Who We Are.

We are an automotive AI company that helps dealers sell more cars faster by driving low funnel in-market car shoppers directly to inventory on dealer’s websites.  LotLinx Inventory Marketing Platform provides several channels to merchandise inventory at the VIN level. These channels include third party inventory listings sites ad placement on key consumer sites, Facebook, SEM and retargeting. We value you as a customer, vendor, or consumer. This document sets forth how we collect and use the information we collect and protect your privacy.

 

How to Contact Us and Concern Resolution.

If you have any questions, comments, concerns or complaints about privacy and the handling of your personal information, please contact us at our Customer Relationship Centre (CRC), canadasupport@lotlinx.com or 800-625-5469.  We are committed to working with you to obtain a fair and rapid resolution of any complaints or disputes about privacy and the handling of your personal information and are happy to respond to your questions and comments. If after contacting our CRC you still have unresolved concerns with respect to our handling of your personal information, please write to our Chief Compliance Officer at:

 

LotLinx Canada Ontario, Inc.

c/o LotLinx Canada Manitoba

307 – 155 Carlton Street
Winnipeg, Manitoba,
R3C 3H8

Re: Notice to LotLinx.ca

 

With a regular mailed copy to:

LotLinx, Inc.

200 West Madison Street, 13th Floor

Chicago, IL  60606

Attention: Notice to LotLinx, Inc./legaladmin@lotlinx.com

 

If you have completed the above process and we have been unable to resolve your concern, you may file a complaint with the Federal Privacy Commissioner of Canada or the appropriate provincial privacy officer. For more information, please go to  https://www.priv.gc.ca/en/.

 

Special Notice to citizens of the EU visiting any LotLinx or LotLinx-Affiliated Sites: LotLinx does not offer products or services to citizens of the EU nor do we collect personal information, as that is defined under the European Union’s General Data Privacy Regulation (GDPR). Independent third-parties may advertise on the LotLinx Site(s). LotLinx is not responsible for the privacy practices of these third parties, and we encourage you to visit their sites and read their privacy policies related GDPR policies. 

Why We Collect and How We Use Customer Information.

LotLinx Canada collects, stores and uses information about you for the following reasons:

  • to enroll you in the services you choose
  • to perform such services
  • to establish, maintain and improve our customer relationship with you, improve our products and services, and provide you with offers, incentives, marketing programs or promotional material about us and our products and services
  • to more effectively market to you our services by better understanding your automotive product needs and preferences
  • to assist in providing you valuable information about marketing your vehicle for sale or lease,
  • to conduct customer surveys and participate in market research studies conducted by third parties
  • to provide you with goods or services you request and respond to your comments, concerns or requests for information, such as through our websites (brochure fulfillment, emails, or other materials) or through our CRC
  • to provide you with offers and information about related automotive products offered by others which may be of interest to you
  • to meet our legal obligations, assist in law enforcement purposes, and protect the business interests of LotLinx Canada and our customers.

Monitoring of Contacts.
When you contact our CRC or when we contact you, it is our general practice to monitor and/or record such contacts for staff training and quality assurance purposes.

Personal information is retained as long as required to fulfill these purposes. We have established retention policies and procedures to ensure that when the retention period expires, your personal information will be removed from our systems and destroyed in a secure manner.

 

Types of Customer Information We Collect and Use.

We may collect the following types of customer information about you or relating to your automotive sales or service experience for the purposes set out above:

  • information which enables us to identify and communicate with you including name, address, phone number, e-mail address, language preference, and title
  • information which enables us to offer you products which better meet your needs and preferences
  • information about your vehicles including VIN, applicable vehicle incentives, new or used, lease or purchase, make, model, model year and vehicle details, photos and images
  • other information that you may provide us to continually improve the services we provide to you

 

How We Collect Customer Information.

  • Directly from You

We obtain information directly from you such as when you complete our enrollment form, use the services participate in testimonials or other research initiatives, promotions, campaign or event, or contact our CRC. We may also obtain information directly from you through our websites.

  • From Other Parties

We may acquire a list of names and addresses, which may include your name and address where you have given your consent, from list vendors to send promotions or product information to the names on the list. We also have relationships with third-parties with whom we conduct joint marketing activities such as contests through which we may obtain your name and address and other information about you with your consent. These activities clearly identify the other parties involved and provide information about their privacy practices. Any such other parties are bound by their privacy policy, not ours.

To ensure our database addresses remain accurate, we also obtain address information from third party licensed data providers for National Change of Address and other authorized parties.

 

How We Collect Information on Our Website and on our Affiliate Websites.

When you visit our website, we do not collect any personally identifiable information about you unless you provide it to us. Information on our site may be available for a user to review without providing us with any personal information. However, even if a user does not submit a name or address, it is possible for us to identify certain geographic and sometimes personal information through the users IP address. If a user does not agree with our privacy policy, we ask that they do not use our services or access our website.

 

When you visit this web site, other parties such as third-party advertising partners and analytics providers may collect information about your online activity over time and across websites. This information may include identifiers that may permit those parties to serve tailored ads to a device. For more information about third-party advertising partners’ collection and use of such data for interest-based advertising purposes (and opting out of such use), see “Interest-Based Online/Behavioral Advertising” below.

 

Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” (“DNT”) signals other than cookies, we do not currently respond to undefined “DNT” signals to this website.

 

Most browsers can be configured not to accept cookies, however, this may prevent you from having access to some functions or services on this website.

 

Non-personally Identifiable Information:

Through our websites, we collect non-personally identifiable information. This means that we do not track this information on a basis that identifies you but rather collect this information on an aggregate (or anonymous) basis that includes all site visitors. This information includes tracking the site pages that are visited or the amount of time spent on our site, clicks, page views, and information about your browser/system. Our primary goal in collecting aggregate information is to be able to perform site metrics that allow us to improve the functionality of the website. We collect aggregate information in order to compile aggregate and statistical data to help in website design and to identify popular features and measure site activity to allow us to update our site to better meet user wants and needs. We track page visits, perform site click through analysis, review peak site usage times and analyze layout and design. We may share these site metrics which are not personal information with our affiliated companies, service providers and others.

 

Our websites may also use session log data and non-personal data for the purpose of performing analytics on the user’s experience while visiting the site. This analysis:

  • Is performed on an aggregate level and does not identify you or your information personally
  • Involves the use of a third-party vendor acting on our behalf
  • Is performed in order to improve our website and the user experience
  • Includes the use of session and/or persistent cookies to track user movement across this and other LotLinx websites or to track other events within or across this and other LotLinx websites

Cookies, Web Beacons and Advertisements

Our website may use session and persistent “cookies,” session logs, spot light ads/web beacons/GIF/pixel tags, banner ads or links, third party networks that serve user-requested emails (e.g., a third-party email service provider for Tell-a-Friend user-customized emails), and third-party click tracking analytics tools (such as Adobe, DoubleClick, Efficient Frontier, and Google Analytics) to collect aggregate or other non-personally identifiable information about site visitors.

 

A “cookie” is a small text file that helps us in many ways to make your visit to our website more enjoyable and meaningful to you. For example, cookies avoid you having to log in every time you come back to one of our websites. They also allow us to tailor a website or advertisement to better match your interests and preferences. There are a couple different types of cookies.

 

A “session” cookie is stored only in your computer’s working memory (RAM) and only lasts for your browsing session. When you close all your browser’s windows, or when you shut down your computer, the session cookie disappears forever.

 

A “persistent” cookie is stored on your computer’s hard drive until a specified date, which could be tomorrow, next week, or 10 years from now. Persistent cookies stay on your computer until either a) they expire, b) they are overwritten with newer cookies, or c) you manually remove them. Most browsers can be configured not to accept cookies; however, this may prevent you from having access to some site functions or features.

This site may use a third party to activate and/or deliver a service, or deliver site functionality such as fulfilling your request for a product or service. In performing this function, the third party may place a persistent cookie on your computer or have to gather personal information from you in order to activate and deliver the product or service.

 

This website may use a third-party click tracking analytics tool (such as Adobe, and Google Analytics) to capture clickthrough statistics.

 

This website may use spotlight ads/web beacons/GIF/pixel tags which are site instrumentation tools that help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. Emails or electronic newsletters we send may use tools (e.g., pixel tags or web beacons) to gather email metrics and information to improve the reader’s experience such as how many of the emails are opened, if they were printed or forwarded, the type of device (e.g., mobile or PC) from which they were opened, and the city, province, and county associated with the applicable IP address. In general, any electronic image viewed as part of a webpage, including an ad banner, can act as a web beacon.

 

When you visit our website, the server housing the pages automatically generates a “session log.” We use session logs to help us determine how people travel through our site. In this way, we can structure our pages so that the information most frequently visited is easier to find. By tracking page visits, we can also determine if the information we’re providing is being used. The only data gathered is the Internet Protocol (IP) address from which you came (which contains no personal information), the website that referred you, the pages you visited and the date and time of those visits.

 

If you visit this site with an open ID, you may integrate with third-party social media sites, and we may track on an aggregate level the number of visits to this site with an open ID, the number of items “liked” on this site, or items on this site that you choose to share with a third-party social media site.

 

Users may be directed to our site via banner ads, site links or QR Codes. Ads, site links or QR Codes may use tools such as cookies or web beacons to deliver metrics on the effectiveness of the ads or links. They do not collect personally identifiable information from the user.

 

Interest-Based/Online Behavioral Advertising

On some pages of our site we may allow third-party advertising partners to set web tracking tools (e.g., cookies and web beacons) to collect anonymous, non-personally identifiable information regarding your activities on those pages (e.g., your IP address, page(s) visited, time of day). We may also share such information we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering future targeted advertisements to you when you visit other (non-LotLinx) sites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

 

Pages of our website that collect information that may be used by such advertising partners for interest-based advertising purposes are identified by a link to AdChoices on the page.

 

Opting out (site pages). If you do not want your browsing while on such pages to be used for interest-based advertising purposes, you may click on the AdChoices link to opt-out of such uses by the listed advertising partner(s). Even if you opt-out through this service, we may still collect non-personally identifiable information regarding your site activities and use it for non-interest-based advertising purposes as described in this privacy policy.

 

Opting out (advertisements). Advertisements on third-party sites that contain the AdChoices link and that link to this privacy policy may have been directed to you based on anonymous, non-personally identifiable information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes. Even if you opt-out through this service, we may still collect and use information from the advertisements for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

Opt-out Compliance Service. This site and advertisements on third-party sites that link to this privacy statement use the Evidon assurance service to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance of Canada (DAAC) (www.youradchoices.ca). When you opt-out on site pages or through such advertisements, Ghostery conveys your opt-out election(s) to the applicable advertising partner(s), which then know to place a cookie on your specific computer and browser (and only the specific computer and browser from which you opt out) indicating that you have opted out. If you clear your browser cookies and wish to remain opted out of interest-based advertising, you must opt-out again. The list of our advertising partners may be updated from time to time. To opt-out of internet-based advertising by all DAAC-participating companies, visit www.youradchoices.ca/

 

 

 

Collection and Use of Personally Identifiable Information on our Website.

There are instances where we request personal information such as name, address, phone number and e-mail address on our site, such as to provide you with a service, or correspondence (promotions and mailed brochures), or where you participate in interactive online activities. Any personal information collected is used as set out in this Privacy Policy.

 

Please keep in mind that if you disclose personally identifiable information through a chat room or message board or other public online forum, this information may be collected and used by others.

 

Links to other Websites.

Our website contains links to other websites. We encourage you to review the privacy statements of all sites which you visit, including those whose links are provided, so that you can understand how those sites collect, use and share your information. We are not responsible for the privacy statements, content or data handling practices on other websites.

 

 

How We Share Customer Information.

We do not sell or rent the personal information you provide us to third parties for their own independent marketing purposes or use without your consent, as required by applicable privacy laws.

We may transfer personal information to suppliers, service providers, contractors or agents (including our affiliates acting in this capacity) that perform services on our behalf such as mailing, customer service, call campaigns, marketing, information technology and/or data hosting or processing services or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these suppliers, service providers, contractors, agents or affiliates may be located outside of Canada, including in the United States and the Philippines. Specifically, we use a service provider in the United States to store and process all your personal information for the purposes described in this Privacy Policy, including providing information technology services to provide you with marketing material and surveys. We may also use service providers in the United States to conduct call campaigns. We require our suppliers, service providers, contractors and agents who have access to your personal information in connection with its processing or use for us to keep the information confidential and they are not permitted to use your personal information for any other purpose than to carry out the services they are performing for us. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by suppliers, service providers, contractors or agents are subject to legal requirements in Canada, the United States and other foreign countries applicable to them, for example, lawful requirements to disclosure personal information to governmental authorities in those countries.

To improve our products and services, we share your name, contact information and vehicle details with third parties who contact you to conduct market research studies on our behalf or on an industry wide basis and are contractually bound to only use your personal information for that purpose.

 

We may also disclose your personal information where we are required or permitted by law to do so. Where required by law, we will release personal information only to the extent required. In addition, personal information may be disclosed or transferred to a third party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of LotLinx Canada through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

  

How You Can Opt Out of Further Marketing Communications.

You may decide that you do not want us to send you marketing or promotional communications. Our marketing emails to you will include an unsubscribe which we will process within ten business days. For other marketing communications, such as direct mail, please contact our CRC at 800-625-5469 or via email at legaladmin@lotlinx.com. You may notify us at any time and your direction will be effective within 30 days. You may, however, no longer receive some offers or information of value to you. It is important for you to know that even if you choose to withdraw your consent, we will continue to use and disclose your personal information to meet legal and contractual obligations such as honor your warranty and send you recall notifications.

 

 

Security and Accuracy of Customer Information.

Safeguarding your personal information is important to us. We use systems, policies and procedures to maintain accuracy of information and to protect your personal information which is stored in the United States and the Philippines from loss, misuse, theft or alteration. Customer personal information is only accessible by appropriate personnel who have a business need for this information. We provide training to educate our personnel about our policies and procedures and appropriate handling of personal information. When you send personal information to our website, we use “Secure Socket Layers” (SSL) to protect your data. SSL is encryption technology that helps safeguard your personal information against misuse by unauthorized individuals.

 

We make reasonable efforts to keep your information up to date and accurate such as by using third party licensed data providers for National Change of Address. We encourage you, however, to contact our CRC at 800-625-5469 as often as necessary to keep your name, address and vehicle ownership information up to date.

 

 

 

Access to and Update or Correct Your Personal Information.

You may contact our CRC at 800-625-5469 to review, correct, or update certain of your personal information which is easily accessible to our service representatives at the CRC.

If you wish us to undertake a more comprehensive search of our files, you may notify us in writing at:

 

Attention: Chief Compliance Officer

LotLinx Canada Ontario, Inc.

c/o LotLinx Canada Manitoba

307 – 155 Carlton Street
Winnipeg, Manitoba,
R3C 3H8

Re: Notice to LotLinx.ca

 

With a regular mailed copy to:

LotLinx, Inc.

200 West Madison Street, 13th Floor

Chicago, IL  60606

Attention: Notice to LotLinx, Inc./legaladmin@lotlinx.com

 

You will be asked for sufficient personal information for us to verify your identity and the details about the personal information you are interested in prior to us processing your request. Information which may be accessible includes your contact information, demographic information, and information about your current or past relationship with LotLinx Canada. We will be unable to provide you with information which is exempt from disclosure such as personal information about another person, privileged information or confidential commercial information.

 

Effective Data and Revisions.

This Privacy Policy is effective April 19, 2018. Occasionally we may update this Privacy Policy to reflect changes to our practices. If we update this statement, the new statement will be posted to the website ten days prior to the changes taking effect. You may determine when this policy was last updated by referring to the modification date at the bottom of the policy.