the services or our business (such as information technology, hosting, customer relationship management and support, email delivery, marketing, website analytics, payment processing, and credit screening).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquiring and other relevant parties to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, CarPay or our affiliates (including in connection with a bankruptcy or similar proceedings).


Your choices

You have the following choices with respect to your personal information.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us You may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of our services or they may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Mobile location data. Users of our mobile application can disable our access to their device’s precise geolocation in their mobile device settings.

Do Not Track. Some Internet browsers may be configured to send “ Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Third party platforms. If you choose to connect your accounts on other platforms, to our services (for example, your bank account), you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.


Other sites and services

Our services may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions.


Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.


Dealer personnel

We collect personal information from an auto dealer’s personnel (such as their employees and contractors) to provide our services to the dealer, for research and development, and for compliance and protection as described above. We may share the personal information with business transferees as described above.


Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.


How to contact us