This statement is effective as of June 16, 2022.
Thank you for your interest in Manheim, a Cox Automotive, Inc. business. When we refer to Manheim within this Privacy Statement, we are referring to Manheim Remarketing, Inc. and its various subsidiaries and affiliates, including the various Manheim auto auctions, and others (collectively, "Manheim," "we," "our," or "us"). We respect the privacy of our users when they use our websites, mobile and other online applications and products and services at Manheim.com, Online Vehicle Exchange, L.L.C., Manheim Express, and Manheim Private Stores (collectively, the “Sites”). By using the Sites, you consent to the use of your information and information about you in accordance with this Privacy Statement. If you do not agree, do not access the Service.
This Privacy Statement applies to information collected through the Sites and does not describe the collection, use and disclosure practices of any of our corporate affiliates or third parties. The Sites utilize information from corporate affiliates, third parties, and publicly available vehicle information. Private stores also use information provided by the seller or franchisor. For information on the collection, use and disclosure practices of any company with whom you are doing business, whether or not affiliated with Manheim, please review their privacy policies.
Manheim is a business-to-business provider of auction and vehicle remarketing services to buyers and sellers of vehicles at wholesale and to their duly authorized agents and representatives. Our Service is not intended for consumers, except as outlined below regarding the Next Inspect service for consumers. Services offered by the Sites are not directed to individuals under the age of eighteen (18). If you are under eighteen (18), you should not provide any personal information to us.
This Privacy Statement covers:
Information is gathered from the Sites by us, our service providers, advertisers, sponsors and partners.
Information You Provide. We may collect information that you choose to provide on the Site (which may include your name, address, telephone number, email address, dealer or company name, AuctionACCESS number(s), the last four digits of your social security number or other valid government-issued identification number and bank account, payment and other financial information) in a variety of ways, such as when you:
Automated Information. Information regarding your use of the Sites may be collected and/or aggregated through the use of automated means. This automatically collected information may include information such as:
Data Technologies. Various technologies are used to automatically collect information, such as cookies, local shared objects, and web beacons (generally referred to as “Data Technologies.”) “Cookies” are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. “Local shared objects,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies. Anonymous advertising identifiers are increasingly being used on mobile devices and otherwise in a manner similar to cookies. When we refer to Data Technologies, we are including all current and similar future technologies.
One or more Data Technologies may be used on the Sites and other websites and mobile applications (that may not be the Sites) by us, by another party on our behalf, or by third parties in accordance with their privacy policies. Data Technologies may be used by us and others, on our behalf and on their own behalf, to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications.
We may use a uniquely generated trackable toll-free telephone number on the Sites or in advertisements. If you call one of these uniquely generated toll-free numbers, we (or a service provider acting on our behalf) may collect non-personally identifiable information about the call (e.g. date, time, duration), as well as personally identifiable information (e.g. your name, the number from which your call originated).
Videos. We may target and track the videos you view on the Sites. You consent to our tracking of your video viewing through the Site or third-party social media for up to two years or as permitted by applicable law.
Location Information. We may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“Location Information”). We only collect Location Information with your permission (e.g., such as when you agree to provide it to us after initial access to or downloading our website). We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as advertising, search results, auctions in the area, and directions.
Publicly Posted Information. Information that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms or similar functionality is public information that we or others may share or use in accordance with the law.
Combined Information and Information from Other Sources. We may combine information that you provide to us with information we receive from our affiliates and other sources, as well as with other information that is automatically collected. The combined information may include information about your use of the Sites, your use of other websites, devices and mobile applications and information from our affiliates and other sources.
We may use information we collect for the following purposes:
Applications, Widgets and Social Media
We may include applications or widgets from social media providers that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Sites and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.
Advertising Networks
Advertising that is customized based on predictions generated over time from your visits across different websites, devices and mobile applications is sometimes called "online behavioral" or "interest-based" advertising. We may partner with advertising networks, which are companies that deliver targeted advertisements to consumers and generate statistics and metrics related to the delivery of interest-based advertisements. They may utilize information collected through a variety of Data Technologies to provide customization, auditing, research and reporting for us, our affiliates and other advertisers. This data collection takes place both on the Sites and on third-party’s websites and mobile applications. This process allows the Sites and third parties to deliver targeted advertising, enhance marketing programs and help track the effectiveness of such efforts. Our advertising networks also may use this information for determining or predicting the characteristics and preferences of their respective advertising audiences and measuring the effectiveness of their advertising in accordance with their privacy policies.
We do not provide information that is directly associated with a specific person (such as name and address) to an advertising network when you interact with or view a customized advertisement. However, when you view or interact with an advertisement, the advertiser may make an assumption that you are interested in the subject matter of the advertisement.
Some companies disclose when they are using interest-based advertising programs on the Sites to deliver third-party ads or collecting information about your visit for these purposes and give you the ability to opt-out of this use of your information. You may see an icon in or around third-party advertisements on the Sites that use interest-based advertising programs and on pages where data is collected and used for online interest-based advertising. Clicking on this icon will provide additional information about the companies and data practices that were used to deliver the ad. You can opt out of delivery of targeted advertising to you by multiple companies by visiting www.aboutads.info/choices, www.networkadvertising.org/managing/opt_out.asp and www.ghosteryenterprise.com. Please note that even if you opt out, you will continue to receive advertisements, but they will not be tailored to your specific interests.
Information We Share
We do not sell or otherwise share information about you that we collect or receive, except as described below:
Thank you for your interest in Next InspectTM. When we refer to Next Inspect within this Privacy Statement, we are referring to the Next Inspect website, mobile site, mobile application, and/or associated user tools (the “Tools”) (collectively, “Next Inspect”, the “Application”, or the “App”). We respect the privacy of our users when they use the App. By using the App, you consent to the use of your information and information about you in accordance with this Privacy Statement. If you do not agree, do not access the App.
This Privacy Statement applies to information collected through the App and does not describe the collection, use and disclosure practices of any of our corporate affiliates or third parties. For information on the collection, use and disclosure practices of any company with whom you are doing business, whether or not affiliated with us, please review their privacy policies.
Next Inspect is an App that helps you create a vehicle condition report. You can use the App to:
A. VIN Scan. Scan the VIN to receive vehicle information from the VIN decode, namely, the year, make, model and trim of the vehicle.
B. Disclosures: Respond to the questionnaire in the “Questions and Announcements” section to provide information about the vehicle and condition to inform the condition report and condition grading.
C. 360 Images: 360 Images allows you to generate 360-degree images from static images of a vehicle for use in connection with the condition report.
D. Condition Report: Based on the information provided through the Tools in A-C above, the Application will generate a condition report and condition grade for the vehicle.
Services offered by the App are not directed to individuals under the age of eighteen (18). If you are under eighteen (18), you should not provide any personal information to us.
What We Collect
Information You Provide. We may collect information that you choose to provide on the App in connection with your vehicle (which may include your name, email address, account number associated with your leased vehicle, dealer-provided information, photographs and accompanying metadata, license plate number, and other vehicle information) in a variety of ways when you register and/or log into the App.
Automated Information. Information regarding your use of the App may be collected and/or aggregated using automated means. This automatically collected information may include information such as: your browser type, device identifier, IP address, and operating system; sites you visited before and after visiting the App; information about your location; pages you view and links you click within the App; and other information about your interactions with the App. This Usage Information does not identify you by name.
How We Use the Information We Collect
We may use information we collect for the following purposes: to provide your vehicle information report and other information to third parties directly involved with your vehicle lease; for everyday business purposes to create or enhance existing products within the Cox Automotive companies; to address technical and service problems; to perform data analyses; to comply with applicable legal requirements and our policies; and to contact you, including, but not limited to, by displaying notifications to you through the App. Certain vehicle lessors may further limit our ability to use this information.
Information We Share
We do not sell or otherwise share information about you that we collect or receive, except as described below:
You are entitled to make certain choices about how we communicate with you.
We may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.
The Sites may contain links to websites not operated by us, as well as third party widgets and applications discussed above. Once you leave the Sites, we suggest that you review the applicable privacy policy of the third-party website or application. We are not responsible for the content or use of any websites or applications other than on the Sites or the privacy practices of those websites or applications.
We use commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard information about you in our possession against loss, theft and unauthorized use, disclosure or modification. Of course, despite these measures, we cannot guarantee perfect security of networks, servers and databases we operate or that are operated on our behalf.
If you choose to visit the Sites, your visit and any dispute regarding privacy is subject to this Privacy Statement and the Visitor Agreement or Terms of Use applicable to each Site, including limitations of liability, arbitration and dispute resolution provisions and provisions relating to governing law or jurisdiction or venue that may be included in any of the foregoing.
We may update this Privacy Statement to provide clarification or notice of changes to our practices. We will provide you with notice of material changes by posting notice of the changes on the Site, or by providing you with notice by email or when you log into your account on the Site. By using our Sites on or after the effective date of any such amendment, you agree that your use, and any dispute over privacy, is governed by this Privacy Statement, as amended.
If you have any questions or comments about this Privacy Statement, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@coxautoinc.com.
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This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Manheim Remarketing, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”), a Cox Automotive, Inc. company, and applies solely to consumers 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.
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 an individual consumer, household, or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
YES |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
YES |
|
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
NO |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
|
E. Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
YES |
|
G. Geolocation data. |
Physical location or movements. |
YES |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
NO |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
NO |
|
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)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
NO |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
YES |
We obtain the categories of personal information listed above from the following categories of sources:
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have sold the following categories of personal information:
Your Rights and Choices
The CCPA provides 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 and Data Portability 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:
California Civil Code Section 1798.83 entitles California users to request information concerning whether a business has disclosed certain information about you to any third parties for the third parties’ direct marketing purposes. California users who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How to Contact Us” section below.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected about you and retained, subject to certain exceptions in the CCPA. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies, and we will direct our service providers to similarly delete your personal information from their records.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a “verifiable consumer request” (defined below) to us by either:
Only you or someone you authorized 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.
A verifiable consumer request must:
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
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.
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, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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:
Email: privacy@coxautoinc.com
Postal Address: Cox Automotive, Inc.
Attn: Scott Hilsen, Chief Compliance & Privacy Officer
6205 Peachtree Dunwoody Rd. NE
Atlanta, Ga 30328