California Consumer Privacy Act (“CCPA”)
This section only applies to individual residents of California. The California Consumer Privacy Act (“CCPA”) gives California residents certain rights. This section covers our Collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA.
Capitalized terms defined in the CCPA that are used in this section shall have the same meaning as in the CCPA.
Collection, Use and Disclosure of Personal Information
Generally, we Collect, retain, use, and disclose your PI to provide you the CT Services and as otherwise related to the operation of our business. In addition, we may Collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this section.
Information We Collect and Disclose
such as name, nickname, alias, contact information including email, phone number, and address, User ID, password, IP address, device ID, and account name and number o Business Purpose Disclosures:
Service Providers, such as cloud vendors, analytics companies, social media networks, and advertising providers
- Personal Records: such as financial account information o Business Purpose Disclosures: Service Providers, such as cloud vendors and financial services companies
- Personal Characteristics and Traits: such as age and gender o Business Purpose Disclosures: Service Providers such as cloud vendors, analytics companies, advertising providers, and social media networks
- Customer Account Details / Commercial Information: such as purchase or service history o Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, cloud vendors, financial services companies, and social media networks
- Internet Usage Information: such as browsing history, referring URLs, search history, interactions with advertising links, and CT mobile application usage o Business Purpose Disclosures: Service Providers such as cloud providers, analytics companies, advertising providers, and social media networks
- Geolocation Data: such as your location we infer based on your IP address o Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, and social media networks
- Sensory Data: such as voice recordings from call centers o Business Purpose Disclosures: Service Providers such as customer service providers
- Inferences from PI Collected: such as customer profiles, including customer characteristics and behaviors o Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, and social media networks
In addition to the disclosures described above, we may disclose each category of personal information above with independent CT dealerships, or our other affiliates at your request or to enable us and our affiliates to provide goods or services to you. Upon request and as required by law, we may provide identifiers, personal records, personal characteristics and traits, customer account details and commercial information, internet usage information, geolocation data, sensory data, and inferences from PI with government entities, including law enforcement.
- Providing the CT Services and our products, including maintaining and servicing your account, verifying your information, processing payments, advertising or analytics services, and similar functions and services
- Detecting security incidents and protecting against malicious, deceptive, or illegal activity
- Debugging the CT Services to identify and repair errors
- Internal research and development
- Quality and safety assurance, and improving, upgrading, and enhancing our products and Services
- Processing and managing interactions and transactions on the CT Services
User’s CCPA Rights
Right to Opt-Out of Sale of Personal Information
We do not knowingly Sell your PI. For this reason, we do not treat PI Collected by us as subject to a Do Not Sell request and, therefore, we do not offer a way for you to submit such a request. There is not yet an industry consensus as to whether third-party cookies and tracking devices associated with our websites and mobile apps may constitute a “Sale” of
your PI as defined by the CCPA and as such, we do not treat such information as subject to a Do Not Sell request.
However, third parties may Collect Personal Information through the CT Services for advertising, analytics and other purposes. Please visit Privacy Rights Info to opt-out of what these participating third parties consider a Sale of PI. This is a third-party program and we are not responsible for its effectiveness. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may still continue to see interest-based ads.
We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to disclose PI; (ii) to comply with your requests under the CCPA; (iii) disclosures among the entities that constitute CT NASSAU, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
We do not knowingly Sell the PI of Consumers under 18 (eighteen). Any California residents under the age of 18 (eighteen) who have registered to use the CT Services, and who posted content or information on the CT Services, can request removal by contacting us at Data Privacy@stellinigroup.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
Rights to Know and Delete Personal Information
California Consumers have the right to exercise certain privacy rights under the CCPA. California Consumers may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI.
If you are unable to provide us with certain information about yourself and your interactions with CT NASSAU we will be unable to verify your identity to fulfill a request to know or delete. In some cases, we may verify your identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.
Some PI we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that Personal
Information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Collect, Process, store, disclose, and otherwise use and to respond to your California Consumer rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
You may use an authorized agent to submit a Consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.
a. Categories of PI
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have Collected about you;
- The categories of sources from which we Collected your PI;
- The business or commercial purposes for our Collecting or Selling your PI;
- The categories of third parties to whom we have disclosed your PI;
- A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we would explain the categories of your PI we have Sold and the categories of Third Parties to which we Sold PI, by categories of PI Sold for each Third Party.
b. Specific Pieces of PI
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have Collected, and are maintaining, in the period that is 12 months prior to the request date. Please note that we retain PI for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
c. The Right to Deletion
You may request that we delete your PI that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your PI for regulatory reasons, to complete a warranty or other contract with you, or for other internal uses of the information that are compatible with the context in which you provided it. Note also that we are not required to delete your PI that we did not Collect directly from you.
To exercise the right to know or right to delete, you may submit a request by:
- e-mail: email@example.com
- postal address: 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39
Please include your name, address, email address, and phone number in your request. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so. We will not discriminate against any consumer for exercising these rights, as described further below.
Notice of Financial Incentive and Non-Discrimination
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable PI.
Notwithstanding anything to the contrary, we may Collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
California Shine the Light Law
California's “Shine the Light” law permits California residents to request certain information regarding our disclosure of “personal information” (as defined by the “Shine the Light” law) to third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by:
- e-mail: firstname.lastname@example.org
- postal address: 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39
Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.