Privacy Policy

SmartTech Enterprises Privacy Policy

This SmartTech Privacy Policy discloses our privacy practices for Personal Information (as defined in this Privacy Policy) collected from our website 4loyalty.com (the “Website”) and from our Automotive Retailer clients and their data management service providers. The Automotive Retailers may have links to this Policy on their websites.

We act as a service provider for our Automotive Retailer clients. In connection with the services we provide to our clients, we receive Personal Information from our clients either through direct connection with them or from their data management system. We disclose the Personal Information to our clients’ mail house vendors and to our clients to assist them in communicating with you and to create your customer rewards portal.  Our Automotive Retailer clients may have their own privacy policies.

SmartTech is not responsible for the privacy or security practices of our Automotive Retailer clients or mail house vendors, which may differ from those set forth in this privacy policy. Please check with individual Automotive Retailers about the policies they have in place.

Types of Information Collected. “Personal Information” collected by SmartTech includes:

  • your first and last name;
  • billing or shipping address;
  • email address;
  • phone number;
  • Vehicle sale information (Retail or Lease) and service history
  • Vehicle Identification Number

Use of Information

SmartTech discloses Personal Information we collect to our Automotive Retailer clients and their mail house vendors to assist them in communicating with you and to create your customer rewards portal.

We may also use the Personal Information we collect about you to generate deidentified, aggregated data. When we do so, we ensure that the deidentified, aggregated data is no longer personally identifiable and may not later be used to identify you.

We may also disclose your Personal Information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Security.  We take what we consider to be appropriate technical and organizational controls and measures to secure and protect your Personal Information from unauthorized or unlawful processing and against accidental loss or destruction. These include strong user access controls, segmented network architecture and comprehensive employee policies and training. It is a priority of SmartTech to ensure all Personal Information is protected and secured to the highest level.

We cannot ensure or warrant that Personal Information will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to Personal Information. The computers/servers in which we store Personal Information are kept in a secure environment.

Links This Website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Children Under the Age of 16

No one under age 16 may provide any Personal Information on the Website or to our Automotive Retailer clients.

Notice to European Users

This Website and the services provided by us to our Automotive Retailer clients are targeted for users in the United States of America. Any information you enter on this Website or provide to our Automotive Retailer clients may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union.

Updates Our Privacy Policy may change from time to time and all updates will be posted on this page. If you feel that we are not abiding by this Privacy Policy, you should contact us immediately via telephone at 866-456-9258 or via our Website.

Last updated November 23, 2020.

PRIVACY STATEMENT-CALIFORNIA 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of SmartTech Enterprises, LLC and applies solely to users and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

We act as a service provider for our Automotive Retailer clients. In connection with the services we provide to our clients, we receive personal information from our clients (either through direct connection with them or from their data management system). We disclose the personal information to our clients’ mail house vendors and to our clients to assist them in communicating with you or to create your customer rewards portal with our clients.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Information Collected by Us

A. Identifiers.

your first and last name;

billing or shipping address;

cookies;

email address;

phone number.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

your first and last name;

billing or shipping address;

email address;

phone number.

C. Commercial information.

Vehicle sale information (Retail or Lease) and service history

Vehicle Identification Number

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our Automotive Retailer clients or their data management services.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided.
  • To provide your contact information to our Automotive Retailer clients and their mail house vendors to enable them to send you mail and emails with information about the Automotive Retailers’ alerts, event registrations and other notices concerning their products and services.
  • To set up a portal for you to access our Automotive Retailer clients and activate rewards.
  • To provide you with information, products or services that you request from our Automotive Retailer clients.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Cookies. We use "cookies" on our Website. A cookie is a piece of data stored on a site visitor's hard drive. We may use cookies to monitor and collect information about how you access, use, and interact with the Website. Cookies can also enable us to track and target the interests of our users to enhance the experience on our Website. Usage of a cookie is in no way linked to any personally identifiable information on our site. If you do not want to be tracked by Google Analytics you may opt-out using Google's official opt-out browser add-on

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to our Automotive Retailer clients and their mail house vendors for a business purpose.  When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. As a service provider to our clients, we agree to the same confidentiality obligations.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:             Identifiers.
Category B:             California Customer Records personal information categories.
Category C:             Commercial Information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our Automotive Retailer clients.
  • Mail house vendors supplying mail house services for our Automotive Retailer clients.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of personal information about you that we disclosed for a business purpose.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or disclosing that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Opt-Out Rights

The CCPA provides you the right to opt-out of having your personal information sold by a business. We do not sell personal information to third parties.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of the Automotive Retailer’s ongoing business relationship with you, or otherwise perform the Automotive Retailer’s contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or our Automotive Retailer clients.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Your access and deletion rights under this Policy apply only to personal information we collect. Your access and deletion rights for personal information collected by our Automotive Retailer clients will be covered by their own privacy policies.

You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. .  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

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

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage. We will update this privacy notice at least once every 12 months.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 866-456-9258

Website: 4loyalty.com

Address: SmartTech Enterprises, LLC

                256 Eagleview Blvd. PMB 511

                Exton, PA 19341

If you have any questions or comments about the ways in which our Automotive Retailer clients collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact your Automotive Dealer directly.