The Northern California Honda Dealers Association (“Association,” “we,” “us” or “our”) respects the privacy of the information you have entrusted to us. This Privacy Policy (“Policy”) applies to the online collection of personal information by the Association. By using our website and services (collectively, the “Services”), you acknowledge you have read and understand the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use our Services.

PLEASE NOTE THE ARBITRATION PROVISION SET FORTH BELOW, WHICH REQUIRES, EXCEPT WHERE AND TO THE EXTENT PROHIBITED BY LAW, YOU TO ARBITRATE ANY CLAIMS YOU MAY HAVE AGAINST THE ASSOCIATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY.

INFORMATION COLLECTED
“Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Under the California Consumer Privacy Act, we must provide a disclosure of covered types of personal information we have collected from consumers over the last 12 months:

Category of personal data	Disclosure to third parties	Disclosure to Service Providers
Identifiers, such as:  Name, postal address, email address, IP address, driver’s license or other similar identification numbers.	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	To Service Providers for administrative and operational assistance
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as: any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, or description, address, telephone number, identification information, or other personal information	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	To Service Providers for administrative and operational assistance
Protected classification characteristics under California or federal law, such as: For example: A photocopy/scan of government issued forms of identification Protected classes such as race, religion, sexual orientation, gender identity, gender expression, age	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	To Service Providers for administrative and operational assistance
Commercial information, such as: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	To Service Providers for administrative and operational assistance
Biometric information, such as: Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data	N/A	N/A
Internet or other electronic network activity information, such as: Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	To Service Providers for administrative and operational assistance
Geolocation data, such as: Physical location	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	To Service Providers for administrative and operational assistance
Sensory Information, such as: Audio, electronic, visual, thermal, olfactory, or similar information	N/A	N/A
Employment Information	N/A	N/A
Education information, such as: Information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)	N/A	N/A
Inferences, such as: Inferences that could be used to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	To business partners such as affiliated dealers, vehicle manufacturer, third party service providers to administer services performed by them on behalf of Association To state or federal agencies, when required by law	N/A

Categories of sources from which the personal information is collected

Directly from our users when they submit a lead form or other web form on the site. Indirectly from consumers (e.g., from observing consumers’ actions on our Services) Third-parties, including analytics providers, data aggregators, affiliated dealers, vehicle manufacturer, or third parties that interact with us in connection with the services we perform.

Business or commercial purpose for collecting personal information:

To send informational and marketing communications, respond to requests and inquiries, and communicate with consumers regarding products or services To forward leads to affiliated dealers and/or manufacturer

Parties to where we may disclose personal information:

To affiliates including but not limited to automobile dealers To the vehicle manufacturer To service providers To other third parties which you authorize in connection with the services we provide

Use of Personal Information

The personal information we collect may be used for the following business purposes: To provide you with vehicle information and incentives, To provide you with information about promotions or offerings, To email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you, To provide you with information about promotions or offerings, To improve our website and present its contents to you including the powering of products and features used throughout the site, To provide you with information about promotions or offerings, To assist in ad serving, targeting and retargeting, creation of audience segments, and related online behavioral advertising purposes, To create inferred search preferences and inclination/intent to purchase certain vehicles or makes/models for improved ad targeting and custom experience implantation, To assist in monitoring site optimization including product development, To assist in testing, research, analysis and product development, To protect the rights, property or safety of us, our clients or others, To respond to law enforcement requests or as required by law.

COOKIES AND THIRD PARTY ADVERTISING

We, or third parties, use cookies and other similar technologies. Cookies are small text files placed on your device that uniquely identify your device and which a website can transfer to a consumer’s hard drive to keep records of his or her visit to a website. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which are explained below:

• Essential. Some cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, we cannot enable appropriate content based on the type of device you are using.

• Analytics. We use Google Analytics to measure how you interact with our website and to improve your user experience. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page at https://support.google.com/analytics/answer/6004245?hl=en

• Target Advertising. We use cookies to compile information on our users interaction with our website. We use this information to serve ads to you off of our website.

There are several ways to manage cookies. You can control the use of cookies at the browser level, by instructing your browser to accept cookies, disable cookies or notify you when receiving a new cookie. Please note that if you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

COLLECTION AND USE OF INFORMATION FROM CHILDREN

Our Services are not intended for children. We do not knowingly collect personal information from children, and none of our Services are designed to attract children. In the event that we learn that a person under the age of 13 has provided personal information to us, we will delete such personal information as soon as possible.

UNSUBSCRIBE

We provide you the opportunity to opt-out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided below. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. Additionally, we may send you information regarding our Services, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature, rather than promotional.

THIRD-PARTY LINKS

Our website contains links to other sites including but not limited to affiliated dealers. The Northern California Honda Dealers Association is not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information, once a year, regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email using the contact information provided below and put “Shine the Light Request” in the subject line of your email.

From January 1, 2020, you may have the following rights:

We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.

SECURITY

We implement reasonable security measures to ensure the security of your personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

INTERNATIONAL DATA TRANSFERS

The Association is based in the U.S.. If you choose to provide us with information, please understand that your personal information may be transferred to the U.S. and that we may transfer that information to our affiliates or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the EU or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the U.S. and other jurisdictions which may not have the same data protection laws as the EU. We put in place appropriate measures to ensure the protection of your personal information. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Policy; and (ii) your personal information may be transferred to the U.S. and other jurisdictions as indicated above, in accordance with applicable law.

DISPUTE RESOLUTION AND AGREEMENT TO ARBITRATE

Except where and to the extent prohibited by law, by using the Services, you and the Association agree that, if there is any controversy, claim, action, or dispute arising out of or related to your use of the Services or the breach, enforcement, interpretation, or validity of this Policy or any part of it (“Dispute”), both parties shall first try in good faith to settle such Dispute by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party thirty (30) days in which to respond to or settle the Dispute. Notice shall be sent to:

You agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS IN CALIFORNIA. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY. Other rights that you and we would otherwise have in court will not be available, or will be more limited in arbitration, including discovery and appeal rights. All such disputes shall be exclusively submitted to the American Arbitration Association https://www.adr.org/ for binding arbitration under its rules then in effect, before one arbitrator to be mutually agreed upon by both parties.
The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising under or relating to the interpretation, applicability, enforceability, or formation of this Policy, including any claim that all or any part of this Policy is void or voidable.

VENUE CHOICE OF LAW

This Policy has been made in and shall be construed in accordance with the laws of the State of California, without giving effect to any conflict of law principles. Any disputes or claims not subject to the arbitration provision discussed above shall be resolved by a court located in the State of California and you agree and submit to the exercise of personal jurisdiction of such courts for the purpose of litigating any such claim or action.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Policy from time to time. When we do, we will also revise the “Date last updated” at the top of this Policy. If we make material changes to the Policy, we will notify you by placing a prominent notice on our website and/or by sending you an email at the email address we have on file for you. We encourage you to periodically review this Policy to keep up to date on how we are handling your personal information.

CONTACT US

If you have any questions, comments or concerns about our privacy practices or this Policy, please contact us at: Baker Street Advertising, 15 Lombard St., San Francisco, CA 94111.