VIRTUAL F&I™

California Privacy Policy

NOTICE TO CALIFORNIA RESIDENTS

This following applies to certain California residents and supplements (but does not replace) the Privacy Policy above. This does not apply to the following information:

Information about individuals who are not California residents.
Information about our own employees, contractors, agents, and job applicants.
Information we collect from individuals with whom we engage in solely business-to-business communications and transactions, including due diligence transactions, such as information about the employees of our business clients.

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with the right to request that we disclose certain information to you about its collection, use, disclosure and sale of your personal information over the past 12 months, and your right to request that we delete any of your personal information that we have collected from you, subject to certain exceptions.

To exercise these access and deletion requests, please email us at privacy@virtualfi.com with “California Privacy Rights” in the subject line. Your request must contain sufficient detail to allow us to understand, evaluate and respond to it. Virtual F&I is only required to respond to two such requests per customer each year. In order to verify your identity to honor these requests, we may require your name, contract number, home address, email address and telephone number.

Below you will find an explanation of the ways in which we may share your information with third parties, including our business partners and service providers, such as identifiers, commercial information, and information about your use of the Services. Some of this sharing may be considered a “sale” under the CCPA. California residents have the right to opt out of the sale of their personal information. To do so, please email us at privacy@virtualfi.com with “California Privacy Rights” in the subject line. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

You may designate an authorized agent to make a request under this section on your behalf. To do so, please submit a written form signed by you and your authorized agent that authorizes your agent to act on your behalf, such as a power of attorney. Virtual F&I will not discriminate against you for exercising your rights under the CCPA.

California residents also have the right to correct information we hold about you. If you would like to correct the personal information, you may do so by visiting your Virtual F&I.com account.

Below is a summary of the personal information we may collect from consumers, the parties with whom we may have shared personal information for business purposes in the previous 12 months and the parties to whom we may have sold personal information in the previous 12 months.

CATEGORIES OF PERSONAL INFORMATION WE MAY COLLECT	CATEGORIES OF THIRD PARTIES WITH WHOM WE MAY DISCLOSE PERSONAL INFORMATION FOR A BUSINESS PURPOSES	CATEGORIES OF THIRD PARTIES WITH WHOM WE MAY SELL PERSONAL INFORMATION
Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Third party social network services • Our parents, subsidiaries, and affiliates • Marketing and advertising partners or providers • Public or law enforcement officials, as well as private parties involved in other legal process • Consumer credit reporting companies • Companies or other users to whom your data is shared at your direction • Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Entities involved in a corporate transaction	• Third party social network services • Data analytics providers • Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Companies that create or receive sales leads
Characteristics of protected classifications under California or Federal Law, such as age, sex (including gender, gender identity, gender expression), citizenship, religion or creed, marital status, medical condition, pregnancy or childbirth, veteran or military status.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Our parents, subsidiaries, and affiliates • Marketing and advertising partners or providers • Public or law enforcement officials, as well as private parties involved in other legal process • Consumer credit reporting companies • Companies or other users to whom your data is shared at your direction • Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Entities involved in a corporate transaction	• Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Companies that create or receive sales leads
Commercial information, including records of personal property, product or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Third party social network services • Our parents, subsidiaries, and affiliates • Marketing and advertising partners or providers • Public or law enforcement officials, as well as private parties involved in other legal process • Consumer credit reporting companies • Companies or other users to whom your data is shared at your direction • Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Entities involved in a corporate transaction	• Third party social network services • Data analytics providers • Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Companies that create or receive sales leads
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Third party social network services • Our parents, subsidiaries, and affiliates • Marketing and advertising partners or providers • Public or law enforcement officials, as well as private parties involved in other legal process • Companies or other users to whom your data is shared at your direction • Entities involved in a corporate transaction	• Third party social network services • Data analytics providers
Geolocation data, such as approximate location of a Device or equipment based on geographical coordinates and measurements.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Our parents, subsidiaries, and affiliates • Marketing and advertising partners or providers • Public or law enforcement officials, as well as private parties involved in other legal process • Companies or other users to whom your data is shared at your direction • Supplemental product providers, such as those who offer vehicle accessories, insurance, etc. • Entities involved in a corporate transaction	• Data analytics providers
Audio, electronic, visual, thermal, olfactory, or similar information such as CCTV footage, call recordings, web activity recordings, etc.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Our parents, subsidiaries, and affiliates • Marketing and advertising partners or providers • Public or law enforcement officials, as well as private parties involved in other legal process • Companies or other users to whom your data is shared at your direction • Entities involved in a corporate transaction	• Data analytics providers
Professional, employment, or education information, such as job title, employer, business address and contact information, employment history, other professional information, or education history.	• Service providers, such as identity verification services, financial services, technical support, research and analytics providers, etc. • Our parents, subsidiaries, and affiliates • Public or law enforcement officials, as well as private parties involved in other legal process • Consumer credit reporting companies • Companies or other users to whom your data is shared at your direction • Entities involved in a corporate transaction	• Data analytics providers

Collection of the categories of personal information identified above may occur through one or more of the following sources:

From you, when you engage in certain activities such as: registering and/or setting up an account/profile to access our website, mobile application, or related platforms and/or Service(s), and navigating and/or utilizing our website, mobile application, and/or related Service(s).
From third party social networking service(s) that you may have accessed, visited, and/or used that may be integrated with or linked to the Service(s).
From lead generation partners or sources.
From identity verification partners.
From entities that sell or share your personal information, including entities registered in California as data brokers.
From service providers who gather personal information from you or external parties who possess and/or process your personal information, once you grant the requisite right, power, and/or authority to those service providers to act on your behalf and gather and/or provide such data to us.
Through local device storage (placing and/or storing code or other types of information and/or devices (e.g., “cookies”) on your Device(s)) or Tracking Technologies (web beacons, web bugs, clear gifs, and similar technologies).

The business and/or or commercial purpose(s) for which we collect the data identified above may include one or more of the following:

Auditing, such as auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
Debugging, such as debugging to identify and repair errors that impair existing intended functionality;
The occurrence of mergers and acquisitions, including in the event Virtual F&I undergoes a corporate reorganization such as a merger, acquisition, sale of part or all of its business, or other related event, in which data may be collected, used, or shared for the purpose of negotiating or completing such transactions;
Performing or improving services, such as maintaining or servicing accounts, providing customer service, facilitating communications between users, providing consumers with requested or personalized content, communicating with you about new features, products, or services, processing or fulfilling orders and transactions, tailoring the services that we offer to your needs; verifying your information, processing payments, providing financing, providing analytic services, or providing similar services on behalf of Virtual F&I;
Quality assurance, including undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Virtual F&I, and to improve, upgrade, or enhance the Service or a device that is owned, manufactured, manufactured for, or controlled by Virtual F&I;
Security, such as detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and/or prosecuting those responsible for that activity;
Short-term, transient use;
To communicate, advertise, and/or market our goods, products, and/or services, to show you content and sponsored messaging, to engage in interest-based advertising, to gauge the effectiveness of marketing campaigns, and/or for other marketing or advertising purposes;
To comply with legal or compliance requirements, such as compliance training, investigating and responding to legal claims, responding to law enforcement requests, or as otherwise required by law;
To conduct internal research, including undertaking internal research for technological development and/or demonstration and analyzing trends;
To help diagnose problems with our servers, to gather broad demographic information, track users’ movements around the Service, and/or to otherwise administer the Service; and/or
To track geographic location, usage patterns, broad demographic information, and/or the movements of individual users.

Virtual F&I™, Inc.
199 Pomeroy Road
Suite 101
Parsippany, New Jersey 07054
Phone: (800)934-5148
Email: privacy@virtualfi.com