Legal / Privacy

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Warranties Disclaimers

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Privacy Policy

We specialize in the development, marketing and administration of automotive aftermarket products, services and programs. We respect your privacy and are committed to protecting it through our compliance with this policy. In order to provide administrative services for these products (including but not limited to service contracts, warranties, maintenance plans and loyalty programs) we must collect nonpublic personal information and sensitive personal information from consumers who have purchased or received one of our products. This policy describes our practices and policies regarding the collection and disclosure of consumers’ nonpublic and sensitive personal information. Privacy practices described herein apply to information held by both current and former consumers. We reserve the right to change this policy; material changes will be posted online.

NONPUBLIC PERSONAL INFORMATION DEFINED

"Nonpublic Personal Information” refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, is not publicly available information and is collected during any transaction with a consumer or in connection with any service performed for the consumer

SENSITIVE PERSONAL INFORMATION DEFINED

Sensitive personal information refers to consumers’ social security, driver’s license, state ID, or passport numbers, financial account information, precise geolocation, race or ethnic origin, sexual orientation or preference, religious or philosophical beliefs, union membership, nonpublic communication and genetic, biometric, and/or health data.

COLLECTION OF NONPUBLIC AND SENSITIVE PERSONAL INFORMATION

In order to administer our products and programs, we collect the following types of information:

• 1. Consumers’ complete legal name or business name (if applicable). This may include the name of co-buyer
• 2. Consumers’ contact information including street address, mailing address, email address and telephone number
• 3. Information about the vehicle associated with the product or service including year, make, model, VIN, weight, MSRP (or other valuation), purchase price, odometer mileage, and whether the vehicle is covered by the manufacturer’s warranty)
• 4. Because our products are often financed with the vehicle under a vehicle finance agreement or relate directly to the vehicle finance or lease agreement, we may collect information about the vehicle finance or lease agreement including but not limited to the amount financed, the finance agreement’s effective date and scheduled termination date, the finance agreement term and APR
• 5. If the vehicle is leased, we may collection information about the lease agreement including the inception date and scheduled termination date. If we adjudicate a claim in connection with a lease, we may request a copy of the lease agreement and a lease end report from the lessor
• 6. During the claim adjudication process, we may collect data vital to the claim including but not limited to vehicle history (e.g. CARFAX), finance agreement payment history and information from insurance carriers (e.g. auto insurance, home owner’s insurance
• 7. We record telephone conversations between consumers and our employees and retain other written communications from consumers. These recordings and written communications may be considered Sensitive Personal Information.

METHODS FOR COLLECTION OF NONPUBLIC AND SENSITIVE PERSONAL INFORMATION

Our products, programs and services are marketed, sold and issued to consumers via retail businesses (e.g. auto, recreational vehicle or powersport dealers) or direct marketing entities (e.g. companies who market products to consumers over the telephone or internet). These parties collect consumers’ Nonpublic Personal Information at the point of sale/issuance and then transmit that information to us. The data is transmitted to us electronically (e.g. via our secure online portal) or by mail or facsimile. Consumers’ Sensitive Personal Information may be collected as part of a claim adjudication process for a program or product administered by us.

USAGE OF NONPUBLIC AND SENSITIVE PERSONAL INFORMATION

We use consumers’ Nonpublic Personal Information to carry out our contractual obligations and to maintain accounts, process transactions, pay claims, provide administrative support and customer service for our products, programs and services. For example, we utilize Nonpublic Personal Information to identify and verify identity of the vehicle owner and the vehicle to adjudicate a claim. Additionally, Nonpublic Personal Information may be used to follow up on a claim, process a cancellation request, send a legally required notice, issue reimbursements, protect against fraud and unauthorized activities, identify and offer additional products and services, develop new products and services and perform various other activities permitted by law. Sensitive Personal Information is collected only during the claim adjudication process and used only in connection with verifying information pertinent to the claim. For example, Sensitive Personal Information may be used to verify consumers’ identity (e.g. driver’s license) or verify the location of a stolen vehicle (e.g geolocation data).

DISCLOSURE OF NONPUBLIC AND SENSITIVE PERSONAL INFORMATION

We share consumers’ Nonpublic Personal Information and Sensitive Personal Information with and/or without consumers’ prior authorization when permitted by law. We may share Nonpublic Personal Information and Sensitive Personal Information with entities in the following categories:

• 1. Affiliates (i.e. entities that have common ownership, sister companies or subsidiaries
• 2. Third party service providers (e.g. repair facilities, roadside assistance providers, independent vehicle inspectors, companies who provide software to dealers, companies that provide language translation administrative services, etc.); and
• 3. Other unaffiliated parties (e.g. our insurer)

We may share the following type of information with the entities described above:

• 1. Consumers’ complete legal name or business name
• 2. Consumers’ contact information including street address, mailing address, email address and telephone number
• 3. Information about the vehicle associated with the product or service
• 4. Information about the vehicle finance or lease agreement including the amount financed, the finance agreement’s effective date and scheduled termination date, term and APR
• 5. Information need to complete the claim adjudication process claim including vehicle history (e.g. CARFAX), finance agreement payment history and information from insurance carriers (e.g. auto insurance, home owner’s insurance
• 6. Police reports which may contain Sensitive Personal Information such as driver’s license number, designation of race or ethnicity and geolocation data.

We are allowed by law to share information with our affiliates without consumers’ authorization in order to facilitate our products and services. We may share information with our affiliates and non-affiliates as required or permitted by law, including for the following purposes:

• - For normal business purposes (e.g.to pay a claim or to request a report from a consumer reporting agency)
• - In connection with a proposed or actual sale, merger, transfer, acquisition, or exchange of all or a portion of our business; and
• - For marketing purposes

CONSUMERS RIGHT TO LIMIT SHARING OF PERSONAL INFORMATION

We share consumers’ personal information with our affiliates and third party service providers in order to facilitate our products, services and programs. However, we will honor requests to limit the personal information we share. We will implement these requests within a reasonable time upon receipt. Generally, consumers have the legal right to limit sharing of their personal information only in certain circumstances. Requests to limit sharing do not limit us from sharing information for everyday business purposes; as required law; or in connection with a proposed or actual sale, merger, transfer, acquisition, or exchange of all or a portion of our business. Some states may have further limitations on the sharing of consumers’ personal information.

SECURITY AND CONFIDENTIALITY

We collect and retain nonpublic personal information only in accordance with this Privacy Notice and applicable laws and regulations. We have taken reasonable precautions to protect consumers’ nonpublic personal information against loss, unauthorized access, or theft by implementing physical, electronic, and procedural safeguards.

Protecting consumer data is our highest priority. We take this responsibility very seriously and we regularly evaluate and update network security measures. We currently utilize the following security protocols and practices:

• - Our systems are stored in a secured datacenter which is monitored 24 hours a day, 365 days a year. Physical access to the datacenter is heavily restricted - only authorized datacenter personnel have access, with outside access restricted to our security officer and network engineer
• - Customer information that is transmitted outside of our network is either encrypted prior to transmission or transmitted to a secure FTP site
• - Our Office Firewalls are monitored 24 hours a day for suspicious activity and enable us to proactively address any threats.
• - We employ a 3rd party vendor to conduct network intrusion testing, which includes proactive testing and confirmation of security measures.
• - Our data is only accessible to authorized users via secure in-house applications. Each authorized user is assigned a security access level based on individual position requirements. All users are required to change network passwords every 90 days.
• - Paper documents containing customer information are scanned into our internal system. All paper documents are shredded prior to disposal.
• - We require all employees to participate in annual data security training. This training ensures that all employees understand the importance of data security and are current on all company data procedures and rules.

CONTACT INFORMATION

For questions about this Privacy Notice, to report a privacy breach or to make a request regarding the sharing of nonpublic personal information please contact us at:

Attn: Chief Privacy Officer/General Counsel
A. Kurt Wolery
555 Metro Place North, Suite 650
Dublin, Ohio 43017
858-810-1703
privacy@pdsadm.com
kwolery@pdsadm.com

Requests for access or changes to information must be submitted in writing to the address listed above.

SPECIFIC RIGHTS AND NOTICES

This Privacy Policy contains the following legally required information

• 1. Category of nonpublic personal information being collected
• 2. Category of sources from which the data is collected (e.g. dealer)
• 3. The purpose for which the data is collected
• 4. Category of other entities the data may be shared with; and
• 5. The specific pieces of data being collected

Consumers have the following rights with regard to nonpublic personal information collected by us:

• 1. The right to request a copy of the consumer’s nonpublic personal information collected by us. This data will be provided to a verified consumer by mail or email within 45 (forty-five) days of the request. To request this information from us, please click here.
• 2. The right to request that a business delete the consumer’s Nonpublic Personal Information and Sensitive Personal Information. In the event you request deletion of your Nonpublic Personal Information and Sensitive Personal Information, we will also affect deletion of that information retained by any 3rd party with whom we shared your information (in accordance with the information sharing policies outlined herein). However, the business is not required to comply with the request if the information is needed provide a good or service so the requesting consumer. To request deletion of your Nonpublic Personal Information and Sensitive Personal Information, please click here.
• 3. The right to request that a business abstain from selling a consumer’s Nonpublic Personal Information and Sensitive Personal Information - PLEASE NOTE THAT WE DO NOT SELL CONSUMERS’ NONPUBLIC OR SENSITIVE PERSONAL INFORMATION.
• 4. The right to request that a business abstain from sharing your Nonpublic Personal Information and Sensitive Personal Information. Please note that opting out of the sharing of your Nonpublic Personal Information and Sensitive Personal Information may your ability to make a claim under a product or program administered by us. To opt out of sharing your Nonpublic Personal Information and Sensitive Personal Information, please click here.
• 5. The right of persons younger than 16 years old that their Nonpublic Personal Information and Sensitive Personal Information not be shared without affirmative written consent of the person or their parent or guardian.
• 6. The right to request that we correct any inaccurate personal information that we may have collected from you. To correct inaccurate personal information please click here.
• 7. The right, at any time, to direct a business that collects Sensitive Personal Information about you to limit its use only to the extent which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services to be performed. To request that we restrict usage of your Sensitive Personal Information please click here.
• 8. The right to access information about how we use automated decision-making technology which includes information about the logic involved in those decision-making processes, as well as a description of the likely outcome of the process. You have the right to opt out of automated decision-making technology processes. To opt out of automated decision-making processes please click here.
• 9. The right to request that we transfer your Nonpublic Personal Information to another entity to the extent technically feasible, in a structured, commonly used, machine-readable format. To request such a transfer please click here.

Transparency in Coverage Rule

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

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