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Home / Privacy Policy

Privacy Policy

Effective Date: January 22, 2021

Introduction

Thank you for visiting our Winn VW of Woodland Hills website. Winn VW of Woodland Hills and our affiliates (together, " Winn VW of Woodland Hills " or "we") strive to make our website a useful tool and a rewarding experience for our customers by tailoring the content to your personal needs and interests. This way, the content of our website will be as relevant as possible for you, the customer. We hope that you find our website to be a useful part of your car-buying experience.

We respect your privacy and have created the following Privacy Policy to let you know what personal information we collect when you visit our website, purchase our product, use our services, and visit our facility, why we collect it and how it is used and disclosed. This Privacy Policy applies to personal information we collect online as well as in person. As used in this policy, “personal information” and “information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be hyperlinked, directly or indirectly, with a natural person who resides in California (or a household having one or more California members), where the information is not excluded from coverage under the California Consumer Privacy Act (CCPA). Information excluded from CCPA coverage may be subject to separate privacy policies we maintain in compliance other applicable laws.

This policy may change from time to time to reflect our internal needs, customer feedback, or changes in law or regulation. We will post any changes on our website. By using our website and services (collectively, the “Services”) you acknowledge you have read and understand the terms and conditions of this Policy.

PLEASE NOTE THE ARBIRATION PROVISION SET FORTH BELOW REQUIRES, EXCEPT WHERE AND TO THE EXTENT PROHIBITED BY LAW, YOU TO ARBITRATE ANY CLAIMS YOU MAY HAVE AGAINST THE COMPANY ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY.

PLEASE SEE THE DISPUTE RESOLUTION AND ARBITRATION PROCEDURE BELOW.

What information do we collect and what do we use it for?

This table provides a summary of the personal information we collect and how we use it, which is further explained in our Privacy Policy below. While the actual information we collect and our use of such personal information varies depending upon the nature of our relationship and interactions, the table below provides a general overview of the categories of personal information we collect, sources of collection, and the purposes for which we use such information including disclosure to third parties as indicated.

Category of personal data
Purpose(s) for collection
Disclosure to third parties
Identifiers, such as: Name, postal address, email address, IP address, identification numbers (e.g., social security number, driver’s license number, state identification number, military identification number or passport number)
• To respond to consumers’ requests and inquiries
• Communicate with consumers regarding our products or services
• Enter into and process transactions with consumers
• Send marketing communications
• Complete government forms
• Confirm consumers’ identity and that they are at least 18 years old
• Confirm consumers are licensed to drive our vehicles or take delivery of a vehicle purchased or leased from us
• Disclosure for service providers, for administrative and operational assistance.
• Disclosure for safety and warranty purposes to vehicle manufacturer, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
• Disclosure to state or federal agencies, when required by law
• Disclosure to vehicle manufacturer for marketing and analytical purposes, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as: Phone number; insurance information; bank account number, credit card number, debit card number, or other financial information, including information relating to consumers’ vehicle financing or lease terms, along with vehicle information; and/or signature(s).
• To respond to consumers’ requests and inquiries
• Communicate with consumers regarding our products or services
• Enter into and process transactions with consumers
• Send marketing communications
• Complete government forms
• Confirm insurance coverage
• Confirm identity
• Obtain authorization to collect payments
• Collect payments
• Confirm acknowledgement of receipt of documents we provide to consumers
• Disclosure for service providers, for administrative and operational assistance.
• State or federal agencies, when required by law
• Disclosure to vehicle manufacturer for marketing and analytical purposes, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
Protected classification characteristics under California or federal law, such as:
A photocopy/scan of government issued identification reveals personal information. For example:
• Driver’s license/state identification card - includes image, date of birth, physical description and gender
• Permanent resident card - includes image, date and place of birth;
• Social security card - includes social security number
• Passport - includes image, date and place of birth and nationality
• Military ID - includes image and rank Completion of a Translated Contract Acknowledgement or signing of translated documents reveals a consumer’s primary language
• To confirm identity
• Confirm consumers are licensed to drive our vehicles or take delivery of a vehicle purchased or leased from us
• Confirm eligibility for a manufacturer or lender rebate and to apply for and process any such rebate
• Determine coverage under the Military Lending Act in connection with a financed vehicle transaction
• Provide consumers with copies of certain documents written in the language in which their finance or lease transaction was primarily negotiated, as required by law
• Complete government forms
• Disclosure to companies from whom consumers request we obtain for them goods or services, such as manufacturers or lenders for processing applicable transactions
• Disclosure to state or federal agencies, when required by law
Commercial information, such as: Vehicle information, ownership information, and current lease or finance terms
• Enter into and process transactions with consumers
• Appraise consumers’ vehicles
• Send informational and marketing communications
• Retain records of transactions as required by law
• Fulfill the terms of a written warranty or product recall
• Process warranty, insurance or service contract claims
• Share information with state agencies as required by law
• Disclosure for business purposes to payment processors, delivery services and warranty, insurance or service contract administrators, if applicable to transaction
• Disclosure for safety and warranty purposes to vehicle manufacturer, if customer purchased/leased a new or certified vehicle or if their vehicle was serviced at our dealership
• Disclosure to state or federal agencies, when required by law
Biometric information
Consumers who finance/lease vehicles may be asked to complete a “Thumbprint form”
• To confirm identity
• Disclosures for business purposes to confirm your identity
Internet or other similar network activity information, such as: IP address, browsing history, and search history
• To communicate with consumers regarding our products and services • Improve user experiences by making our website easier to use and navigate, and more personalized based on the profile we create about consumers
• Disclosure for service providers, for administrative and operational assistance.
Geolocation information, such as: IP address and vehicle location (using GPS, as permitted by law)
• To respond to consumers’ requests and inquiries
• Enter into and process consumers’ transactions with you • Send marketing communications
• Track vehicles as permitted by law
• Disclosure for service providers, for administrative and operational assistance.
• Disclosure to service providers for business purposes
Sensory data, such as Audio information from voicemail messages and/or recorded phone calls (with consumers’ consent)
• To communicate with you; some phone calls are recorded (with your consent) for training our staff and for quality assurance purposes
N/A
Professional or employment-related information, such as: Information regarding current occupation
• To confirm eligibility for a manufacturer or lender rebate and to apply for and process any such rebate
• To confirm eligibility for employee discount pricing
• Complete government forms, as required
• Disclosure to manufacturer or lender for processing applicable rebate
• Disclosure to state or federal agencies, when required by law
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such as: Information regarding whether a consumer is or will soon be a college graduate
• To confirm eligibility for a manufacturer or lender rebate and to apply for and process any such rebate
• Disclosure to manufacturer or lender for processing applicable rebate
Inferences drawn from personal information to create a profile, such as: Information regarding consumers’ vehicle preferences and needs
• To market our products and services to consumers
N/A

Sources of personal information.

We collect personal information from consumers and other individuals like you (both directly and indirectly, such as from your transactions and interactions with us), and from other sources, including the following:

• Credit bureaus (to check credit and verify information)
• Governmental agencies like DMV (to check vehicle title status, for example)
• Vendors and service providers (such as advertising or dealership computer companies)
• Contractual counterparties (such as the vehicle manufacturer)
• Financial institutions (such as the bank that finances a customer’s trade-in)
• Websites and social media (where you may have expressed an interest in shopping with us, for example)
• Our affiliates (such as other dealerships or businesses of ours where you previously shopped)
• Customer referrals or personal references
• Other parties we contract with (such as service contract providers who provide information about existing service contracts you may have)
• Government’s Military Lending Act website in the case of military customers
• From telematics systems (such as vehicles equipped with GPS tracking (in limited instances and only as permitted by law) or smartphone or mobile devices set to share information with us)
Affiliates
Winn VW of Woodland Hills shares your information with its affiliated dealerships and businesses in order to make offers to you for sales and service.

Sales of Information
Winn VW of Woodland Hills does not engage in transactions to provide any third party with personal information about you in exchange for money. However, some marketing and data analysis arrangements dealers have with third parties could be considered under certain interpretations of the CCPA to involve a “sale” of personal information by the dealer to those parties. As a result, to avoid even the potential of making disclosures inconsistent with the CCPA’s definition of sale, we state that we may “sell,” as that term is defined under the CCPA, the following categories of information about you:

• Personal identifiers
• Any categories of personal information described in subdivision (e) of California Civil Code Section 1798.80.
• Characteristics of protected classifications under California or federal law
• Commercial information
• Internet, application, and network activity, such as cookie IDs and browser visits
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information
• Employment information, such as occupation, title, licenses and professional memberships
• Education information, such as degree and schooling information
• Inferences drawn from any of the information identified in this section

We do not sell personal information about California residents who we know are younger than 16 years old without opt-in consent


International Data Transfers

Dealership is based in the U.S. If you choose to provide us with information, please understand that your personal information may be transferred to the U.S. and that we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the EU or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the U.S. and other jurisdictions which may not have the same data protection laws as the EU. We put in place appropriate operational, procedural and technical measures in order to ensure the protection of your personal information. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Policy; and (ii) your personal information may be transferred to the U.S. and other jurisdictions as indicated above, in accordance with applicable law.



Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not knowingly collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 16 years old or older. In the event that we learn that a person under the age of 13 has provided personal information to us, we will delete such personal information as soon as possible.

Cookies and Third Party Advertising

We, and third parties we allow, use cookies and other similar technologies. Cookies are small text files placed on your device that uniquely identify your device and which a website can transfer to a consumer’s hard drive to keep records of his or her visit to a website. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which are explained below:

• Essential. Some cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
• Analytics. We use Google Analytics to measure how you interact with our website and to improve your user experience. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page at https://support.google.com/analytics/answer/6004245?hl=en. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics at https://tools.google.com/dlpage/gaoptout.
• Targeted Advertising. We use cookies to compile information on our users interaction with our website. We use this information to serve ads to you off of our website.

There are several ways to manage cookies. You can control the use of cookies at the browser level, by instructing your browser to accept cookies, disable cookies or notify you when receiving a new cookie. Please note that if you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

Unsubscribe-if applicable

We provide you the opportunity to opt-out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided below. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.

Third-Party Links-if applicable

Our website contains links to other sites. Dealership is not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.
California Consumer Privacy Act Rights

Notice at Collection. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. Please see our Notice at Collection at this web page: winnvwwoodlandhills.com/notice-at-collection

Right to Know: California residents are entitled to ask us for a notice describing (1) the categories of personal information we have collected in the preceding 12 months, (2) the categories of sources of that information, (3) the business or commercial purpose for collecting that information, (4) the categories of third parties and affiliates the information is shared with, (5) whether the information was sold, and (6) whether we sell the information of minors under 16 (we do not). If you would like a copy of this notice, you may submit a request by emailing Privacy@WinnMotors.com or place a request by calling this number: 747-259-0364. We will contact you to verify the request and will ask that you provide information that matches the identifying information you provided that we already maintain. Please allow up to 45 days for us to provide this notice.

Data Portability: California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. If you would like a copy of this notice, you may submit a request by emailing Privacy@WinnMotors.com or place a request by calling this number: 747-259-0364. We will contact you to verify the request and will ask that you provide information that matches the identifying information you provided that we already maintain. Please allow up to 45 days for us to provide this notice.
Right to Request Deletion: California residents are entitled to request the deletion of their personal information collected or maintained by us. If you would like some or all of the personal information we have collected and maintained about you deleted, you may submit a request by emailing Privacy@WinnMotors.com or place a request by calling this number: 747-259-0364. We will contact you to verify the request and will ask that you provide information that matches the identifying information you provided that we already maintain. Please allow up to 45 days for us to provide this notice.

Right to Opt-Out: California residents have the right to opt-out of the sale of their personal information. If you would like your personal information to be deleted, you may submit a request by emailing Privacy@WinnMotors.com or place a request by calling this number: 747- 259-0364. We will contact you to verify the request and will ask that you provide information that matches the identifying information you provided that we already maintain. Please allow up to 45 days for us to provide this notice.

 Authorized Agent: You have the right to designate an authorized agent to exercise your privacy right under California law. Any person seeking to exercise the privacy rights of another must either (1) provide written permission from the individual granted to the agent to act in this manner AND verify their own identity to us, or (2) provide a copy of power of attorney pursuant to Probate Code section 4000 to 4465.

Discrimination and Incentives. The CCPA prohibits discrimination against those who exercise their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their Personal Information. A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent.

We do not sell or knowingly collect the personal information of minors under 16 years of age and do not have actual knowledge of selling personal information of minors under 16 years of age.

 If you would like to exercise one or more of the rights above, please contact us using the contact information provided below. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent if we cannot confirm that they have been authorized by you to act on your behalf.

We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Shine the Light. Under California’s Shine the Light law Civil Code Section 1798.83), California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about customer information obtained online that we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. You may call 747-259-0364 or email Privacy@WinnMotors.com to request a copy. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” law requirements and only information on covered sharing will be included in our response.

Notice Regarding Public Posting Areas

Please note that any information you include in a message you post to any public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. DEALERSHIP IS NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.

Security

We implement reasonable security measures to ensure the security of your personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Assignment

We may share or transfer your information in the course of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or a part of our assets. Your information may be shared following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, your information would remain subject to this Policy or a privacy policy that, at a minimum, protects your privacy to an equal degree as this Policy.

Dispute Resolution and Agreement to Arbitrate

By providing information to us, you and we agree that if there is any controversy, claim, action, or dispute arising out of or related to your use of our services or the breach, enforcement, interpretation, or validity of this Policy or any part of it (“Dispute”), both parties shall first try in good faith to settle such Dispute by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party 30 days in which to respond to or settle the Dispute. Notice shall be sent to:
• Winn VW of Woodland Hills at 21141 Ventura Blvd., Woodland Hills, CA 91364; ATTN: Privacy Policy
• You, at the address we have on file for you.

Both you and we agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS IN CALIFORNIA. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY. The parties expressly agree that this arbitration provision and any arbitration under this agreement is governed and controlled by the Federal Arbitration Act. Other rights that you and we would otherwise have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. All such disputes shall be exclusively submitted to JAMS, at offices closest to our principal place of business in California, for binding arbitration under its rules then in effect, before one arbitrator to be mutually agreed upon by both parties. The rules for arbitration may be reviewed at jamsadr.com.

The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising under or relating to the interpretation, applicability, enforceability, or formation of this Privacy Policy, including any claim that all or any part of this Privacy Policy is void or voidable.
Other Arbitration Agreements

In the event of a conflict between this agreement to arbitrate and any other arbitration agreement between you and Winn VW of Woodland Hills, such as an arbitration agreement contained in a retail installment sale contract, lease agreement, or repair estimate (Other Arbitration Agreement), the terms of the Other Arbitration Agreement shall govern and prevail in each instance.

Venue and Choice of Law

This Policy has been made in and shall be construed in accordance with the laws of the State of California, without giving effect to any conflict of law principles. Any disputes or claims not subject to the arbitration provision discussed above shall be resolved by a court located in the State of California and you agree and submit to the exercise of personal jurisdiction of such courts for the purpose of litigating any such claim or action.

How We Respond to Do-Not-Track Signals

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time our website does not recognize automated browser signals regarding tracking mechanisms, which may include DNT instructions.

Changes to this Privacy Policy

If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date above. If we make material changes to the Policy, we will notify you by placing a prominent notice on our website and/or by sending you an email at the email address we have on file for you. We encourage you to periodically review this Policy to keep up to date on how we are handling your personal information.

Your Consent

By using our website or providing information to us, you consent to this privacy policy and agree to those sections of it providing for there to be an agreement between you and us.

Contacting Us If you have questions, comments or concerns about our privacy practices or this policy, please contact us at 747-259-0364, by email at Privacy@WinnMotors.com or by postal mail to: Winn VW of Woodland Hills, Attention Privacy Policy, 21141 Ventura Blvd., Woodland Hills, CA 91364.

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