DotNet Holdings LLC DBA Refer.Direct and its subsidiaries and affiliated entities (collectively “Refer.Direct” “Company,” “we”, “us” or “our”) is primarily engaged in the business of digital marketing for industries such as automotive, real estate, and home improvement services that assists automotive retail dealers, vehicle manufacturers, home improvement professionals (such as handymen, roofers, and contractors), real estate agents and brokers as well as other third parties in the mentioned industries to market and sell their products and services to Consumers through our programs for online Consumer referrals, dealer marketing products and services, email marketing, postal advertising and online advertising. The primary component of our business is the collection of Personal Information voluntarily provided by Consumers in order to connect the Consumer to Third Parties offering products and services that relate, including but not limited, to the automotive field and vehicle ownership, vehicle leasing, home ownership and remodeling, real estate purchasing and selling.
We strive to build and maintain a relationship of trust with you. This Privacy Policy (“Privacy Policy”) describes how we collect, use, share and retain your Personal Information (as defined below) and how to exercise any rights you might have with respect to this information. It governs information we collect through our website(s), microsite(s), mobile website(s), and mobile applications (collectively, “Refer.Direct Sites”) and information we collect, directly or indirectly, through any other means, including offline activities (collectively, “Services”). All Personal Information collected by us may be used, disclosed, shared, sold, transferred, or retained as described in this Privacy Policy.
Please read this Privacy Policy, which is part of our website Terms of Use (as defined below), before using Refer.Direct Sites and/or Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using Refer.Direct Sites and/or Services. By using Refer.Direct Sites and/or Services you agree and provide your consent to our collection, sale, sharing, disclosure, use, and retention of your personal information consistent with the Terms of Use and this Privacy Policy, subject to your rights described below.
We encourage Consumers to read this Privacy Policy carefully before providing any Voluntarily Provided Personal Information on any Refer.Direct Site.
“Advertising Networks” are Third Parties that serve interest-based advertising to Consumers and generate statistics and metrics related to the delivery of interest-based advertising.
“Authorized Agent” means a natural person or a business entity that a Consumer has authorized to act on behalf of the Consumer as provided in the California Privacy Act.”
“Automatically-Collected Personal Information” is Personal Information collected automatically through the use of Data Technologies without any action or entry of Personal Information by a Consumer when the Consumer visits or uses Refer.Direct Sites or Third Party sites. Automatically-Collected Information does not identify a Consumer personally and cannot be linked back to a Consumer unless the Consumer decides at some point to identify the Consumer by submitting Voluntarily-Provided Information.
“California Privacy Act” means, collectively, the California Consumer Privacy Act of 2018 (Cal. Civ. Code Section 1798.100 et. seq)(“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and the California Consumer Privacy Act Regulations adopted thereunder (Cal. Code of Regulations, Title 11, Division 6, Chapter 1)(“Regulations”) .
“Consumer” means a natural person.
“Consumer Requests” means the submission of a specific request online from a Consumer that (i) is initiated by the Consumer; (ii) contains Voluntarily-Provided Personal Information furnished by the Consumer; and (iii) expresses the Consumer’s interest in (1) purchasing or leasing a vehicle or real estate, remodeling or renovating homes or receiving a price quote or other information regarding a vehicle, real estate or home improvement services; (2) other products and services offered by Third Parties;
“Contractor” means a Third Party to which Refer.Direct makes available Personal Information for a business purpose pursuant to a written contract with Refer.Direct.
“Data Technologies” are technologies, such as cookies, local shared objects, pixels and web beacons, used to collect information about your actions and your visit to Refer.Direct Sites or Third Party sites, and includes all current and similar future technologies, including anonymous advertising identifications used on mobile devices and otherwise in a manner similar to cookies.
“Employment-Related Information” means Personal Information that is collected by the business about a natural person for reasons related to employment (including emergency contact information) and employment benefits as identified in California Civil Code Section 1798.145(m)(1).
“Interest-Based Advertising” or “Behavioral Advertising” is advertising that is customized and targeted based on predictions generated over time from a Consumer’s visits across different websites, devices, and mobile applications.
“Online Behavioral Information” is the collection of data online from a particular computer or device regarding Web viewing behaviors over time, and across non-affiliated Websites for the purpose to use such data to predict visitor preferences or interests. Online behavioral information includes browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes “Sensitive Personal Information” and “Employment-Related Information.”
“Sensitive Personal Information” shall have the meaning set forth in the California Privacy Act and includes:
(A) Personal Information that reveals: (i) a consumer’s social security, driver’s license, state identification card, or passport number; (ii) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (iii) a consumer’s precise geolocation; (iv) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (v) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (vi) a consumer’s genetic data.
(B) (i) The processing of biometric information for the purpose of uniquely identifying a consumer; (ii) Personal information collected and analyzed concerning a consumer’s health; (iii) Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Sensitive personal information that is publicly available shall not be considered Sensitive Personal Information or Personal Information.
“Service Provider” is a Third Party who has contracted with Refer.Direct to process Personal Information on Refer.Direct’s behalf and receives the information from or on behalf of Refer.Direct for a business purpose pursuant to a written contract with Refer.Direct.
“TCPA” means the Telephone Consumer Protection Act of 1991. “Terms of Use” means the terms and conditions governing your use of Refer.Direct Sites and that can be accessed at https://refer.direct/terms-of-service.
“Third Party” means a person or entity not owned, operated or controlled by Refer.Direct or any person or entity owned, operated or controlled by Refer.Direct.
“Voluntarily-Provided Personal Information” means Personal Information collected from a Consumer as a result of the Consumer providing that information voluntarily to Refer.Direct or to a Third Party that sells or otherwise transfers the Personal Information to Refer.Direct.
Categories of Personal Information We Collect and Retention Periods
The tables below list the categories of Personal Information that (i) we collect; (ii) the purposes for which we collect, sell, share or disclose the Personal Information; and (iii) our expected retention periods for the Personal Information.
The types of Personal Information we collect about you may vary based on how you use the Refer.Direct Web Sites and/or Services and the nature of your relationship with us.
Note to Company employees, independent contractors and job applicants (“Employment-Related Consumers”): Refer.Direct does collect, share, retain, and disclose certain categories of Employment-Related Information, which includes Sensitive Personal Information, from Employment-Related Consumers in connection with employment-related matters. The collection, sharing, retention and disclosure of Employment-Related Information is governed by the Company’s Supplemental Privacy Policy for Employment-Related Information that is accessible by and provided to Employment-Related Consumers.
Categories of Sources From Which We Collect Personal Information
We collect Personal Information from the following categories of sources of Personal Information:
Personal Information Voluntarily Provided by Consumers. You are not required to provide us your Personal Information to view Refer.Direct Websites unless you wish to voluntarily provide your Personal Information in order to be contacted by us, a vehicle seller, home improvement professional, real estate broker or other Third Party providing products or services in which you are or may be interested. If you choose not to provide the requested information, you may not be able to use some or all of the features of the Refer.Direct Sites or Services, and we may not be able to fulfill your requested interaction. We may also ask you to provide us with Personal Information when you communicate with us online or offline by telephone or texting, including in connection with customer surveys. Voluntarily-Provided Personal Information is also obtained from Third Parties that sell Consumer Requests to Refer.Direct where the Voluntarily-Provided Personal Information is collected by the Third Party from the Consumer on the Third Party’s website and sold to Refer.Direct to fulfill the Consumer’s Consumer Request by referral to a Refer.Direct client who is a vehicle seller, home improvement professional, real estate agent or broker, or other customer.
Personal Information Automatically Collected From Consumers.
Third-Party Data Sources. We may collect Personal Information from third-party data sources such as advertising networks, marketing agencies, internet service providers, data brokers, operating systems and platforms, analytics firms, government agencies, and social networks.
Vehicle Dealerships, Real Estate Agents and Home Improvement Professionals. We may collect Personal Information from our clients including Home Improvement professionals and companies, Automotive/Vehicle dealers and manufacturers, and Real Estate Agents, with whom you interact. For example, if you purchase a product from a client that Refer.Direct referred you to, that client might share with us Personal Information relating to the product or service you purchased from them or another Third Party.
Mobile-specific information that we may collect. Refer.Direct collects information from a Consumer’s mobile devices such as hardware IDs and device type, the request type, your carrier, the Consumer’s carrier user ID, and the content of the Consumer’s request, which does not by itself identify the Consumer, though it may be unique or consist of or contain information that the Consumer may consider personal.
Trackable Telephone Numbers. We publish uniquely-generated, trackable toll-free phone numbers on the Refer.Direct Sites or in advertisements posted on Refer.Direct Sites. If a Consumer dials one of these telephone numbers, Refer.Direct or a service provider working with Refer.Direct may record the date, time and length of the Consumer’s call and the phone number from which the call originated.
Combined or Appended Personal Information and Personal Information from Third Parties. We may obtain from Third Parties Personal Information that they have collected and combine that information with Personal Information that we have collected. The combined information may include information about the Consumer’s use of the Refer.Direct Sites; use of Third Party websites, devices and mobile applications; interactions or transactions with vehicle dealers; interests and preferences; and other information about the Consumer or the Consumer’s household.
Sales Matching. When we refer a Consumer to a partner, we may obtain sales matching data from the partner or other Third Parties that contains Personal Information that we did not originally provide to the partner or other Third Parties. Sales matching data may include the details of a product purchase, the purchase price, and/or the purchase date.
Purposes for Collecting, Selling, Sharing or Disclosing Personal Information.
We collect, sell, share, or disclose Personal Information for the following business and commercial purposes:
Provide Consumers with access to and use of the Refer.Direct’s Services offered on Refer.Direct Sites;
Facilitate, provide or fulfill the information, products, or services requested by Consumers, primarily the referral of Consumers requesting vehicle pricing, availability and other information to vehicle dealers;
Communicate with Consumers about their interest in purchasing or leasing vehicles or real estate, remodeling or renovating homes, or receiving a price quote or other information regarding a vehicle, real estate or home improvement services or other products and services;
Market products or services offered by Third Parties to Consumers, primarily vehicle and automotive and nonautomotive-related products and services;
Sell or share Personal Information with Third Parties for the Third Parties to market their products and services, or the products and services of their customers, to Consumers.
Operate information security and anti-fraud programs;
Perform business operations, including the improvement of our Refer.Direct Sites and Services; surveys, research and data analytics; and other normal business activities for digital marketing;
Respond to governmental and other legal requests;
Providing Our Services to Consumers and Fulfilling Consumer Requests
Refer.Direct collects Voluntarily Provided Personal Information in order to provide the Services requested by Consumers when they submit Consumer Requests through the Consumer’s use of a feature or service offered by Refer.Direct where the requested service or feature requires the entry of Voluntarily-Provided Personal Information.
We collect Voluntarily-Provided Personal Information in Consumer Requests submitted by Consumers directly from Refer.Direct Sites or that were submitted by Consumers through Third Party websites and that were acquired by us from the Third Parties in order to provide the Consumer’s Voluntarily-Provided Personal Information to a vehicle dealer, vehicle manufacturer, home improvement professional, real estate agent or broker or other Third Party that can contact the Consumer directly and provide the Consumer the product, service or information that the Consumer has requested or in which the Consumer may have an interest or to send the Consumer advertising, marketing or content. Consumers may come to Refer.Direct Sites to submit Consumer Requests directly by visiting an Refer.Direct Site or may indirectly submit Consumer Requests to us by submitting a Consumer Request on a Third Party website or clicking on advertisements or links to Refer.Direct Sites that Refer.Direct places or has placed on Third Party sites, social media platforms or emails sent by Refer.Direct or Third Parties.
Marketing and Advertising
We use Personal Information to engage in marketing and advertising:
To provide Consumers with information about services that we offer and think may interest Consumers, and/or deliver what we believe is relevant advertising to Consumers. We use Automatically-Collected Personal Information that generates Online Behavioral Information that may be used to generate Interest-Based Advertising.
To provide customization, auditing, research and reporting for us, our Third Party affiliates and other advertisers and to enhance marketing programs, Refer.Direct engages with Advertising Networks that may use Information collected through a variety of Data Technologies. This data collection takes place both on the Refer.Direct Sites and on Third-Party’s websites and mobile applications. This process allows Refer.Direct and Third Parties to deliver Interest-Based Advertising, and helps track the effectiveness of such efforts. 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.
To provide Consumers with content and services that we believe are relevant to a particular location and to customize marketing to the Consumer. When a Consumer uses the Refer.Direct Sites, we may collect geolocation information. We may use geolocation information and provide it to Third Parties to provide the Consumer with content and services that are relevant to a particular location, such as advertising, partners who service that location and/or to customize marketing to the Consumer for what is available in the Consumer’s area or close proximity. This geolocation information may reveal a Consumer’s actual location, such as GPS data, or it may not, such as when the Consumer submits a partial address to look at a map of the area.
Service improvement- We use Personal Information to engage improvement of our Services:
To provide you with a good experience when you use our services and/or to show you more personalized advertising, including advertising on other websites, we use Data Technologies to distinguish you from other users of our websites and apps (including when you browse third party websites). One or more Data Technologies may be used on the Refer.Direct Sites and other websites and mobile applications (that may not be the Refer.Direct Sites) by Refer.Direct or Third Parties. Data Technologies may be used to collect information about web pages you visit and to transmit information to you or about you and connect information about you from different sources, websites, devices, and mobile applications. Refer.Direct places or "sets" Refer.Direct cookies on a Consumer’s computer or device when the Consumer visits Refer.Direct Sites. We may also set cookies on a Consumer’s computer or device on behalf of Third Parties authorized by Refer.Direct or may enable certain Third Parties to set their own cookies on the Consumer’s computer or device.
To better understand our users and improve the Refer.Direct Sites, Refer.Direct uses Third Party tracking services for which Refer.Direct sets cookies on your computer or enables the Third Party tracking services to set cookies on your computer or device, when you visit Refer.Direct Sites. These cookies track visits, page views and click stream behavior. Third Party tracking services report this data to Refer.Direct in aggregated form. Refer.Direct shares such anonymous, aggregated information obtained from these cookies with our advertisers and other Third Parties.
To help diagnose problems with our servers, administer the Refer.Direct Sites and track site usage statistics, anytime you visit Refer.Direct Sites, we collect the Internet Protocol (“IP”) address. A Consumer’s IP address may vary each time the Consumer visits, or it may be the same, depending on how the Consumer accesses the Internet. We also collect information on whether the Consumer reached a Refer.Direct Site by clicking on a link or advertisement on a Third Party site, which helps us to maximize our Internet exposure, and to understand the interests of our users. We also collect information on the Consumer’s ISP (internet service provider) or mobile carrier and the type of handheld or mobile device the Consumer used. All of this information is collected and used only in the aggregate; that is, it is entered into our database, where we can use it to generate overall reports on our visitors, but not reports about individual visitors.
To enhance a Consumer’s experience on Refer.Direct Sites, Refer.Direct uses Google Analytics to collect information through Data Technologies. This data is collected on an anonymized basis and is aggregated but may include or be associated with other non-Personal Information or with Voluntarily-Provided Personal Information. Google Analytics is a web analytics tool provided by Google, Inc. ("Google") that helps website owners understand how visitors engage with their website. We can view a variety of reports about how visitors interact with Refer.Direct Sites so we can improve the Refer.Direct Sites. Google uses first party cookies and IP addresses, and it reports website trends without identifying individual visitors. We may also use VWO to capture our visitors' website experiences, without seeing the text of anything the visitors type in. We use it to be able to understand how Consumers use the Refer.Direct Sites to improve the user experience. Information collected by VWO is governed by its own privacy policy, which can be found at VWO.
To reduce risk and ensure we meet ever evolving privacy standards, we use third-party services to record lead consent and automatically encrypt Consumer information whenever a Consumer visits, enters information into, browses or otherwise interacts with our website. These services may include, but are not limited to services such as Verisk (formerly Jornaya) and ActiveProspect. These services will capture certain information and automatically create a unique lead identifier associated with each unique online or application event as well as provide us with factual information about the environment that the consumer experienced. These services may use various technologies to do this, including JavaScript, website scripts, pixel tags, cookies, local storage, session replay, and device identification. The Consumer information captured may include, but is not limited to a Consumer's Internet Protocol (IP) address, browser type, browser language, and the date and time that web page was visited.
How We Use Your Personal Information and Categories of Third Parties To Which We Sell, Share or Disclose Personal Information.
Use of Personal Information by Refer.Direct - Personal Information collected by Refer.Direct is used by Refer.Direct for the purposes described above, including to (i) improve the content or layout of the Refer.Direct Sites; (ii) improve user experience on Refer.Direct Sites; (iii) provide services requested by users of the Refer.Direct Sites; (iii) respond to questions, requests or complaints from Consumers; (iv) request feedback from Consumers; (v) develop new products and services; (vi) evaluate the effectiveness of the Refer.Direct Sites; (vii) contact Consumers for marketing purposes, including through email and SMS/text marketing.
When a Consumer provides the Consumer’s email address as Voluntarily-Provided Information, we automatically include the Consumer’s name and email address and other Voluntarily-Provided Information in our marketing database to receive email communications from us that contain marketing, advertisements and content. We may collect information regarding the effectiveness of our email and other communications with the Consumer.
The Consumer’s submission of a Consumer Request constitutes the Consumer’s (i) affirmative consent and agreement to our Terms of Use and this Privacy Policy; and (ii) affirmative express written consent to sell/share the Consumer’s information with Refer.Direct, its affiliates, automotive dealers, and other automotive or non-automotive third parties (and their agents or representatives), and authorize them to contact the Consumer through automated means (e.g., automatic telephone dialing system, text, artificial or pre-recorded messaging) for promotional marketing purposes at the phone number and email address the Consumer provided via live, pre-recorded, or auto dialed via telephone, mobile device (including SMS and MMS), and/or email, even if my number is currently listed on Federal or any state Do Not Call or Do Not Email. The Consumer also confirms the Consumer’s understanding that the foregoing consent is not a condition to purchase any product/service, and that the Consumer can revoke this consent at any time or opt-out of SMS messages by replying STOP. The acknowledges that the Consumer’s carrier’s message and data rates may apply.
Categories of Third Parties to Which We Sell, Share or Disclose Personal Information
We may sell, share, disclose, or transfer Personal Information to Third Parties under the following circumstances:
To Third Parties, including vehicle dealers, home improvement professionals, real estate agents or brokers that can provide the Consumer with the products, services or information that the Consumer has requested;
To our advertiser clients to assess the effectiveness of advertising campaigns we have provided for them;
To other digital marketing services companies that purchase Consumer Requests from Refer.Direct for sale, disclosure or transfer to such Third Party’s customers;
To Service Providers and Contractors;
To Third Parties who provide us appended Personal Information;
To Third Party vendors and suppliers of products and services in which the Consumer has expressed an interest or about which a Consumer has requested information;
To Third Parties that may wish to send the Consumer email, postal mail or SMS/text messages containing advertising or marketing materials regarding products or services that the Third Parties or their customers believe Consumers may find of interest; and To courts, governmental agencies and other Third Parties as required by applicable law, rule, regulation or order.
These Third Parties may use your Personal Information for their normal business purposes, including marketing, customer service, fulfillment, and related purposes.
We may aggregate Personal Information from all of our users and provide that information in the aggregate to vehicle dealers, vehicle manufacturers, home improvement professionals, real estate agents or brokers, advertisers and other Third Parties for marketing and promotional purposes. However, if we do so, that aggregated information will be anonymized so as not to be personally-identifiable.
Co-Branded Websites
We sometimes partner with Refer.Direct’s affiliated companies whose products or offerings may be of interest to you. We strive to be transparent by co-branding our Sites and clearly posting a message if you leave our Sites and navigate to another. When you visit or use a part of any Site that is co-branded or that is a part of a joint promotion involving Refer.Direct’s affiliate (each a “Co-Branded Party”), you are providing and consenting to provide your Personal Information and any other information collected by any Co-Branded Party to Refer.Direct’s affiliate.
Service Providers and Contractors
Categories of Service Providers or Contractors that may receive Personal Information from us or on our behalf or to which we make available Personal Information include:
Fulfillment and account servicing vendors that help us provide products, services and information to you, service your account or benefits, collect survey responses, and support our e-commerce services;
Marketing and communications vendors that help us market our products/services to you, conduct promotions, events, surveys and other outreach campaigns;
Research and development vendors that help us develop and improve our products and services;
Data and business analytics vendors that help us collect, analyze, and improve the accuracy of our data (including Personal Information);
IT and network administration vendors that provide services such as data storage and management, website hosting, and data security;
Professional service firms that provide accounting, legal, and other professional services; and
General service providers that help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.
Legal Matters - Refer.Direct will cooperate with legal authorities and may in some circumstances be required to disclose Personal Information in response to requests from law enforcement or other governmental agencies, or in response to a subpoena or other legal process. We can also share information about you if we believe we must in order to (i) prevent a violation of the law; (ii) protect or defend our interests and the legal rights or property of Refer.Direct and our affiliates; (iii) protect the rights, interests, safety and security of users of the Refer.Direct Sites or members of the public; (iv) protect against fraud or for risk management purposes; or (v) comply with prudent legal practice as we may determine, and with applicable law or legal process. We may also share Personal Information in the course of legal proceedings if we are legally required to do so, if we reasonably believe that doing so may mitigate our liability, or if doing so will assist us in enforcing our legal rights.
Business Transfers and Other Transactions
Information about our users and the Refer.Direct Sites is a business asset of Refer.Direct. As we continue to develop our business, we might sell or buy websites, subsidiaries or business units. In such transactions, Personal Information generally is one of the transferred business assets. Also, in the event that Refer.Direct or substantially all of its assets are acquired, Personal Information will of course be one of the transferred assets. In addition, Personal Information will be disclosed as part of any creation of a separate business to provide a Refer.Direct Site, or to provide other services or fulfill products; debt financing, sale or pledge of company assets, or insolvency, bankruptcy or receivership. We will make reasonable efforts to ensure that the acquirer of our users' Personal Information respects the provisions of this Policy, although this may not be possible in certain legal settings (such as bankruptcy).
Your Choices Regarding Your Personal Information - You may limit and control the Personal Information collected by us in a number of ways. Note that California residents may have additional limitation and control rights that are described in the section of this Privacy Policy entitled “Notice to California Residents Regarding Your California Privacy Rights.”
Voluntarily-Provided Personal Information - You are not required to provide any Voluntarily-Provided Personal Information to visit or use the Refer.Direct Sites. You may elect to not provide Voluntarily-Provided Personal Information for any purpose. However, in doing so, you may not be able to use all features provided by the Refer.Direct Sites or all services provided by Refer.Direct. For example, if you do not provide the Voluntarily-Provided Information required to submit a Consumer Request, you will not be able to submit Consumer Requests, and Refer.Direct and vehicle sellers, vehicle manufacturers, home improvement professionals, real estate agents or brokers and other Third Party service and product providers will not be able to contact you to provide you the products, services or information in which you may be interested. You may also choose not to participate in surveys.
Opting Out of Email Marketing - We provide our users with the ability to choose whether to receive email communications from us and to permit their Personal Information to be disclosed to Third Parties for marketing or related purposes. If a Consumer does not wish to receive promotional and marketing communications from us, the Consumer may do so (i) if the Consumer received a promotional or marketing email from us, by following the link for that purpose located at the bottom of the email, or (ii) by sending a request to us by contacting our Feedback Department as provided under the section of this Privacy Policy entitled “Contact Us” below. However, withdrawing a Consumer’s consent will not affect the use of the Consumer’s Personal Information by Third Parties that previously received the Consumer’s Personal Information to continue to send communications to the Consumer and otherwise use the Consumer’s Personal Information.
In addition, we provide you the opportunity to indicate your preferences as to what types of offerings of products or services you wish to receive from Third Parties or, subject to the exceptions below, to opt-out of disclosures to those Third Parties altogether. You may update your preferences at any time by contacting us at feedback@refer.direct. Those Third Parties who receive your Personal Information prior to your opt-out will remain able to send you communications, subject to their privacy policies and practices. To opt-out from receiving third party emails, you must contact those third parties directly.
Even if a Consumer decides not to receive offers or other product or service information, Refer.Direct and the dealers, manufacturers, other product and services providers, fulfillment third-parties and other referral services with which Refer.Direct has relationships, may use a phone number, mailing address or email address that the Consumer has provided to contact the Consumer regarding a Consumer Request that the Consumer submitted. Additionally, phone numbers and email addresses may be used to conduct customer surveys regarding individual experiences with Refer.Direct, dealers, or other product and services providers. Phone numbers and email addresses are made available only to Refer.Direct, its affiliates and dealers, manufacturers, other referral services, fulfillment third parties and other referral services who receive a Consumer Request.
If a Consumer requests to opt-out of receiving emails from us and then subsequently submits a Consumer Request (either directly or submitted through a Third-Party and are referred to us), we will reinstate the relationship with us and we will the Consumer’s Personal Information as set forth herein, unless the Consumer subsequently requests to opt-out. Each time a Consumer submits a Consumer Request, this process will restart.
Most web browsers automatically accept cookies, but a Consumer can usually modify the Consumer’s browser’s setting to decline cookies if the Consumer prefers. Consumers have the ability to accept or decline cookies by modifying the Consumer’s browser settings, and our websites are viewable even if the Consumer disables the cookie function on the Consumer’s browser. However, if a Consumer disables cookies, note that certain features may not function properly or at all as a result, and some advanced and customized features or offerings will not be available to the Consumer, including personalization features.
If a Consumer prefers not to accept cookies, the Consumer should consult documentation for the Consumer’s browser or device for more information. Most browsers will explain how to view and disable cookies under the help portion of the toolbar or notify the Consumer when the Consumer receives a new cookie. Use of third party cookies is subject to the privacy policies and opt-out procedures of these third parties and not Refer.Direct's policy and procedures. To learn more about the data and information collection and use practices of some third parties as well as ways to opt-out, visit http://www.networkadvertising.org/managing/opt_out.asp. At times, not all of the third parties for which we set cookies on Refer.Direct Websites or for which we enable to set their own cookies are included in the preceding link to opt-out from these cookies. Should you wish to opt-out of these cookies, a Consumer will need to access the third party’s website to determine their opt-out procedure.
A Consumer may also render some web beacons unusable by rejecting their associated cookies and disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on's settings or opting out at the website of the technology provider.
A Consumer may refuse to accept a cookie from us on mobile devices by adjusting the use of advertising identifiers through the settings on the Consumer’s computer or device. A Consumer’s mobile device may also have settings that allow the Consumer to prevent sharing Geolocation Information with us. Consumer’s should consult their mobile device’s settings or help documentation for more information about exercising these options.
Consumers can opt out of f interest-based advertising by multiple companies by visiting www.aboutads.info/choices and www.networkadvertising.org/managing/opt_out.asp. Please note that even if a Consumer opts out, the Consumer will continue to receive advertisements, but the advertisements will not be tailored to the Consumer’s specific interests.
Refer.Direct uses Google Analytics, which helps Refer.Direct better understand its audience and target communications and advertisements based on demographic or interest-based information. Consumers may learn more about opting out of certain Google advertising initiatives and to install Google Analytics Opt-out Browser Add-on. Please note that Consumers may still receive advertising even after opting out, but that advertising may not be tailored to the Consumer or the Consumer’s interests.
Response to Opt-Out Preference Signals - As of the effective date of this Privacy Policy, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of Personal Information regarding your online activities over time and across third party websites or online services. If you would like to submit a privacy request concerning the collection of your Personal Information, please use our “Do Not Sell My Personal Information” request form.
Meta Pixel is a javascript code created by Meta that allows us to track user activity on our website to measure the effectiveness of our ads. If you would like to opt-out of Meta Pixel, please visit the "Settings & Privacy" menu on your Facebook profile. Additionally, you may opt-out of tracking by:
Changing your ad preferences on your browser; Disabling ad tracking at the device level; Clearing your Activity Log; Turning off location tracking; Using an anti-tracking extension; and Avoiding social logins and provide minimal permissions.
Revocation of TCPA Consent and Opting Out of Automated Calls and Text Messaging - You may revoke your consent and opt-out from receiving calls or text messages at any time. You may opt-out of text messages by replying STOP to any text message you receive or follow other opt-out instructions included with the text message. You acknowledge and agree that you may receive a text message confirming your opt-out. To opt-out of telephone calls from Refer.Direct (but not text messages), contact our Feedback Department as provided below under “Contact Us.” To opt-out of receiving telephone calls or texts from Third Parties, please contact the Third Party directly. To obtain assistance from our Feedback Department with respect to text messaging, contact our Feedback Department as provided below under “Contact Us.”
VII. Children and Minors
Refer.Direct Sites are not directed to minors under the age of 16, including both children under the age of 13 and children at least 13 and less than 16 years of age (collectively, “Minors under the age of 16”). We do not intend, and Refer.Direct Sites are not designed, to collect from, sell or share Personal Information of Minors under the age of 16. We do not knowingly collect, sell, or share Personal Information of Minors under age 16 and do not have actual knowledge that we sell or share Personal Information of Minors under age 16. If you are under 16 years old, you should not provide Personal Information to any Refer.Direct Website. Should we obtain actual knowledge that we have collected or received Personal Information from a Minor under the age of 16 without the verifiable consent of a person that we have determined by reasonable methods to be the minor’s a parent or guardian (if a minor is under 13 years of age), or the minors’ consent (if a minor is at least 13 and less than 16 years of age), we will delete that information. If you believe we might have any information from or about a Minor under the age of 16, please contact our Feedback Department as specified in the " Contact Us" section below. We do not sell or share Personal Information without the affirmative consents required by the California Privacy Act if we obtain actual knowledge that we collected or maintain Personal Information from Minors under the age of 16.
VIII. When Third Party Privacy Policies, Terms of Use and Consents To Marketing Calls and Texting Govern the Collection, Use, Sale or Sharing of Personal Information
A Consumer’s Personal Information is collected by a Third Party:
When the Consumer initially provides the Third Party the Consumer’s Personal Information on a Third Party site and not on a Refer.Direct Site.
When a Consumer clicks on a link to a Third Party site from a Refer.Direct Site, including clicking on a Third Party advertisement placed on a Refer.Direct Site, the Consumer will leave the Refer.Direct Site the Consumer was visiting and be redirected to the Third Party site.
When we sell, share, disclose or otherwise transfer the Consumer’s Personal Information to the Third Party, for example, when we sell a Consumer Request to a vehicle dealer to contact the Consumer regarding the information, product or services the Consumer requested.
When Refer.Direct authorizes a Third Party to place the Third Party’s cookie or other Data Technology on a Refer.Direct site.
When Refer.Direct authorizes a Third Party to offer their products and services on Refer.Direct Sites through use of a "framed" format, where the Refer.Direct border will surround the pages served by the Third Party, or by directly linking the user to the Third Party’s sites. In either case, the Third Party is prominently identified.
When a Consumer’s Personal Information is collected by a Third Party, the Third Party’s collection, use, sale, sharing, disclosure or otherwise transfer the Consumer’s Personal Information is governed by the Third Party’s privacy policy and terms of use. In addition, the Third Party is responsible for obtaining the Consumer’s consent under the TCPA if the Personal Information collected includes your telephone number (landline or mobile). Because we do not control the activities of Third Parties, we do not accept or assume responsibility for any collection, use, storage, sale, sharing, disclosure or other transfer of Personal Information by such Third Parties or with respect to obtaining your TCPA consent, and we cannot represent or guarantee that they will adhere to the same privacy practices or procedures as Refer.Direct. We encourage Consumers to review the privacy policies and terms of use of any Third Parties to which a Consumer provides Personal Information or from which a Consumer requests information, products or services.
IX. Security Procedures and Practices - Refer.Direct has implemented and maintains reasonable administrative, technical, personnel, and physical security procedures and practices appropriate to the nature of the Personal Information and designed to protect the Personal Information stored in our systems against unauthorized or illegal access, destruction, use, modification, or disclosure. Although Refer.Direct has endeavored to create secure and reliable networks, servers and databases that we operate or that are operated on our behalf, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security and cannot guarantee protection of all information against interception, misappropriation, misuse, or alteration, or that information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.
X. Changes or Revisions to This Policy - We reserve the right to change this Privacy Policy at any time without prior individual notice. Any changes to our Privacy Policy will be posted at this URL, so be sure to check back often and consult the last updated version. Your continued use of Refer.Direct Sites and Services following notice of such changes will be conclusively deemed acceptance of any changes to this Privacy Policy. You agree that posting of changes to this Privacy Policy constitutes reasonable and sufficient notice. At all times, you are bound by the then-current version of the Privacy Policy and all applicable laws. We highly recommend that you review this Privacy Policy from time to time. Any change to this Privacy Policy that materially affects your rights to your Personal Information will not take effect until 30 days after notice of such change is posted on the site, during which time you may notify us that you do not accept such change. If you do not accept such change, then you must immediately discontinue use of Refer.Direct Sites. Your continued use of Refer.Direct Sites after such a 30-day period will mean that you accept such changes. If we make material changes that will affect Personal Information we have already collected from you prior to the changes going into effect, we will make reasonable efforts to notify you of these material changes and to give you the opportunity to opt-out and not allow us to use your Personal Information in the manner allowed by the changes.
XI. Disputes - Your access and use of Refer.Direct Sites and any dispute regarding privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the State of California.
XII. Updating or Correcting Your Personal Information. To update your Personal Information, you must submit a request by contacting our Feedback Department as provided under the section of this Privacy Policy entitled “Contact Us” below. Note that California residents should also review the additional requirements applicable to California residents in the section of this Privacy Policy entitled “Notice to California Residents Regarding Your California Privacy Rights.”
XIII. Contact Us - If you have any questions or need help or assistance regarding privacy, security, opting-out of email or text communications, your email and marketing preferences, or understanding how your Personal Information is being used, please contact our Feedback Department by email at feedback@refer.direct or by calling via our toll-free number at 1-888-821-1041. Note that California residents should also review the additional requirements applicable to California residents in the section of this Privacy Policy entitled “Notice to California Residents Regarding Your California Privacy Rights.”
Notice to California Residents Regarding Your California Privacy Rights - The California Privacy Act provides eligible California residents with specific rights with respect to our collection, retention, use, selling, sharing and disclosure of Personal Information. This California Privacy Rights section supplements this Privacy Policy and applies solely to eligible residents of California. Any terms not defined in this section have the same meaning as defined in the California Privacy Act.
Summary of California Privacy Rights Act - Right to Request and Obtain Information Regarding Personal Information (“Right to Know”). The California Privacy Act entitles California residents to request information about the Consumer’s Personal Information collected by the business in the 12 months preceding the request and concerning the categories of Personal Information that the business has collected about the Consumer; the categories of sources from which the Personal Information was collected; the business or commercial purpose for collecting, selling or sharing the Personal Information; the categories of third parties with whom the business discloses Personal Information; and the specific pieces of Personal Information that a business has collected about the individual Consumer. If the business also sells or shares the Consumer’s Personal Information or discloses it for a business purpose, in addition to the foregoing information, the consumer has the right to obtain the categories of Personal Information that the business sold or shared about the consumer in the 12 months preceding the request and the categories of third parties to whom the Consumer’s Personal Information was sold or shared (by category or categories of Personal Information for each third party to whom the Personal Information was sold or shared); and the categories of Personal Information that the business disclosed about the Consumer for a business purpose. Upon request by the Consumer, we may be required to provide the foregoing information for a period beyond the 12-month period unless doing so proves impossible or would involve disproportionate effort. This extended reporting period shall only apply to Personal Information collected on or after January 2, 2022. California residents who wish to request the foregoing information in compliance with the California Privacy Act should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights--Requests to Know, Requests to Delete and Requests to Correct” below.
Right to Have Personal Information Deleted (“Right to Delete”). The California Privacy Act entitles California residents to request that a business delete all Personal Information about the Consumer that the business has collected, subject to certain exceptions set forth in the California Privacy Act. California residents who wish to request deletion of their Personal Information in compliance with the California Privacy Act should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights--Requests to Know, Requests to Delete and Requests to Correct” below.
Right to Have Inaccurate Personal Information Corrected (“Right to Correct”). The California Privacy Act entitles California residents to request that a business that maintains inaccurate Personal Information about the Consumer to use commercially reasonable efforts to correct that inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. California residents who wish to exercise the foregoing right should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights-- Requests to Know, Requests to Delete and Requests to Correct” below.
Right to Opt-out From the Sale or Sharing of Your Personal Information to Third Parties (“Right to Opt-Out of Sale/Sharing”). The California Privacy Act entitles California residents to direct that a business that sells or shares Personal Information about the Consumer to third parties not to sell and/or share the Consumer’s Personal Information. California residents who wish to exercise this right in compliance with the California Privacy Act should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights-- Requests to Opt-Out of Sale/Sharing” below.
Right to Have the Use and Disclosure of Sensitive Personal Information Limited (“Right to Limit). The California Privacy Act entitles California residents to direct that a business that collects Sensitive Personal Information about the Consumer to limit its use of the Consumer’s Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests those goods or services, except that this Right to Limit is not applicable to certain such uses permitted by the California Privacy Act. California residents who wish to exercise the foregoing right should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights-- Requests to Limit below.
No Discrimination Against Persons Exercising Rights Under the California Privacy Act. Refer.Direct will not discriminate against any Consumer because the Consumer exercised any of the Consumer’s rights under the California Privacy Act. Unless permitted by applicable law, 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. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Retaliate against an employee, applicant for employment, or independent contractor. Information Regarding Collection and Sale of Personal Information and Requests. The following information regarding Personal Information collected and sold/shared by Refer.Direct and Consumer requests to exercise various rights under the California Privacy Act can be accessed by clicking here:
Metrics for the immediately preceding calendar year regarding the following: The number of requests to delete Personal Information that we received, compiled with in whole or in part, and denied during the calendar year. The number of requests to correct Personal Information that we received, complied with in whole or in part, and denied during the calendar year. The number of requests to know Personal Information that we received, complied with in whole or in part, and denied during the calendar year. The number of requests to opt-out of sale/sharing Personal Information that we received, compiled with in whole or in part, and denied during the calendar year. The number of requests to limit the use or disclosure of Sensitive Personal Information that we received, compiled with in whole or in part, and denied during the calendar year. The median number of days within which we substantively responded to requests to delete, requests to know, requests to opt-out of sale/sharing, and requests to limit.
Other California Privacy Rights - Right to Request Information Regarding Sharing of Personal Information With Third Parties for Direct Marketing Purposes. The California “Shine the Light Law” (Cal. Civil Code Section 1798.83) entitles California residents to request information concerning whether a business has disclosed certain Personal Information about the consumer during the immediately preceding calendar year to any third parties for the third parties' direct marketing purposes. California residents who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact our Feedback Department as specified in the section entitled "How to Contact Us Regarding This Privacy Policy and Your California Privacy Rights, below.
Children and Minors. Section 22581 of the California Business and Professions Code permits a resident of California who is both under the age of 18 and a registered user of any site on which this Privacy Policy is posted to request and obtain removal of content that the user has publicly posted. Please be aware that such requests do not ensure the complete removal of the content posted, and there may be circumstances in which the law does not require or allow removal, even if requested. To request removal of content under Section 22581 of the California Business and Professions Code, please contact us as specified in the section entitled “How to Contact Us Regarding This Privacy Policy and Your California Privacy Rights below.
Requests to Know, Requests to Delete and Requests to Correct - To exercise your Right to Know, Right to Delete or Right to Correct, you must submit a verifiable request (as defined by the California Privacy Act) to our Feedback Department by email at feedback@refer.direct, by calling via our toll-free number at 844-855-4095, or by accessing our online request form.
A verifiable consumer request must: Provide sufficient information that allows us to verify, using commercially reasonable methods, that you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
For Requests to Delete, we may use a two-step process for online Requests to Delete where the Consumer must first submit the request and then separately confirm that the Consumer wants to delete the Consumer’s Personal Information.
The California Privacy Act requires that we verify the identity of the requesting Consumer to a reasonable degree of certainty or reasonably high degree of certainty depending on the type of request and the Personal Information about the requesting Consumer maintained by us, as well as the sensitivity of the Personal Information and the risk of harm to the Consumer posed by unauthorized deletion, access or correction. We cannot comply with your Request to Know, Request to Delete or Request to Correct if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
No later than ten (10) business days after receiving a Request to Know, Request to Delete, or Request to Correct, we will confirm receipt of your request and provide information about how we will process the request, including information regarding our verification process and when you should get a response to your request. We will respond to a Request to Know, Request to Delete or Request to Correct within 45 calendar days of receipt of a request. If we require more time (up to an additional 45 calendar days, for a maximum total of 90 calendar days) to respond, we will notify you of the reason and extension period. If we are unable to comply with or deny a request, we will provide you with an explanation.
We will deliver our written response to a Request to Know information by mail or electronically, at your option. We are not obligated to provide a Consumer the information requested in response to a Request to Know more than twice within a 12-month period.
With respect to Requests to Correct, if we deny a Request to Correct because we have determined that the contested Personal Information is more likely than not accurate based on the totality of the circumstances, we may elect to delete the contested Personal Information if the deletion does not negatively impact the Consumer or the Consumer consents to the deletion.
Requests to Opt-Out of Sale/Sharing and Requests to Limit - To exercise your Right to Opt-Out of Sale/Sharing or Right to Limit you must submit a request to our Feedback Department by email at feedback@refer.direct, by calling via our toll-free number at 844-855-4095, or by accessing our online request form.
We will act upon your request within fifteen (15) business days after receipt of your request. If we determine that your Request to Opt-Out of Sale/Sharing or Request to Limit is fraudulent and deny the request, we will inform the requesting Consumer of that decision and provide an explanation of why we believe the request is fraudulent.
Requests to Opt-In To Sale/Sharing - A Consumer who has exercised the Consumer’s right to opt-out from the sale and/or share of the Consumer’s Personal Information, may change the Consumer’s mind and opt back in to personal information sales or sharing at any time by submitting a request to our Feedback Department by email at feedback@refer.direct or by calling via our toll-free number at 844-855-4095. A two-step process will be used whereby the Consumer must first clearly submit the request to opt-in, and then second, separately confirm the Consumer’s choice to opt-in.
Authorized Agents
A request that must be verified may be submitted by an Authorized Agent. If a request is submitted by an Authorized Agent on your behalf, we will require that (i) the Authorized Agent to provide proof that the Consumer gave the Authorized Agent signed permission to submit the request; and (ii) the Consumer verify the Consumer’s own identity directly with us or directly confirms with us that the Consumer provided the Authorized Agent permission to submit the request; provided that the foregoing two requirements shall not apply to an Authorized Agent who has been given a power of attorney by the Consumer pursuant to California Probate Code sections 4121-4130. If a parent or guardian is submitting a request on behalf of a minor under the age of 13, the parent or guardian must submit verifiable proof and we must determine by reasonable methods that they are the parent or guardian of the minor.
Request Fees and Denial of Requests
We do not charge a fee to verify, process or respond to requests; provided that if requests are manifestly unfounded or excessive, including by reason of them being repetitive, we may charge a reasonable fee with respect to responding to the request or refuse to act on the request. If we determine that a request is manifestly unfounded or excessive, we provide you with a cost estimate before completing your request or notify you of the reason we decided to refuse to act on the request and.
How to Contact Us Regarding This Privacy Policy and Your California Privacy Rights
If you have any questions regarding this Privacy Policy, your rights under the California Privacy Act (e.g., Right to Know, Right to Delete, Right to Correct, Right to Opt-Out of Sale/Sharing, Right to Limit) or the other California privacy rights summarized above, or the process to submit requests to exercise your California Privacy Rights, please contact our Feedback Department by email at feedback@refer.direct or by calling via our toll-free number at 844-855-4095.