I. Consent and Mobile Platform Permissions
II. Our Collection of Information
We collect “Personal Information” and “Non-Personal Information.”
Personal Information is information that can be used to personally identify you, for example your name, phone number, and e-mail address.
Non-Personal Information is information that cannot be used to personally identify you, for example, anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.
We collect Personal and Non-Personal Information from you at several different points, including but not limited to the following:
- when you register with us;
- when you visit our websites;
- when you communicate with our concierge;
- when you use our apps; and
- when you contact us for help.
Under the California Consumer Privacy Act (“CCPA”) we have collected the following categories of personal information from California consumers within the last twelve (12) months:
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
K. Inferences drawn from other personal information.
We obtain the categories of personal information listed above from the following categories of sources:
• Directly or indirectly from you;
• From activity on our website, apps, marketing campaigns or social networking sites; and
• Service providers and other partners.
III. How we Use and Share your Information
We may use Personal Information that we collect about you to:
- deliver the products and services that you have requested;
- schedule appointments with dealers (if applicable);
- match you with a real estate agent (if applicable);
- manage your customer relationship and provide you with customer support;
- perform analysis about your use of the Services;
- communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you;
- enforce our terms and conditions;
- manage our business;
- respond to investigation, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, or as otherwise required by law; and
- perform functions as otherwise described to you at the time of collection.
We may, and you authorize us to, transfer your Personal Information to any of our affiliates for the purpose of processing or storage. Additionally, we may, and you authorize us to transfer your Personal Information to the extent that:
- We have your written consent.
- Transfer is done in connection with a business transaction, such as a merger, acquisition, or liquidation of Vast.com, Inc.
- We believe, in our own sole discretion, that transfer is necessary to limit our liability or protect and defend the rights, property or personal safety of our Company, its affiliated companies, this Website or its users or to investigate violations of our agreements or Company policies.
- Transfer is required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to our Company.
The CCPA requires that we disclose if personal information of California consumers was shared or sold in the last 12 months. We disclosed the personal information of California consumers for a business or commercial purpose to the following categories:
• Affiliated companies, service providers and other vendors.
• Third parties and other partners to whom you or your agents authorize us to disclose your personal information in connection with products or services.
The CCPA does not consider disclosure of personal information a “sale” if it occurs pursuant to a consumer’s request or direction. We structure transactions where we collect and disclose your personal information involving a commercial purpose to fall within this exemption.
IV. Our Retention of your Information
We will retain any Personal Information and Non-Personal Information only for as long as is necessary to fulfill the business purpose it was collected. We will also retain and use any Personal Information and Non-Personal Information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
V. How we Protect your Personal Information
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Services, you acknowledge that you understand and agree to assume these risks.
VI. Your Rights and Choices Regarding your Personal Information
If your Personal Information changes, or if you no longer desire to use the Services, you can correct, update, or delete inaccuracies by making the change within your profile settings section of the app or by contacting us at email@example.com.
Reasonable access to your Personal Information may be provided at no cost upon request made to firstname.lastname@example.org. If access cannot be provided within the time frame requested, our Company will provide the requesting party a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied.
Location Information and Notifications
If applicable, you can turn off and on location information within your profile settings section of the app. If you wish to stop receiving notifications through the app, you may change the settings for the app and/or your device.
Because of the nature of our business, our Services is not designed to appeal to children under 13 years of age. We do not knowingly attempt to solicit or receive any information from children.
Your California Privacy Rights
Disabled consumers who need these disclosures presented in an alternate medium, may contact us at the email address listed below.
Our Company does not currently respond to browser “Do Not Track” (DNT) signals or other mechanisms. Third parties may collect Personal Information about your online activities over time and across websites when you visit our website or use our Services.
If you are a California resident, California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of Personal Information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us by sending an e-mail to email@example.com.
If you are a California resident under the age of 18, and a registered user of any website where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content or information to firstname.lastname@example.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Do Not Sell My Personal Information: Under the CCPA, California residents may opt out of the sale of personal information. Please visit the Do Not Sell My Personal Information Opt-Out page to exercise your right.
Right to Know and Deletion Requests: You may request that our Company disclose certain information to you about the collection and use of your personal information, under the CCPA or other applicable law. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information collected about you.
• The categories of sources for the personal information collected about you.
• The business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom the personal information is shared.
• The specific pieces of personal information collected about you, in a portable format.
You may also request that any of your personal information is deleted, subject to certain exceptions. Once our Company receives and confirms your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records. We may deny your deletion request in whole or in part if retaining the information is necessary for our Company or our service providers to retain under an exception provided for by the CCPA.
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us through the contact information below.
- Cookies. In an effort to improve the quality of the Services, we track information provided to us by your browser or by our software application when you view or use the Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Services, the time and date of access, and other information that does not personally identify you.
The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. For example, we store a persistent cookie to track the following: information you provide us by registering for an account, and information you provide us by signing up for Market Reports.
You have many choices with regards to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. Before taking such steps, you should be aware that the Services may not work properly if you choose to block the placement of cookies on your computer. You will need to decide whether enabling cookies outweigh privacy concerns. To learn more about your ability to manage cookies, please consult the privacy features in your browser.
- Web Beacons. Our Company and third parties may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. These “web beacons” may be used to deliver cookies that conform to our Company’s cookie requirements.
- Analytics Services. We use the following third-party data analytics platforms to improve our Services:
- Google Analytics. We use Google Analytics to help understand how visitors interact with our websites so that the websites can be improved. You can read Google’s security and privacy policies for Google Analytics. You can chose not to have your data used by Google Analytics by downloading Google’s opt-out browser add-on.
- Facebook Analytics. We use Facebook measuring tools to improve our advertising and measurement systems. You can view Facebook’s Data Policy athttps://www.facebook.com/privacy/explanation.
- App Annie.
- Other. Our Company sites may use third parties to present or serve the advertisements that you may see at its web pages and to conduct research about the advertisements and web usage. This Privacy Statement does not cover any use of information that such third parties may have collected from you or the methods used by the third parties to collect that information.
This document was last updated on March 20, 2020