Last Updated: December 2022
Wash Depot Holdings, Inc. (“Company,” “we,” “our,” or “us”) takes your privacy seriously. We want you to know how we collect, use, share, and protect your Personal Information. If you are a California resident, please refer to Your Rights section below.
SOME HELPFUL TERMS
Personal Information" is any information that can be used to identify you, either alone or in combination with other information. Examples of Personal Information include name, email address, and phone number. Personal Information also includes certain information that we collect from you when you sign up for our Unlimited Wash Club membership, Email Club, complete online surveys, and otherwise for us to provide services to you.
"Cookies" are text files, typically small in size, that are placed on your computer by a webpage server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookies to you. There are different type of cookies, and some cookies may be necessary for the website to run properly.
"Aggregate Information" is information that has been combined with information about other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified. For example, Aggregate Information may include a statement that says "50% of our users have visited our website in the last month".
HOW WE MAY COLLECT AND USE YOUR PERSONAL INFORMATION
We collect your Personal Information when we deliver our services, conduct marketing activities, gather feedback, provide customer support, and run our business operations. The Personal Information we collect varies based upon whether you are using our website, our services, purchasing our products or participating in surveys and providing feedback.
For the information that you provide to us during sign up or when you set up an account or profile, sign-up for our Email Club, purchase our Unlimited Wash Club membership, or otherwise use our services, we may collect information such as your name, email address, mailing address, birthday, vehicle information, and other information that may help us better service you.
We may also collect Personal Information from your use of our services. This information may include:
In addition to the purposes listed above, we may also use your Personal Information to:
We may also gather non-descriptive, non-identifiable statistical information about how many visitors use our services, how our users use the services, how our users access certain content available on our websites and social media pages, how long our users access certain content, what content our users are accessing, and our user preferences or settings for certain services. We use this Aggregated Information for statistical analysis of how users make use of the services so we can better improve our services.
DATA COLLECTION TECHNOLOGIES
Although most browsers and devices accept Cookies and other Data Collection Technologies by default, their settings usually allow you to clear or decline Cookies. If you disable Cookies, some of the features of our services may not be available or function properly.
Interest Based Advertising: We may use vendors to serve advertisements on our behalf across the Internet. These advertising vendors may collect (through the use of Data Collection Technologies) non-identifiable information about your visits to and interactions with our services. In addition, our vendors may also use the information about your visits to other websites to target advertisements for products and services available from us. If you would like more information about this practice, please visit the Network Advertising Initiative (NAI) at http://optout.networkadvertising.org/?c=1#!/
Please note: Some web browsers incorporate a "Do Not Track" feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.
SHARING YOUR PERSONAL INFORMATION
Because we know your Personal Information is important to you, we may share your information for the reason(s) disclosed to you at the time we collect it, with your consent, as well as in the following ways:
Your preferences about how we use your information are important to us and, when possible, we aim to honor them. We offer the following choices that you can exercise with regard to your Personal Information.
PROTECTING YOUR PERSONAL INFORMATION
We use reasonable organizational and technical security measures designed to preserve the security of your Personal Information, including without limitation, encryption technologies and authentication tools. Note, however, that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to or from our services.
We respect the privacy of children. Our services are not designed to attract an audience younger than 16, and we do not knowingly collect Personal Information from children under 16. Please contact us using the contact details below if you believe we may have collected information from your child, and we will work to delete it.
YOUR CALIFORNIA PRIVACY RIGHTS
This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see [Privacy Notice to California Applicants and Employees)]
• How to Exercise Your Rights
• How We Will Verify Your Requests
• Requests by Authorized Agents
• The Company's Non-Discrimination Policy
• Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes
• Your "Do Not Track" Browser Setting
• Third-Party Links and Services
• Minors Under 13 Years of Age
• For More Information
Assistance For the Disabled
Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at email@example.com for assistance.
What Is Personal Information?
"Personal Information". "Personal Information" means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer, household, or device.
Whose Personal Information Is Covered by This Policy?
Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data.
o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
• Individuals who are NOT California residents.
• California residents who are Company's employees, job applicants, or contract workers (collectively, "HR Individuals"), or the emergency contacts of HR Individuals or the dependents or spouses who receive Company benefits by virtue of their relationship to an HR Individual in their capacities as HR Individuals or emergency contacts, dependents, or spouses; or
• California residents who are employees or other agents of a business engaged in a transaction with Company in their capacities as employees or agents of that business.
The Company's Collection, Use and Disclosure of Personal Information
Categories Of Personal Information Collected
In the last 12 months, Company collected the following categories of Personal Information about California Consumers:
• Identifiers, including real name, mailing address, email address, birthdate, zip code, vehicle information (e.g., vehicle make, model, color and year), internet protocol address.
• Commercial information, including products and services purchased, service date, price, and frequency of visit.
• Internet or other electronic network activity information, including browsing history, search history, information on a consumer's interaction within our website, or device information from connection with Wi-Fi
• Sensory information, including video surveillance
• Financial Information, including credit card numbers and related payment information
• Preference information, including attitudes collected from online and in-store survey responders, purchasing patterns.
Sources Of Personal Information and Purposes for Using Personal Information
In the last 12 months, Company collected the categories of Personal Information listed above from the following sources: (1) Customers (directly from you, i.e., from forms you complete or produce and services you purchase); and (2) Website Users (i.e., from observing your actions on our website), and used those categories of Personal Information for the following purposes:
Categories of Personal Information Collected in the Last 12 Months
Sources of that Personal Information
Business Purposes and Commercial Purposes for Collecting that Personal Information
From: (1) California Consumers; (2) Website Users
• Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services.
• Communications about promotions, for example, by communicating about special events, sweepstakes (e.g., "Bumper to Bumper" survey), promotions and surveys.
• Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.
From: (1) California Consumers; and (2) Website Users
• For providing marketing and promotional information, including for Email Club through service providers such as MailChimp
• Perform business analysis
Internet or other electronic network activity information
• understand customer shopping habits
• for security of premises
From California Consumers
• To process payments for purchase of services, gift cards, and Unlimited Wash Club membership purchases, including through service providers such as Authorize.net
From California Consumers and Website Users who respond to online or in-store surveys
• To determine customer satisfaction, obtain feedback on customer service and use of facilities
• To improve services
Disclosure Of Personal Information to Third Parties
•We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
Category of Personal Information
Categories of Third Parties
• Online marketing platform, such as MailChimp, and our web hosting platform Bluehost
• Service Providers, including e-commerce vendors such as Authorize.net
• law enforcement and regulatory agencies to comply with law
• Insurance companies
• As related to legal proceeding
• Payment processing services
No Sale of Personal Information
The Company has not sold California Consumers' Personal Information in the past 12 months, does not and will not sell California Consumers' Personal Information.
California Consumers have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know").• Once we receive a verifiable request, we will disclose to you:
• The categories and specific pieces of Personal Information that Company has collected about them.
• The categories of sources from which Company collected the Personal Information.
• The categories of Personal Information that Company sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and
• The business or commercial purposes for Company's collection, disclosure, or sale of the Personal Information.
Right To Delete
California Consumers have the right to submit a verifiable request for deletion of their Personal Information that Company has collected from the Consumer.
Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1.• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2.• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3.• Debug products to identify and repair errors that impair existing intended functionality.
4.• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5.• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code • 1546 et. seq.).
6.• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7.• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8.• Comply with a legal obligation.
9.• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Opt Out of Sale of Personal Information
• California Consumers have a right to opt-out of the sale of the Personal Information. However, as stated above, Company does not and will not sell Personal Information.
How to Exercise Your Rights
Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights in the following ways:
• Complete the request form available by emailing: firstname.lastname@example.org
• Contact by telephone: 1-800-339-3949.
You may also make a request to know or delete on behalf of your child in the same manner.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
• Provide sufficient information that allows us to reasonably verify 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.
Requests By Authorized Agents
You can have an authorized agent submit a CCPA request to us on your behalf by (a) providing us with a written authorization signed by you that designates the agent as your authorized agent for purposes of a CCPA request; (b) verifying your identity directly with us; and (c) directly confirming with us that the agent is authorized to submit the request.
How We Will Verify Your Requests
The processes that we follow to verify that the person making a request to know or a request to delete is the person about whom we have collected personal information are described below. The relevant process depends on how and why the request is submitted.
Requests Through Your Password-Protected Account
If you created a password-protected account with us before the date of your request, we will rely on the fact that your request has been submitted through your account as verification of your identity. We will require that you re-authenticate yourself before we disclose your personal information in response to a request to know and before we delete your personal information in response to a request to delete.
You are responsible for protecting the security of your log-in credentials for your account. Please do not share your log-in credentials with anyone. If we suspect fraudulent or malicious activity on or from your account, we will not respond to a request to know or a request to delete until we have been able to confirm, through further verification procedures, that you made the request.
Requests Other Than Through A Password-Protected Account
If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:
• Requests To Know Categories of Personal Information: We will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or information about products or services that you have purchased from us.
• Requests To Know Specific Pieces of Personal Information: We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity.
• Requests To Delete Personal Information: Our process for verifying your identity will depend on the sensitivity (as determined by Company) of the personal information that you ask us to delete. For less sensitive personal information, we will require a match of two data points as described in Point No. 1, above. For more sensitive personal information, we will require a match of three data points as described in Point No. 2, above.
We have implemented the following additional procedures when verifying the identity of requestors:
1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process. We will not use that information for any purpose other than verification.
2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email email@example.com
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
The Company's Non-Discrimination Policy
•We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your consent, which you may revoke at any time.
Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes:
Under California law, California Consumers can request information from us whether we have disclosed Personal Information to any third parties for the third parties' direct marketing purposes. We will not sell your Personal Information to, or share it with, third-party companies for their direct marketing purposes without your consent. California Consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.
Your ‘Do Not Track’ Browser Setting
The Site collects personally identifiable information about your online activities over time and across third-party websites or online services. We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit, including the Site, know that you do not want the sites collecting your personally identifiable information.
Information We Collect Through Technology
We collect information through technology to enhance our ability to serve you. For example, when you visit the Site, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. We do not link IP addresses to personal information.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies by adjusting your browser settings. Like most websites, if you turn your cookies off, some of the features on the Site may not function properly.
Third-Party Links And Services
Links to and Plug-Ins from Other Web Sites or Media
You can obtain more information about Google Analytics here: https://marketingplatform.google.com/about/?rd=1
Minors Under 16 Years of Age
We respect the privacy of children. Our Services are not designed to attract an audience younger than sixteen (16), and we do not knowingly collect Personal Information from children under sixteen (16). If you are under the age of sixteen (16), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected information from your child under the age of sixteen (16), and we will work to delete it.
For More Information
For questions or concerns about Company's privacy policies and practices, please contact us at firstname.lastname@example.org.
QUESTIONS AND FEEDBACK
Wash Depot Holdings, Inc.
2400 East Commercial Blvd., Suite 901
Fort Lauderdale, FL 33308