Last Updated: February 11, 2020
This privacy notice (the "Privacy Notice") applies to personal information that Hearst Autos, Inc. ("Hearst Autos", "we", "our" or "us") obtains in connection with the operation of our mobile application BuyQ (the "App"). The App allows a user to scan a car in order to obtain relevant information about the car such as the make, model, comparable cars and location of the closest car dealer(s) listing the car for sale. This Privacy Notice applies only to the personal information and other data that Hearst Autos obtains in connection with the operation of the App and describes how we can use the personal information we obtain, with whom we may share it and rights you may have with respect to your personal information collected through the App.
This Privacy Notice does not describe the data handling practices of the car dealers and others with whom you may choose to contact through the App. We encourage you to review the privacy notices and similar statements on the car dealers' site to learn about their privacy practices.
What Personal Information We Obtain
Hearst Autos will use your personal information and other data for the purposes described in the table below. In addition, Hearst Autos may use any and all of the personal information and other data collected though or in connection with the operation of the App for certain standard purposes and may disclose such personal information and data in certain circumstances (e.g., to comply with a legal obligation) described further down below.
|Categories of Personal Information||Source(s) of Personal Information||How is Your Personal Information Used by Hearst Autos?||With Whom is Your Personal Information Shared?|
|1.||Identifiers including your name and contact details (e.g., email address, postal code and phone number)||
|2.||Geolocation data when you choose to permit the App to access device location||
|3.||Internet or other electronic network activity (e.g., information about how you use, access, or interact with the App)||
|4.||Inferences regarding your preferences or interests||
Please note that some features of the App may not work if you choose not to allow certain mobile device permissions or provide some of the requested personal information.
In addition to the purposes set out in the table above, Hearst Autos may use the personal information and other data we obtain in connection with the operation of the App to:
- Comply with and enforce applicable industry and legal requirements (including legal process such as court orders, warrants or subpoenas).
Hearst Autos also may share the personal information and other data we obtain in connection with the operation of the App:
- With our affiliates and subsidiaries, as necessary or appropriate to operate the App;
- With our attorneys, accountants, auditors or other advisors, as necessary or appropriate;
- To comply with or enforce applicable law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities; and/or
- To the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of our assets (including in the event of a reorganization, dissolution or liquidation).
In addition, we may share aggregated or deidentified data with third parties for any purpose.
The information ad networks may collect include information about your visits to websites or apps that participate in the relevant advertising networks, such as the pages, advertisements or videos you view and the actions you take on the websites or apps. This data collection may take place on the App and on third-party websites or apps that participate in ad networks. This process allows us and third parties to deliver more tailored advertising. In addition, it helps us track the effectiveness of our marketing efforts. In serving interest-based ads, Hearst Autos adheres to the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance. To learn more about your rights in relation to interest-based advertising, including your choice to opt-out, please see the "Your Rights Over Your Personal Information" section below.
Third-Party Links And Features
The App may contain links to third-party websites or features. Hearst Autos is not responsible for the collection or use of your personal information by such third parties. We encourage you to review the privacy notices or other similar statements applicable to third-party websites or features.
Your Rights Over Your Personal Information
Interest-Based Ads Opt-Outs
To learn more about your rights in relation to interest-based advertising, including your choice to opt-out, you can follow the instructions provided by the Digital Advertising Alliance ("DAA") here (for browsers), here (for apps) and/or the Network Advertising Initiative ("NAI") here to place an opt-out cookie on your browser. These opt-out Cookies enable you to block participating companies from installing future Cookies. The DAA "AppChoices" tool allows you to limit the collection and use of information for interest-based advertising purposes by participating companies in the app environment. In addition, to limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as "Limit Ad Tracking" for iOS or "Opt-out of interest-based ads" for Android.
These opt-out mechanisms are provided by third parties. Hearst Autos does not control or operate these mechanisms, or the choices provided through these mechanisms.
Web Monitoring and Analytics
The App's use analytics, including analytics provided by Mixpanel, to help improve the user experience and functionality. To learn more, please visit the link here.
Additional Information for California Residents
Under California law, specific disclosures are required and California residents have additional rights regarding their personal information. Please review this section to learn more.
Your California Consumer Privacy Act of 2018 (“CCPA”) Rights
Residents of California may have the following rights:
- Right to access your personal information. You may request to access the categories and specific pieces of personal information that we collected about you through the App.
- Right to deletion. Subject to certain exceptions, you may ask us to delete the personal information we collected about you through the App.
- Right to disclosure. You may request to receive additional details about the sources from which we collect information, the reasons we collect and share information, and the types of third parties with which we share the personal information we collected about you through the App.
- Right to opt out of sales. Under CCPA, certain types of sharing of personal information may constitute a “sale” of your personal information. When you engage with the app or the car dealer(s) and share your personal information, you direct Hearst Autos to share your information with the relevant car dealer(s) with whom you choose to interact. This type of interaction does not constitute a “sale” of your personal information by Hearst Autos.
- Right to be free from discrimination. You may exercise any of the above rights without fear of being denied goods or services.
If you would like to exercise your CCPA rights with respect to the personal information we collected about you through the App, please contact us by email at email@example.com.
We do not knowingly collect or disclose personal information of minors under the age of 16, without affirmative authorization.
Your Shine the Light California Rights (CA Civil Code § 1798.83)
Residents of California may request a list of third parties to which certain personal information (as defined by applicable California law) obtained through the App was disclosed by Hearst Autos during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at Hearst Autos, Inc, Attn: Privacy, 300 West 57th Street, New York, NY 10019. For such requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. Please also indicate in your request that it relates to BuyQ. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Do Not Track
Hearst Autos does not currently take steps to respond to browsers' "Do Not Track" signals as no uniform standard to respond to such signals has been developed at this time.
Children's Privacy Rights
The App is not intended for use by children, especially those under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us as indicated below.
How We Protect Your Personal Information
We maintain reasonable administrative, technical and physical safeguards to protect the personal information we obtain through the App. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
International Data Transfers
The personal information collected through the App will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country. The App is intended for consumers located in the United States only.
Changes To This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our privacy practices or applicable laws. We may, as permitted by law, make such changes without prior notice. We will publish the updated version on the App and indicate at the top of the Privacy Notice when it was most recently updated.
If you have any questions about this Privacy Notice or, in accordance with applicable laws, you would like to review or request changes to the personal information collected in connection with your use of the App, please contact us at firstname.lastname@example.org.