Privacy Policy

PROVIDER KEY: We may disclose, sell, or share your Personal Information with the following categories of service providers, contractors, or third parties for purposes including employment, providing employment benefits, fulfilling contractual obligations with customers, vendors, or contractors, or for improving our website(s):

A. Financial institutions

B. Lead providers

C. Product manufacturers/administrators

D. Government agencies

E. Promotional or other fulfillment vendors

F. Support vendors for marketing, managing, or hosting the website or the Ethics Hotline

G. Transaction support vendors (e.g., check guaranty, payment processors)

H. Data analytics vendors

I. Professional employer organizations

J. Consumer reporting agencies or credit reporting agencies

K. Third-Party hosted (i.e., SaaS) technology service providers

L. Security and risk management vendors

M. Corporate customers

N. Original equipment manufacturers (OEM) (suppliers and makers of the products we sell or lease to our customers)

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect from or about consumers, independent contractors, or applicants:

1. Personal Identifiers: Social Security number, driver’s license or state identification card number, passport number
2. Account Information: Company account login, in combination with any required security or access code, password, or credentials allowing access to the account
3. Protected Classifications: Racial or ethnic origin, religious or philosophical beliefs, union membership, or sexual orientation
4. Biometric Information: Information used to uniquely identifying you
5. Medical and Health Information
6. Geolocation Data: IP address and/or GPS location, latitude and longitude

Personal information does not include:

• Publicly available information from government records
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer, independent contractor, or applicant, or from widely distributed media
• Information made available by a person to whom the consumer, independent contractor, or applicant has disclosed it, if the consumer, independent contractor, or applicant has not restricted the information to a specific audience
• Deidentified or aggregated information

We may collect your Personal Information from the following sources:

• You, the consumer, independent contractor, or job applicant, when you visit the website and voluntarily submit information through forms on the website or social media, visit any of our stores or physical locations, purchase or inquire about our products or services, enter into a contract to perform services for us, or apply for a position of employment
• Our employees and contractors, when you interact with them
• Other customers and visitors, when you interact with them or when they observe you
• Cookies and other tracking technologies, which automatically collect information about website visitors
• Surveillance cameras at our physical locations
• Lead generators and referral sources
• Credit and consumer reporting agencies
• Recruiters
• Social media platforms
• Company-issued computers, electronic devices, and vehicles
• Company systems, networks, software applications, and databases you log into or use

We may collect your Personal Information for the following business purposes:

• To fulfill or meet the purpose for which you provided the information
• To process and submit financing applications, including applications for credit or credit pre-qualification
• To process, complete, and maintain records of transactions
• To provide warranty coverage on products and services
• To retain your Text opt-in/opt-out to ensure customers who opted out are not sent any text messages
• To provide and communicate recall notifications to customers
• To schedule, manage, and track customer appointments
• To complete appraisals
• To maintain records when customers decline a service or sale
• To respond to consumer inquiries, including requests for information, customer support online, via the Ethics Hotline, phone calls, or in-facility inquiries
• To provide interest-based and targeted advertising
• To improve user experience on our website
• To understand the demographics of our website visitors
• To detect security incidents
• To debug, identify, and repair errors that impair intended functionality of our website
• To protect against malicious or illegal activity and prosecute those responsible
• To verify and respond to consumer requests
• To prevent identity theft

JOB APPLICANT PURPOSES:

• To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment.
• To comply with local, state, and federal law and regulations requiring employers to maintain certain records, as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19.
• To evaluate your job application and candidacy for employment.
• To obtain and verify background check and references.
• To communicate with you regarding your candidacy for employment.
• To reduce the risk of spreading infectious diseases in or through the workplace.

INDEPENDENT CONTRACTOR PURPOSES:

• To fulfill or meet the purpose for which you provided the information.
• To comply with state and federal law and regulations requiring businesses to maintain certain records (accident or safety records, and tax records/1099 forms).
• To engage the services of independent contractors and compensate them for services.
• To evaluate, make, and communicate decisions regarding an independent contractor, including decisions to hire and/or terminate.
• To grant independent contractors access to secure Company facilities, systems, networks, computers, and equipment, and maintain information on who accessed such facilities, systems, networks, computers, and equipment, and what they did therein or thereon.
• To implement, monitor, and manage electronic security measures on independent contractor devices that are used to access Company networks and systems.
• To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company.
• To improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
• To reduce the risk of spreading infectious diseases in or through the workplace.

We may disclose your personal information for the following business purposes as numbered above: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19(a), 19(b), 19(d), 20(a), 20(e), 20(f), 20(g), 20(h), and 20(i).

We do NOT and will not sell your Personal Information in exchange for monetary or other valuable consideration. We do not share your Personal Information for cross-context behavioral advertising.

We do NOT and will not use or disclose your sensitive Personal Information for purposes other than the following:

1. To perform the services reasonably expected by an average employee who requests those services
2. To detect security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the Company and to prosecute those responsible
4. To ensure the physical safety of natural persons
5. For short-term, transient use
6. To perform services on behalf of the Company
7. To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance that product, service, or device that is owned, manufactured, manufactured for, or controlled by the Company
8. For purposes that do not involve inferring characteristics about the consumers, contractors, or applicants

Retention of Personal Information

We will retain each category of Personal Information in accordance with our established data retention schedule as indicated above. In determining how long to retain each category of Personal Information, we consider multiple criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state, and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal obligations to preserve evidence.

We apply our data retention procedures annually to determine whether the business purposes for collecting the Personal Information and legal reasons for retaining it have both expired. If so, we will purge the information in a secure manner.

Third Party Vendors

We may use other companies and individuals to perform certain functions on our behalf. Examples include administering email services and running special promotions. Such parties only have access to the Personal Information necessary to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited email messages from vendors working on our behalf.

Business Transfers

In the event we sell or transfer a particular portion of our business assets, the information of consumers, contractors, and applicants may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, this information of consumers, contractors, and applicants may be transferred as part of the acquisition.

Compliance with Law and Safety

We may disclose specific personal and sensitive Personal Information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.

Use of Cookies and Other Tracking Technologies

Cookies are small files that a website may transfer to a user’s computer. They may reside on the computer for the duration of the browsing session (session cookies) or on a permanent basis until deleted (persistent cookies). Cookies may be used to identify a user, a user’s device, or a user’s behavior.

We use cookies under the following circumstances and for the following purposes:

1. To provide you with services available through the website and enable the use of certain features
2. To authenticate users and prevent fraudulent use of user accounts
3. To identify whether users have accepted the use of cookies on the website
4. To compile data about website traffic and how users interact with the website, in order to offer a better website experience
5. To understand and save visitor preferences for future visits—such as remembering login details or language settings—and provide a more personalized experience without requiring preferences to be re-entered each time the website is used
6. To track browsing habits in order to display advertising more likely to be of interest, including third-party advertising on the website

Users can delete cookies from their web browser at any time or block cookies on their device; however, doing so may affect website functionality or even block the website. Users can configure browser settings to prevent the saving of cookies (disable or delete them) at any time. Some functions on our website may not be available when cookies are deactivated. Check the browser settings.

Below is guidance for common browsers:

• Google Chrome
• Microsoft Edge
• Mozilla
• Safari
• Opera

External Links

Our website may contain links to other sites. We are not responsible for the privacy practices or the content of such websites. To help protect your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website.

Passwords

The personal data record created when you register on our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained within this record, you should not disclose or otherwise reveal your password to third parties.

Children Under the Age of 16

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

How We Protect the Information that We Collect

The protection of the information that we collect about visitors to this website is of the utmost importance, and we take every reasonable measure to ensure that protection, including:

1. Keeping automatically collected data and voluntarily collected data separate at all times
2. Using internal encryption on all data stores that house voluntarily captured data
3. Using commercially reasonable tools and techniques to protect against unauthorized access to our systems
4. Restricting access to private information to those who need such access in the course of their duties

International Visitors

We do not target, market to, or offer our products or services to consumers outside of the United States. You agree not to submit your personally identifiable information through the website if you reside outside the United States. If we become aware that a person residing in the European Economic Area, the European Union, Great Britain, or Switzerland has submitted their personal information to us, we will delete it.

Rights Under the CCPA and CPRA

This section of the Privacy Policy applies only to California residents who are natural persons; it does not apply to any entities (whether business, non-profit, or governmental). If you are a California resident, you have the following rights:

1. Right to Know. The right to request, up to two (2) times in a 12-month period, that we identify (1) the categories of Personal Information we have collected about you since January 1, 2022, unless doing so would be impossible, involve disproportionate effort, or you request a specific time period; (2) the categories of sources from which the Personal Information was collected; (3) the business or commercial purpose for collecting, selling, or sharing this information; (4) the categories of third parties with whom we share or have shared your Personal Information; (5) the categories of Personal Information that we have sold or shared about you, and the categories of third parties to whom the Personal Information was sold or shared, by category of Personal Information for each category of third parties to whom the Personal Information was sold or shared; and (6) the categories of Personal Information that we have disclosed about you for a business purpose, and the categories of persons to whom it was disclosed for a business purpose;
2. Right to Access. The right to request, up to two (2) times in a 12-month period, that we disclose to you, free of charge, the specific pieces of Personal Information we have collected about you since January 1, 2022, unless doing so would be impossible, involve disproportionate effort, or unless you request a specific time period;
3. Right to Delete. The right to request, up to two (2) times in a 12-month period, that we delete Personal Information that we collected from you, subject to certain exceptions;
4. Right to Correct. The right to request that we correct inaccurate Personal Information (to the extent such an inaccuracy exists) that we maintain about you;
5. Right to Opt-Out. The right to opt out of the selling or sharing of your Personal Information to third parties;
6. Right to Limit. The right to limit the use or disclosure of your sensitive Personal Information for purposes other than those expressly set forth in this policy;
7. The right to designate an authorized agent to submit one of the above requests on your behalf. See below on designating an authorized agent; and
8. The right not to be discriminated against or retaliated against for exercising any of the above rights, including an applicant’s and independent contractor’s right not to face retaliation for exercising the above rights.

You can submit any of the above types of consumer requests through any of the 3 options below:

1. Submit an email request to privacy@meruelocpra.com.
2. Leave a detailed message on our privacy toll-free line at +1-866-303-0790.
3. Complete a paper form, which can be requested in person at the Company Human Resources Department.

Gramm-Leach-Bliley Act Exemption

Portions of our services may be subject to the Gramm-Leach-Bliley Act. When we are extending credit, or providing financial advice or counseling, those activities are covered by the Gramm-Leach-Bliley Act. The CCPA does not apply to Personal Information to the extent that we collect, process, sell, or disclose it, subject to the Gramm-Leach-Bliley Act. Therefore, certain rights under the CCPA may be limited to the extent such requests to exercise CCPA rights relate to the collection, processing, selling, or disclosure of Personal Information in connection with financial activities covered by the Gramm-Leach-Bliley Act.

How We Will Verify That It Is Really You Submitting the Request

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us. For example, we may need you to provide your name, email, phone number, IP address, browser ID, or the date of your last transaction with the Company.

Responding to Your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests

Upon receiving a verifiable request from a California resident, we will confirm its receipt no later than ten (10) business days after receiving it. We endeavor to respond to a verifiable request within forty-five (45) calendar days of its receipt. If we require more time (up to an additional forty-five (45) calendar days, or ninety (90) calendar days total from the date we receive your request), we will inform you  in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain any reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will explain why we made that decision and provide you with a cost estimate before completing your request.

For a request to correct inaccurate Personal Information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own records if we believe the Personal Information is accurate. You should make a good-faith effort to provide us with all necessary information at the time that you submit the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we will inform you of our decision not to comply and provide an explanation for why we believe the request is fraudulent.

Responding to Your Request to Opt Out of the Selling or Sharing of Your Personal Information

We will act upon a verifiable request to opt out within fifteen (15) days of its receipt. We will notify all third parties to whom we have sold or shared Personal Information of your request and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.

A request to opt out need not be a verifiable consumer request. However, we may deny a request to opt out if we have a good faith, reasonable, and documented belief that a request to is fraudulent. If we deny your request to opt out, we will inform you of our decision not to comply and provide an explanation for why we believe the request is fraudulent.

Responding to Your Request to Limit the Use of Sensitive Personal Information

We will act upon a verifiable request to limit the use of sensitive Personal Information for purposes other than those expressly set forth in this policy within fifteen (15) business days of its receipt. We will notify all third parties that use or disclose sensitive Personal Information of your request to limit and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.

A request to limit need not be a verifiable request. However, we may deny a request to limit if we have a good faith, reasonable, and documented belief that a request to limit is fraudulent. If we deny your request to limit, we shall inform you of our decision not to comply and provide an explanation for why we believe the request is fraudulent.

If You Have an Authorized Agent:

If you are a California resident, you can designate an authorized agent to submit a request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized power of attorney; or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf. We will also contact you and ask you directly for information to verify your own identity, rather than relying solely on your authorized agent.

We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Consent to Terms and Conditions

By using this website, you consent to all terms and conditions expressed in this Privacy Policy.

Changes to Our Privacy Policy

As our services evolve, or as we identify new ways to use the information we collect, we may amend this Privacy Policy from time to time. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made to it. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the updated effective date on this website. Please check back periodically or contact us at the address listed at the end of this Privacy Policy.

Consumers With Disabilities

This policy is provided in a form that is accessible to consumers with disabilities.

Questions About the Policy

This website is owned and operated by Meruelo Group LLC. If you have any questions about this Privacy Policy, please contact us at meruelogroup@meruelocpra.com or call +1-866-303-0790.

**This policy was last updated February 12, 2024.