Privacy Policy

Collecting Data to Improve Your Online Experience

We use the analytics and reporting system, Foureyes® (the “Tool”), provided by our website analytics vendor, Adpearance Holdings, LLC, a Delaware limited liability company.

When used in this Foureyes® Supplemental Notice (“Foureyes Privacy Notice”), “we,” “us,” and “our” may refer to us, *customer name* (“Dealer”), and/or Adpearance, its affiliates or subsidiaries (collectively, “Adpearance”), as applicable. This Foureyes Privacy Notice may be posted or displayed separately on the site or may be appended to another privacy notice or policy posted or displayed on the site (“Additional Privacy Notices”). To the extent an inconsistency or conflict arises between the terms of this Foureyes Privacy Notice and any Additional Privacy Notices, the terms of this Foureyes Privacy Notice will control with respect to the Tool. However, this Foureyes Privacy Notice applies only with respect to the Tool, and not any other features or functions of the site.

This Foureyes Privacy Notice describes how the Tool works when you visit this site, and how it collects, uses, and discloses your personal information. Please read this Foureyes Privacy Notice carefully. We may also update or modify this Foureyes Privacy Notice at any time by posting it to this site. Please refer to “Effective Date and Modifications” below for the effective date of this Foureyes Privacy Notice.

By using this site or our phone system, you consent to the collection, use and disclosure of your personal information as described herein. If you do not consent, you may opt-out of the use of the Tool (as set out below). You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below.

How the Tool Works. For each visit to the site, the Tool: (1) identifies the traffic source for the visit; and (2) issues a unique visitor ID number and visitor traffic number. As the user navigates the site, the Tool may track and store the pages visited and features used. The Tool also may collect and link information provided through forms featured on the site or during phone calls with a visitor ID number. Using local storage, the Tool may also store data in the user's Internet browser or in a data repository on the user's device for purposes of associating the user with his or her user profile. The Tool operates only on the site and our phone system – it does not track information regarding your use of other sites or activities on other sites.

Purpose of Collection. Using the Tool, we collect personal information for purposes related to managing, marketing and developing our businesses as further described herein and including:

  • establishing and managing business relations with you;
  • providing us with information in order to allow us to analyze usage of the site, improve the site, the Tool, and for development of new services and products;
  • marketing products and services to you; and
  • for other purposes related to the management of our relationship.

Adpearance further collects personal information for purposes of operating and administering the Tool for subscribers of the Tool, such as the Dealer and other third parties.

Information Collected and Usage of Information. The Tool creates a user profile including the user's visitor ID number and any information the user directly provides through the site or other interactions with the site and/or the company associated with the site (e.g., phone calls and chats). This information may include a user's personal information, such as name, personal phone number, home address, email address, and similar information, whether or not this information is complete or partially entered by the user. We will not ask for or knowingly associate financial information with your user profile. Unless the user provides us personal information, the information we collect using the Tool and which is associated with the user profile is limited to information automatically collected as a user browses and interacts with the site, such as the user's browser type, available plugins, Internet service provider, Internet protocol (“IP”) address and/or mobile device ID, and pages visited, features used, and activities performed on the site. Except as otherwise expressly set forth herein, the information collected and associated with a user profile is used, maintained and disclosed in accordance with the restrictions, consents, and permissions in this Foureyes Privacy Notice and any Additional Privacy Notices (if any), including obligations of confidentiality and restrictions on disclosure to third parties.

You expressly acknowledge and agree that the information associated with your user profile may be used to understand and analyze the usage of the site, and for the purposes of marketing products or services to you. In particular, where it is lawful to do so (please see additional note below on Canada’s Anti-Spam Legislation), the Tool may automatically generate and send email marketing communications to you (to the extent you have provided your email address as part of your interactions with the site and/or the company associated with the site). The content of those email marketing communications may be based on the pages that you have visited and/or the features you have used on the site. To opt-out of receiving the email marketing communications generated by the Tool, please see the Opt-Out instructions below.

Third Party Disclosure. Unless required or permitted by law, the information associated with your user profile will not be used or disclosed to third parties other than for the purpose for which it was collected, without the user’s prior consent.

For purposes of clarity and in addition to any disclosure to third parties described in any Additional Privacy Notice, the information collected by the Tool and/or associated with your user profile may be disclosed by Adpearance to the following category of third parties or as otherwise authorized or required by law:

(i) OEMs: Adpearance partners with various automotive manufacturers (“OEMs”) as a part of their respective certified marketing programs and their affiliates.

(ii) Third Parties Adpearance is party to certain agreements with third parties with whom it conducts business regarding the Tool and/or the information collected by the Tool and/or associated with your user profile. Adpearance may disclose your personal information to such third parties who may provide services that facilitate the operation of the Tool, assist us in providing an improved customer experience to you, or assist us in providing improved services to Adpearance’s customers.

Blocking and/or Disabling the Tool. The Tool gathers information about the user's computer hardware and software configurations to identify the user each visit and associate the user with their existing user profile. Unlike a “cookie”, and except for local storage discussed below, the system does not store a file on the user's computer; therefore, the user information gathered is not deleted when the user clears their cache and/or deletes their cookies. In order to disable the tool, see the Opt-Out instructions below.

Opt-Out. The Tool’s opt-out functionality is cookie based, so for it to work for you, your browser must allow third party cookies. If you change computers or browsers or delete this cookie, we will no longer know you have opted out, so you will need to opt-out again. To opt out, Click Here. Note that opting out of cookies on the Dealer’s site will not be an opt out with respect to the Tool.

You may also opt-out of, or withdraw your consent to (where the Canadian Anti-Spam Legislation applies) receiving email marketing communications generated by the Tool by sending a request to [email protected], or by clicking the unsubscribe link on any such email marketing communication you receive. Please note that clicking the unsubscribe link may only result in your no longer receiving marketing communications generated by the Tool; you may still receive other email marketing communications from the Dealer. If you opt out or withdraw consent with the Dealer or on the Dealer’s site, you will still also need to opt-out or withdraw your consent regarding the Tool as set out in this paragraph.

As noted above, the Tool may also collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches. Browser web storage enables websites to store data in a browser on a device. When used in “local storage” mode, it enables data to be stored across sessions. Similarly, an application data cache is a data repository on a device. You may stop local storage from being used by modifying your Internet browser settings, but stopping local storage may result in the site having impaired or limited functionality. Furthermore, disabling local storage will not block the Tool from operating; rather, it will only prevent the Tool from collecting and storing information locally on your device. To disable the Tool, see the Opt-Out instructions above. Further, you should refer to the help provided by your Internet browser for the most up-to date and accurate instructions on disabling local storage.

Do Not Track Signals. IF YOU DO NOT WANT THE TOOL TO GATHER INFORMATION ABOUT YOUR USER PROFILE AND SITE VISIT, NOW AND FOR FUTURE BROWSING SESSIONS, PLEASE REFER TO THE OPT-OUT PROCEDURES ABOVE /OR REFRAIN FROM USING THE SITE. WE DO NOT CURRENTLY RESPOND TO DO NOT TRACK (DNT) SIGNALS.

Accessing, Correcting, Updating Your Personal Information. You have a right to know what personal information we have about you and correct any inaccuracies. To review your information that is collected using the Tool, contact Adpearance by email at [email protected], or by regular mail addressed to Adpearance Holdings, LLC, 2035 NW Front Street #300, Portland, OR 97209.

Data Retention. We keep information associated with your user profile for as long as we think is necessary or advisable to fulfill the purposes for which it was collected, and we reserve the right to retain it to the full extent permitted by law. If required by law, a governmental order, or similar legal process, we will disclose your information.

Children. The site is intended for adults who have reached the age of majority in their state, province or territory of residence. The site is not directed at children under age 16. We do not knowingly collect personal information from children under age 16, and if we learn that the Tool has collected information of a child under age 16, we will delete the information.

Canada’s Anti-Spam Legislation. We are committed to complying with Canada’s Anti-Spam Legislation and will only send you email marketing communications (or other commercial electronic messages, as defined in Canada’s Anti-Spam Legislation) where it is lawful to do so. If you have consented to receiving marketing materials from us, you can withdraw your consent to receiving email marketing communications generated by the Tool by sending a request to [email protected], or by clicking the unsubscribe link on any such email marketing communication you receive. Please note that clicking the unsubscribe link may only result in your no longer receiving marketing communications generated by the Tool; you may still receive other email marketing communications from the company associated with the site.

European Union Privacy. If the processing of your information in connection with the Tool is subject to the General Data Protection Regulation 2016/679 (“GDPR”), we have additional obligations and you have additional rights under the GDPR. These rights and obligations are as follows:

We will process your personal information using the Tool in order to support our provision of services in connection with your use of the site. The lawful bases for processing your personal information may include:

  • When you have given consent;
  • When processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
  • When processing is necessary to protect Adpearance’s or our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights;
  • When processing is necessary for compliance with a legal obligation to which we or Adpearance are subject; and
  • When processing is necessary to protect the vital interests of the data subject or of another natural person.

You have many rights with respect to our processing of your personal information. Depending upon the lawful basis of processing, you may have the right to withdraw consent or object to our processing your personal information.

You have the right to be informed about your personal information and how it is being processed, to access, correct and erase personal information, to restrict further processing, to obtain and reuse your data for your own purposes across different services and to object to our processing. You also have the right to lodge a complaint with the relevant EU supervisory authority.

If we transfer your personal information to a recipient in a country outside the European Economic Area, we will do so in compliance with applicable laws with respect to such transfer.

Storage in the United States. The Tool is operated and controlled from offices in the United States. If you access the site from locations outside the United States, you do so at your own risk and are responsible for compliance with applicable local laws. Your access to the site constitutes your agreement to our storage of your personal information within the United States. You understand that your personal information may be stored and/or processed in the United States, notably at the address indicated above, that it may be subject to the laws of the United States and that it may be accessible to tribunals, courts, law enforcement and regulatory agencies in the United States.

Effective Date and Modifications. This Foureyes Privacy Notice is effective on March 22, 2022. We review this Foureyes Privacy Notice at least annually and may amend it from time to time. Except as otherwise required by applicable law, our only notification will consist of posting a new policy.

Supplemental California Privacy Information. We are required by law to provide California residents with certain additional information about their privacy rights under the California Consumer Privacy Act. This information is available at the following link: foureyes.io/privacy-policy/ccpa-privacy-addendum.

Contacting Us. If you have any questions, complaints, or comments about this Foureyes Privacy Notice, your information, our third-party disclosure practices or your consent choices in connection with the use of the Tool, please contact Adpearance’s privacy officer at [email protected]