PRIVACY STATEMENT
UPDATED DATE: August 20, 2024
EFFECTIVE DATE: January 20, 2024
INTRODUCTION & SUMMARY OF PRIVACY STATEMENT
Highroad is dedicated to helping all visitors to our Sites, including those that use and interact with our Services and connect with bidders, buyers, sellers, automobile dealers, affiliates, partners, and other third parties that come to the Site to learn about vehicles for sale and other information related to selling or buying a vehicle displayed on our Site(s).
We care about privacy at Highroad, and we believe in being transparent with consumers about our personal information practices. This Privacy Statement explains how Highroad collects, uses, discloses, and protects your personal information, as well as your rights regarding your personal information.
This Privacy Statement applies to the personal information Highroad may collect about you through websites, applications, social media, mobile interactions, software, and other services provided by or on behalf of Highroad (collectively referred to as “Sites” for shorthand purposes). This Privacy Statement only applies to our Sites and does not apply to information collected or received by other means. When you use or interact with the Services, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Statement.
Please be aware that Highroad’s Privacy Statement may not apply to the privacy practices of bidding entities, buyers, dealers, or Highroad partners and affiliates or links to third parties hosted on our Sites or any co-branded service. The foregoing party’s privacy statement may apply in addition to or in lieu of this Privacy Statement. For information regarding third-parties or business affiliates, please consult those entities for copies of their privacy policies
If you have any questions about our privacy practices, please contact us as set out in the “Contact Highroad” section below. If you are a California or Nevada resident, please see the relevant “Your California Privacy Rights”, or “Your Nevada Privacy Rights” section herein for additional disclosures. If you are resident of Virginia, Colorado, Connecticut, Utah, Texas or Oregon, please see “Your Other State Rights” section below for additional disclosures.
This Privacy Statement is a contract between you, the user or visitor to Sites (“you”, “user”), and Highrd Corporation, a Delaware corporation (“Highroad” or “Company”) and its subsidiaries and affiliates, including our Highroad website located at www.highroadx.net and any of Highroad applications, (collectively “Highroad”, “we”, “us” or “our”). Our Sites offer Highroad services (“Services”), but as stated above, may also include links to third-party sites, our business affiliates’ sites, and other information or services that are not operated by Highroad. This Privacy Statement explains how Highroad collects, uses, discloses, and protects your personal information, as well as your rights regarding your personal information that is obtained with our Sites.
You do not have to use our Services to be bound by this Privacy Statement. By visiting our Sites, you are consenting to our collection, use, disclosure, retention, and protection of information about you and devices you use as described in this Notice. We may continue to share your information as described in this Privacy Statement, even after you no longer use the Sites and/or end of your relationship with us.
INFORMATION WE COLLECT
Information You Give Us. We may collect and retain any information from you, or your devices provided to us when you visit a Site, including when you:
use our service or mobile application;
register for an account;
communicate with us, such as to provide feedback, request support, or ask for additional information; and
subscribe to content we offer.
We may collect information such as your first and last name, home or other physical address, email address, zip code, telephone number, your automobile’s make, model, trim, model year, mileage, color, options, vehicle identification number (“VIN”), license plate number, or information about your interactions with us or others, and other information.
Social Media. You may use social networks or other online services to access our Sites. When you do so, information from those services may be made available to us. By associating a social network account with our Sites, you agree that we may access and retain that information in accordance with the policies of the social network or other online service and this Notice. For example, we may be able to access account or profile information that you have provided to the social network or information about your interactions with the social network to make information available to us (such as when commenting on a blog post or using a sign-on service, such as TikTok, Instagram, and Facebook).
Automatically Collected Information. We may collect information automatically when you visit our Sites or use our mobile applications, such as:
your IP address; the type of browser, devices, and operating systems you use including imprecise geolocation;
identifiers associated with the device(s) you use to access our Sites;
the pages you visit, vehicles you view or configure, and the features you use, including dates and times;
if you navigated from or navigate to another website, the address of that website; and
information regarding your internet service provider.
your contact information (name, postal or email address, phone number, etc.);
your automobile’s make, model, trim, model year, mileage, color, options vehicle identification num (“VIN”), license plate number, or information about your interactions with us or others;
demographic information;
activity, use and interaction with our Services;
personal preferences; and
social media details and any other information you choose to share on those platforms.
In addition, we may collect information about your activities on our Sites via first and third-party cookies, clear GIFs or web beacons, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as Metrics Tools.
We may allow third parties to use Metrics Tools on our Sites. The information collected by Metrics Tools may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by Metrics Tools may be used on this Site or on other websites or services, including those that may not be operated by us. When You opt-out of cookies on our Sites, you may not be able to receive or access all functionalities. In addition, if You opt-out of cookies on our Sites, this does not act to opt You out of cookies if redirected to our Affiliate or other third party sites.
Email. We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if you follow a link in an email we send to you.
Mobile. We may collect session and geolocation information from your mobile device. Geolocation information includes data such as your device’s physical location and may include GPS-based, Wi-Fi-based or cell-based location information.
Information from Other Sources. We may obtain information about you from affiliates, partners, automobile dealers and other third parties. This information may include information about your use of this Site or our services, your use of other websites, your interactions with or purchases from automobile dealers, your interests and preferences and other information about you or your household. We may combine the information we obtain from third parties with information that we or our affiliates have collected about you.
We may collect and retain any information from you, or your devices provided to us when you visit our Site(s), mobile application, register an account, communicate with us such as to provide feedback, request support, or ask for additional information.
Information About You.
The information that you provide directly to us and that we obtain from others is what we need to serve you, our affiliates and business customers. This information may include your contact details (such as name, postal and email addresses, phone number, social media handles and other online aliases); information specific to the Service you request (such as financial information when you apply for credit); details about your vehicle (such as performance and location information), information about your Dealer transactions (including phone calls, chat transcripts, and other details); contact information of individuals with whom you would like to share Highroad content; social media information; demographic and household information; your responses and engagement with our Services; and other information you may choose to share with us by interacting with our Services or with our affiliates, business customers, suppliers or other businesses that share information with us.
Information About Your Device.
The information we collect by automated means also helps us, our affiliates and our business customers to provide and tailor various products and services. Examples of information we collect by automated means include the following:
Usage Information.
We and our suppliers may automatically collect your usage activity, preferences, and browser details (such as your IP address and browser type), as well the ID and type of the device you use to connect or interact with our Services, and other details about your use or interaction with our Services. This may also include the collection of information about your online activities over time and across third-party websites or online services and across devices that you use.
Location Data.
Some of our Services may collect imprecise geolocation data to provide or improve our Services and location-related functionality, such as the location of your nearest Dealer, and your imprecise location while at a Dealer or near a Dealer’s location. We may link location data to other information we have collected about you.
HOW WE COLLECT INFORMATION
We collect information about you from a variety of sources, including:
· details you choose to provide via our Services;
· from our affiliates;
· from our business customers;
· from other outside sources (i.e. suppliers, third parties); and
· automatically, from devices that you use to connect or interact with our Services.
Information You Provide.
We and our suppliers collect the information you voluntarily provide to us in connection with using our Services, including
through product inquiries (including phone calls, chat transcripts, and other details), requests for vehicle information, financing requests, technical services or questions, product registration and support, events and promotions, job applications, and other inquiries and transactions. Our suppliers also may collect information from you, including, for example, when you participate in our contests, sweepstakes, surveys, and other promotions. Some portions of the Services may allow you to submit comments, reviews, ratings and other content.
Information We Obtain from Affiliates, Business Customers, Suppliers and Others.
We may obtain information about you from outside sources. For example, our affiliates, Dealers, and Dealer Associations that deploy Highroad products and Services and suppliers may share with us certain information you provided to them or collected by using their website. They may also inform us whether you have been approved for credit and related information. We also may obtain demographics, user preferences, imprecise geolocation, and other information about you from other parties. If you engage via social media with us, our affiliates, our business customers, or our suppliers, the social media platforms may share certain information with Highroad. You may be able to adjust your social media privacy settings to limit the sharing of your social media data.
Information We Obtain by Automated Means.
We may collect information about your use or interaction with our Services or about the devices you use to connect or interact with the Services by automated means, including tracking technologies. These tracking technologies may include “cookies,” which are small lines of text/data that are written onto your device by a website. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. Highroad and suppliers acting on our behalf may use cookies, pixel tags, beacons, Bluetooth and Wi-Fi monitoring and other technologies to operate the Services. Cookies we use may redirect you to other websites. With your consent, we may also use video technologies to capture your demographic information and engagement with our Services in order to present you with a more personalized experience.
Browser cookie controls.
Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. You can also choose to limit the information shared with social media, advertising, and analytics partners.
Mobile advertising ID controls.
Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID.
HOW DOES HIGHROAD USE INFORMATION
We and others acting on our behalf may use the information that we collect or receive to operate our business, including our Sites, as described below:
Operate and Support our Sites and Services. We use the information that we gather in order to operate our Sites and our services and share your information with contractors and other service suppliers assisting in operating our business. For example, we may use the information that we collect or receive to share with support and assistance that you request or to diagnose or address technical problems in the operation of our Sites or any of our services. If you establish an account with us, we may use information about you to manage or support your account. We may identify your use of our Sites across devices, and we may use information we collect from you and receive from others to optimize your use of the Sites and our services as you use different devices.
Improving and Evolving our Services. We constantly evaluate and improve our Sites and services; including developing new products or services and use the information we gather to do so.
To Allow You to Connect with Potential Bidders, Buyers, Sellers, Dealers and Affiliates. When you use our service, and after you provide your contact information to request offers or information, we may use the information you provide us to connect you with potential buyers and sellers, reserving the right to connect you with a limited number of the foregoing. These bidders, buyers, and our affiliate partners may offer you savings certificate, offers and/or incentives for vehicles offered for sale or other products or services. When you choose to share your contact information directly with bidders, buyers, and other affiliates, your direct interactions with those entities will not be controlled by this Privacy Statement . You should review the applicable notices of those entities to understand how they may use your information.
To Allow You to Connect with Lending Institutions. Our Sites and services may permit you to provide information relevant to assessing your creditworthiness or designed to facilitate financing (for example, in connection a potential vehicle lease or purchase). Your direct interactions with lending institutions will not be controlled by Highroad or this Privacy Statement. You should review the applicable notices of those lending institutions to understand how they may use your information.
Advertising and Promotions. We may use the information we gather to offer, provide, or personalize products and services from us and third parties. For example, we may customize content, advertising, promotions, and incentives to reflect your preferences, interests, or prior interactions with us and others. We are not responsible for advertising and promotions provided by our Affiliates that may display content on our Site.
Other Contacts; SMS; and Texting Consent. By using any of our Sites or Services you acknowledge and agree that you have opted in to allowing Us to contact you through telephone, text, or chat for other purposes, as permitted by law. This Privacy Statement only addresses our own information practices. This Privacy Statement does not apply to information you share with third parties, including but not limited to dealers and lending institutions, even if we link to those third parties from a Site. These third parties may have their own privacy policies governing their use of information that you can access from their websites. Our services may be offered through third party websites or mobile applications (“Partner Sites”). This Privacy Statement does not apply to Partner Sites, unless otherwise indicated on the Partner Site.
Please note that other parties may collect personally identifiable information about your online activities over time and across different websites when you use our Site.
Other Uses.
We may also use the information we collect to:
· communicate with you unrelated to the Sites or Services under certain circumstances;
· analyze the development of new products and services;
· facilitate Highroad employee recruitment; and
· comply with applicable laws, rules and our policies
WHEN DOES HIGHROAD SHARE INFORMATION
A primary use of your information is to serve you, which requires certain sharing with our affiliates and business customers. The following are examples of the types of general purposes for which we may use your information.
As more detailed below, We may share the information we collect:
· within our enterprise;
· with our suppliers;
· with our affiliates, Dealers, Dealer Associations, and business customers;
· with our marketing partners;
· with third parties;
· as we otherwise may notify you; and
· if Highroad or its assets are acquired.
Corporate Affiliates. We may share information with our corporate affiliates for their everyday business purposes, to provide services or to perform marketing. We may also participate in joint ventures with others, and we may share information as part of that joint venture.
Partner Sites. We may share the information we gather with Partner Sites (and the owners of those sites). For example, we may share information for determining or verifying our economic rights and obligations.
Service Providers. We may share information with third party service providers who help us operate our business or provide services on our behalf, including third parties who help us operate our Sites. These service providers include analytics companies and advertising networks that provide Metrics Tools on our Sites.
Promotional. We may share information with third parties to help us promote our products and services, or to help us customize advertisements, offers, or other communications to you.
Business Transfer. We may share information we have collected from you in connection with the sale or merger of our business or the transfer of assets.
Protection of Ourselves and Others. We may use and share the information we gather to enforce our rights and protect our property and those of our affiliates, customers, and members of the public, to comply with applicable law, legal process, legal advice and for preventing fraud, theft, and injury to you, us, or others.
Service Insight.
We may, for example, use information collected and shared through cookies and similar technology to better understand how our Services are used, develop new offerings, or personalize your experience when using the Services.
Customer Service.
If you request support or other information, we may use your information to respond to your request and share it with a customer service representative. We may also follow up with you to notify you periodically about important topics, like Services updates or changes to our Privacy Statement.
Marketing.
We may use your information to let you know about current offers, invite you to participate in those offers and manage your participation in them. We also may use information about you, your use or your interaction with our Services to tailor our offers to your preferences or to offer you products and services that we believe may be of interest to you. Dealers, Dealer Associations, and our affiliates may use your information for their own marketing purposes. Among other privacy choices described in this Privacy Statement, you may direct us to not send you email marketing communications by clicking on the unsubscribe link included in the emails you receive from us or texting back to us as directed (e.g. “Stop”).
Compliance with Legal Requirements, Rules and Internal Policies.
We may be required by law or internal data retention policies to maintain information about you for a certain period of time, or to notify you of a security breach. We also may be required by social media platform rules (such as Facebook) to handle the social media information you or the platform share with us in a certain manner. A primary use of your information is to serve you, which requires certain sharing with our affiliates and business customers. This section describes the types of organizations with whom we may share your information.
Within Highroad.
Highroad may authorize access to your information within our enterprise, by our employees and other personnel, to fulfill our obligations to you and to operate our business.
Affiliates, Dealers, and Dealer Associations.
Our affiliates, Dealers, and Dealer Associations may access and use your information for the purposes we describe in this
Privacy Statement. We may also allow our affiliates, Dealers, and Dealer Associations to have access to your information and to use aggregate statistics – statistics not linked by us to any specific consumer – about consumer behavior, sales, online activity patterns, and related Services information. Except as necessary to provide you with the Services, we will not provide our affiliates with personal financial information that we obtain when you use the Services to submit a request for credit.
All the above categories exclude text messaging originator opt-in data and consent, which we receive from Highroad
employees, contractors, and/or Dealer contacts. Such data will not be shared with any third parties, provided that the foregoing does not apply to sharing (1) with suppliers, consultants and other service providers who need access to such information to carry out work on our behalf (and who will not use such information for their own purposes); (2) when we believe disclosure is required by any applicable law, rule, or regulation or to comply with law enforcement or legal process; and/or (3) when the user consents to our sharing of such information.
Suppliers. We disclose personal information to suppliers working on our behalf for the purposes described in this Privacy Statement, including as necessary to provide functionality, products, and services to us and you in connection with the Services. Highroad requires suppliers to process your information under the direction of Highroad and in accordance with contractual restrictions and applicable law.
Marketing Partners.
We may share your information with our marketing partners when, for example, at some point we may participate in a co-branded promotion with another company. Other than as described in this Privacy Statement, we will not share your information with suppliers for their own marketing purposes. Except as necessary to provide you with the Services, we also will not provide our marketing partners with personal financial information that we obtain when you use the Services to submit a request for credit.
Analytics and Advertising. We may share your information, including data collected through cookies and similar technology, with third-party businesses for analytics and advertising related purposes. Third-party businesses may act as our suppliers, or in many contexts, independently decide how to process your information. Please see the “Data Collection and Use by Third Parties” section for a description of how we work with third-party businesses.
Your Public Comments.
Some portions of our Services may allow you to submit comments, reviews, ratings, and other content. You agree this content may be displayed on the Services and may be viewable by other users of the Services or the public generally.
Mergers, Acquisitions or Insolvency.
If Highroad should ever file for bankruptcy or merge with another company, or if Highroad should decide to buy, sell, or
reorganize some part or all of its business, Highroad reserves the right to disclose your information, including to prospective or actual purchasers in connection with one of these transactions.
As Required by Law and Other Disclosures.
Highroad may be required to disclose your information if it:
· believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority;
· would potentially lessen our liability in an actual or potential lawsuit or investigation;
· as allowed under state or federal law; or
· is necessary to protect our or others' rights or property.
YOU HAVE CHOICES REGARDING YOUR INFORMATION
You may limit and control the information provided to us in several ways, however, you may not be able to use all features of our Sites if you limit the information you share with us.
For example, you can choose not to access our Sites through your social media account. You may also be able to limit the information provided to us by third party social media providers by altering your privacy settings with those providers. You may unsubscribe from promotional emails from us by following the unsubscribe link included in each such email. You may stop receiving SMS/text messages from Highroad by texting Us as indicated.
Your browser and your device may provide you with the option to limit the use of cookies or other Metrics Tools. You should consult documentation for your browser or device for more information. Your mobile device may have settings that allow you to prevent sharing geolocation information with us. You should consult your mobile device’s settings or help documentation for more information about exercising these options.
Highroad uses Google Analytics, which helps us better understand our audience and target communications and advertisements based on demographic or interest-based information. You may learn more about opting out of certain Google advertising initiatives here and here. You may also be able to opt out of certain targeted behavioral advertising via the Network Advertising Initiative’s opt-out.
INFORMATION ON SECURITY
We take reasonable measures to secure our systems and protect your personal information. When we receive your personal information, we securely store and protect your information from unauthorized access and use with the highest security measures that comply with applicable law. These measures include computer safeguards and physical controls. However, data transmissions over the Internet and otherwise can never be guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us, and you do so at your own risk.
By providing your email address or mobile number to us or using the Services, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically, as permitted by applicable law. You may have a legal right to receive this notice in writing.
CALIFORNIA, NEVADA, VIRGINIA, COLORADO, CONNECTICUT, UTAH, TEXAS, OR OREGON RESIDENTS
If you are a California, Nevada resident, please see the relevant “Your California Privacy Rights”, or “Your Nevada Privacy
Rights” section below for additional rights. If you are a resident of Virginia, Colorado, Connecticut, Utah or Oregon resident please see the “Your Other State Privacy Rights” section below for additional rights.
Other Information.
To the extent permitted by applicable law, we may use or disclose non-personal information, aggregated information, de-
identified or pseudonymized information, and statistical information for any lawful purpose, and any obligations or restrictions contained in this Privacy Statement do not apply to such information.
Children.
Our Services are not directed at children or intended to be used by children. Do not send any information about yourself to us if you are under the age of sixteen (18). In addition, if we learn a person under the age of thirteen (13) has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately at privacy@highroadx.com .
Retention of Your Information.
We retain each category of personal information, in accordance with this Privacy Statement and with our records retention policy for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to provide Services, comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
Changes To This Privacy Statement.
In the future, we may change our Privacy Statement, and we will post the new Privacy Statement on www.highroadx.com. You agree to the new Privacy Statement by continuing to use or interact with the Services unless prohibited by law.
Non-U.S. Users.
This is a U.S. website, and this site and our Services are subject to U.S. laws, including those governing the privacy and security of your information. Our Sites and Services are intended for use solely in the United States (including its territories and commonwealths). We make no claims that the Sites and Services are appropriate for use outside of the United States. Highroad does not knowingly collect or solicit Personal Information from residents of the European Union, United Kingdom, Switzerland, or any other jurisdiction other than the U.S. If you believe that We may have any Personal Information from or about a non-U.S. or Canada resident, please email us at privacy@highroadx.com. No information should be submitted to Us or any entity on our Sites by any resident from outside of the U.S.
YOUR CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”)
The CCPA provides additional rights to California residents. These additional disclosures address those rights and apply only to California residents. Any rights specifically relating to the California Privacy Rights Act took effect on January 1, 2023. If you are a California resident and the processing of personal information about you is subject to the CCPA, you have certain rights with respect to that information.
Categories of Personal Information. Below please find the categories of personal information we have collected in the past 12 months, although “Examples” do not represent information We collect each time you visit our Sites:
For more information on information we collect, including the sources from which we receive information, review the
“Information We Collect” section above.
Purposes for Collecting and Using Personal Information. Generally, Highroad may use some or all of the above categories of personal information for its business and commercial purposes. For more information with respect to how we use your
information, review the “How We Use Your Information” section above.
CATEGORIES OF THIRD PARTIES WITH WHICH WE MAY SELL OR SHARE PERSONAL INFORMATION
In the past 12 months, Highroad has disclosed the personal information to the following categories of third parties:
· website analytics providers (e.g. Google, Adobe etc.);
· marketing and advertising partners;
· Dealers; and
· Affiliates.
Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the
CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under the CCPA to include a disclosure for cross-context behavioral advertising. For details about your rights regarding sales and shares, please see below.
CATEGORIES OF PERSONAL INFORMATION WE HAVE SOLD OR SHARED
In the past 12 months, Highroad has sold or shared the following categories of personal information:
· identifiers;
· commercial information;
· personal information categories listed in the California Customer Records statute;
· internet or other similar network activity;
· non-precise geolocation data; and
· inferences drawn from other personal information.
Sensitive Personal Information.
To the extent any of the personal information we collect is sensitive personal information, we collect, use, and disclose such
sensitive personal information only for the permissible business purposes for sensitive personal information under the CCPA. We do not sell or share sensitive personal information to third parties unaffiliate with the Services You asked Us to perform.
Information Security.
For information on how we safeguard your personal information, review “Information Security” section.
Retention.
For information on how long we retain your personal information, review the “Retention of Your Information” section.
ACCESS/RIGHT TO KNOW
You have a right to request that we provide you with the following information
· specific pieces of personal information that we have collected about you;
· categories of personal information we have collected about you;
· categories of sources from which the personal information is collected;
· categories of personal information that we sold or shared or disclosed for a business purpose about you;
· categories of third parties to whom the personal information was sold or shared or disclosed for a business purpose; and
· business or commercial purpose for collecting, sharing, or selling personal information.
Right to Correct.
You have a right to request that we update or correct your personal information.
Right to Delete.
You also have a right to request that we delete your personal information under certain circumstances, subject to a number of exceptions.
Right to Opt-Out of Sales and Sharing.
To the extent we sell or share your personal information to third parties as those terms are defined under CCPA, you have a right to opt-out from the sale or sharing, which you can exercise through this logging into My Account on the highroadx.com Site or contacting Us at privacy@Highroadx.com.
Do Not Track Disclosure.
We do not respond to a user's DNT browser setting, We cannot control the DNT handling of third parties interacting with your site, such as Google Analytics, AdWords and others.
HOW TO EXECERCISE YOUR CCPA RIGHTS.
To exercise your CCPA rights you must submit in writing Your request by email privacy@Highroadx.com or writing to:
Attention: Privacy, Highrd Corporation d/b/a Highroad, 11854 Bradburn Boulevard, Westminster, CO 80031
If you want to exercise more than one of your CCPA rights, please submit a separate request for each CCPA right, which will help us handle your requests more effectively. Please be aware that we will process your requests in the order we receive them. We will endeavor to confirm receipt of your request within 10 days and respond to verified and valid requests within 45 calendar days.
Please be aware that there might be circumstances where we will not honor your request, as permitted under the CCPA. For example, if we are not able to verify your identity or you are not a California resident, we may not honor your access, correction, or deletion request. In addition, we may not delete your personal information if an exception under the CCPA applies.
If personal information about you has been processed by us as a service provider on behalf of a Dealer and you wish to exercise any rights you have with such personal information, please inquire with the Dealer directly. If you wish to make your request directly to us, please provide the name of the Dealer or other entity on whose behalf we processed your personal information. We will refer your request to the Dealer and will support them to the extent required by applicable law in responding to your request.
Whether you use the email or ground mail, Highroad will need information from you to process your request so that we can confirm you are a California resident, determine if we have personal information about you, and, for access and deletion requests, verify your identity. Highroad may also need to contact you about your request, and you can choose the contact method you would like them to use.
California Minors
Highroad does not knowingly sell the personal information of minors under 18 years of age without consent.
Non-Discrimination
Highroad will not discriminate against you for exercising your rights under CCPA, including denying you goods or services; providing a different level of goods or services; or charging you different prices or rates for goods or services.
Disability Notice
If you have a disability and would like to access this Privacy Statement in an alternative format, please contact us at privacy@highroadx.com.
Business-to-Business Notice.
This business-to-business notice (the “B2B Notice”) applies to personal information Highroad collects, uses, and shares of California residents who interact with Highroad as an employee, owner, director, officer, or independent contractor of another company, partnership, sole proprietorship, non-profit, or government agency (collectively, “Entity”). For information on our data practices, please see above. If you like to submit a request relating to your personal information in B2B context, please submit a request through privacy@highroadx.com. You may be required to submit evidence to verify your identity to process your request.
CALIFORNIA “SHINE THE LIGHT” LAW
Under California’s “Shine the Light” law, California residents may also request that we provide to you:
· a list of the categories of personal information about you that Highroad has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request; and
· a list of the categories of third parties to whom we disclosed such personal information.
To submit your request, please email privacy@highroadx.com and reference “Shine the Light” in the subject line or if you write to us at the address above, note on the correspondence Attn: “Shine the Light”.
YOUR NEVADA PRIVACY RIGHTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated email address: privacy@highroadx.com or writing to:
Attention: Nevada Privacy, Highrd Corporation d/b/a Highroad, 11854 Bradburn Boulevard, Westminster, CO 80031
Your Other State Privacy Rights
This section applies to the laws of the following states which provides additional rights to the residents of these states:
· Virginia Consumer Data Protection Act (“VCDPA”) effective January 1, 2023;
· Colorado Privacy Act (“CPA”) effective July 1, 2023; and
· Connecticut Data Privacy Act (“CTDPA”) effective July 1, 2023.
· Utah Consumer Privacy Act (“UCPA”) effective December 31, 2023.
· Texas Data Privacy and Security Act (“TDPSA”) effective July 1, 2024
· Oregon Consumer Privacy Act (“OCPA”) effective June 23, 2023
This section addresses those rights and applies only to the residents of the states listed above. Any rights shall not take effect until the stated effective date.
You have the following rights under these laws:
· To confirm whether or not we are processing your personal data;
· To confirm how we process your personal data
· To access your personal data;
· To correct inaccuracies in your personal data;
· To delete your personal data; or
· To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format; and
· To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or
· Opt out of profiling or targeted advertising.
Other State Laws. You can exercise or inquire about your rights by submitting your request(s) by email privacy@highroadx.com or writing to:
Attention: State Law Privacy, Highrd Corporation d/b/a Highroad, 11854 Bradburn Boulevard, Westminster, CO 80031
We will respond to your request in accordance with the applicable state law.
Right to Appeal.
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@highroadx.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the
decisions. If the appeal is denied, you may submit a complaint to the Attorney General of your state as follows:
· For Colorado residents, to the Colorado AG at https://coag.gov/file-complaint/
· For Connecticut residents, to the Connecticut AG at https://www.dir.ct.gov/ag/complaint/.
· For Virginia residents, to the AG at https://www.oag.state.va.us/consumercomplaintform.
· For Utah residents, to the AG at https://services.dcp.utah.gov
CONTACTING HIGHROAD
If you have any questions, comments, or concerns about our information practices or this Privacy Statement, please email us at privacy@highroadx.com or write to us at:
Attn: Data Privacy
Highrd Corporation d/b/a Highroad, 11854 Bradburn Boulevard, Westminster, CO 80031