WASH DEPOT PRIVACY POLICY

Last Updated: March 2020

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:

  • Device-specific information. We collect device-specific information when you visit our website such as your internet protocol address.
  • Location information. We may collect and process information about your geographic location through the use of Google Analytics.  However, this information is in aggregate form and we do not know your exact geographic location.
  • Vehicle Information. We may collect and process information about your vehicle such as the make, model, vehicle identification number, license plate number with state identification, and color so that we can easily access your account, including the date and type of service you received from us.
  • Information we collect when you receive our services may be associated with your account. When information is associated with your account, we treat it as Personal Information.

In addition to the purposes listed above, we may also use your Personal Information to:

  • Communicate with you. Obtain your name for purposes of communicating with you and identifying you as a user of the website or our services.
  • Verify your identity. We may use your Personal Information to verify who you are. For example, we may verify your age or that you have obtained your parent’s or guardian’s permission to use the website or services.
  • Send you marketing materials. We may send you marketing materials, such as promotional emails, to keep you informed of our upcoming products and services. Some of these marketing emails may come directly from us or from our marketing partner MailChimp.  You generally must opt-in to receive our marketing materials, such as when you provide us your email address online and at our lube centers, and you may opt out of receiving them at any time by selecting the “unsubscribe” option at the bottom of such promotions. For more information on how to opt out, please see YOUR CHOICES below.
  • Respond to your questions and fulfill your requests. We may send you communications upon your request or otherwise with your consent.
  • Provide support and receive feedback. We may request Personal Information in order to provide support to you. We may also collect Personal Information that are associated with your feedback.
  • Process your transactions. In partnership with our service provider Authorize.net, we may use your Personal Information that you provide to us in the process of making a purchase to confirm your use of a valid credit card (or other authorized methods of payment), process your payment via a credit card (or other authorized methods of payment), and provide our products and services.

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

We use Cookies, Web Beacons, and other data collection technologies (together, “Data Collection Technologies”) to provide you with a better experience when you use the services. Data Collection Technologies help you log onto the services, remember your settings and preferences, help us keep your information safe and secure, and enable our partners to serve ads for our products and services, including those targeted to your interests. While the Data Collection Technologies we use may change from time to time, they generally fall into the following categories:

  • Authentication. We use cookies to verify your account and determine when you’re logged in so we can make it easier for you to access the services and show you the appropriate experience and features.
  • Security and product integrity. We use cookies to help us keep your account and information safe and secure. We also use cookies to combat activity that violates our policies or otherwise degrades our ability to provide our services.
  • Advertising, insights and measurement. We use cookies to help us show ads for businesses and other organizations to people who may be interested in the products, services or causes they promote. We also use cookies to help measure the performance of ad campaigns for businesses that use the services. Cookies help us serve and measure ads across different browsers and devices used by the same person.
  • Site features and services. We use cookies to enable the functionality that helps us provide the services and provide you with the best experience possible, including to help provide you with content relevant to your locale.
  • Analytics and research: We use Cookies to better understand how people use the website so that we can improve the services. For example, we partner with Google Analytics, which uses Cookies to track your interactions with our services. Google then collects that information and reports it to us, without identifying individual users. This information helps us improve our Services so that we can better serve users like you. For more information on Google Analytics, visit https://support.google.com/analytics.

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:

  • At your direction. We will share your information with third parties if and when you direct us to. For example, you may ask us to share your Personal Information when you wish to interact with other users or post certain information on social media.
  • With our Vendors. We may share your Personal Information with our Vendors such as MailChimp, Bluehost and Authorize.net, as necessary to enable them to provide services to us. Vendors are third parties (other companies and individuals) that support the operation and maintenance of our services.
  • With our commonly owned entities. We may share your Personal Information with other companies under common ownership and control of Wash Depot Holding, Inc., which may include our subsidiaries, corporate parent, or any other subsidiaries owned by our corporate parent. We do this in order to provide you better service and improve your experience.
  • For legal purposes. We may share your Personal Information as reasonably necessary to comply with law, legal process (including a court or government order or subpoena), and to meet our insurance obligations, to detect, prevent, or otherwise address fraud, security or technical issues, to enforce this Privacy Policy, and to protect the rights, property or safety of Wash Depot, our users, and/or the public.
  • During a corporate transaction. If Wash Depot is involved in a merger, acquisition, financing, or sale of business or assets, information collected from and about users may be transferred to one or more third parties involved in such transaction and, upon such transfer, the relevant third party privacy policy or policies may govern further use of the information.

YOUR CHOICES

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.

  • Access, modify, or delete your Personal Information. You can contact us at any time to request to access, modify, or delete the Personal Information we possess about you. Please refer to the “Contact Us” section below.
  • Opt out of marketing communications. You can opt out of marketing communications by indicating your preference when you sign up for our services. You may also contact us to opt out of our marketing communications.
  • Managing Cookies and Other Data Collection Technologies. You have a number of options to control or limit how we and our vendors use Cookies and other Data Collection Technologies including for advertising:
    • To prevent location information from being collected by us at any time, you can turn off your device’s location-tracking functionality.
    • To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
    • To opt out of interest-based advertising, you can visit http://optout.networkadvertising.org/#!/ and follow NAI’s on-screen instructions. Note that if you opt out through the NAI, you will still receive advertising, but the advertising will not be tailored to your interests. In addition, if you opt out through NAI and later delete your Cookies, use a different browser, or buy a new device, you will need you opt out of interest-based advertising again.
    • To opt out of ads on Facebook or Google that are targeted to your interests, use your Facebook or Google Ads settings.
    • Check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.

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.

CHILDREN'S PRIVACY

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 section of the Privacy Statement applies only if you reside in the state of California in the United States (“California Consumer”).  This section applies to all Personal Information of California Consumers that Wash Depot Holdings, Inc. collects both online and offline, including through California Consumers’ (a) visits to our website, and (b) use of our services that references this Privacy Policy.   

 

This Privacy Policy addresses the following topics

·         The Scope of This Privacy Policy

·         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

·         Changes to This California Privacy Policy

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability.  Please contact us at info@washdepot.com for assistance.

The Scope Of This Privacy Policy

            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 or household. 

Whose Personal Information Is Covered By This Policy?

This California Privacy Policy applies to the Personal Information of residents of the State of California in their capacity as consumers (“California Consumers”).

            What Personal Information Does This Privacy Policy Cover?

This Privacy Policy applies to all Personal Information of California Consumers that we collect both online and offline, including through California Consumers’ (a) visits to our website, (b) video; (c) emails; (d) use of our products and services that references this Privacy Policy (collectively, the “Services”). 

            Whose Personal Information Is Not Covered By This Privacy Policy?

For purposes of this Privacy Policy, “Consumer” does not include:

·         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

This section of the Privacy Policy describes, for the 12 months preceding the date last updated, above, (a) the categories of Personal Information we have collected about you, (b) the sources of that Personal Information, (c) the business and commercial purposes for use, and (d) the categories of third party recipients of your Personal Information.  Unless we inform you otherwise, this section also serves as our “notice at collection” by informing you of your Personal Information to be collected in the future and the purposes for its use.

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: 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; and (2) Website Users, 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

Identifiers

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.

 

Commercial information

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

 

 

Sensory information

 

·   for security of premises

 

 

Financial Information

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

Preference information

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

In the last 12 months, Company disclosed the following categories of Personal Information about California Consumers to the following categories of third parties for a business or commercial purpose:

Category of Personal Information

Categories of Third Parties

Identifiers

 

·         Online marketing platform, such as MailChimp, and our web hosting platform Bluehost

 

Commercial Information

 

·         Service Providers, including e-commerce vendors such as Authorize.net

 

Sensory Information

·         law enforcement and regulatory agencies to comply with law

·         Insurance companies

·         As related to legal proceeding

Financial Information

·         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.

Your Rights

California Consumers have the right to submit a verifiable request to know:

·         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. 

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 online request form available here: info@washdepot.com

·         Contact by telephone: 1-800-339-3949.

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.

The Company’s Non-Discrimination Policy

California Consumers have the right not to be subject to discriminatory treatment by Company for exercising their privacy rights under the California Consumer Privacy Act, and Company will not discriminate on that basis. However, Company may charge a California Consumer a different price or rate or provide a different level or quality of goods or services if the difference is reasonably related to the value provided to the California Consumer by the Consumer’s Personal Information.  At this time, Company does not.  If Company does so, it will provide Consumers with any legally required notice.

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.

Do We Use Cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand and save your preferences for future visits to our Site. For example, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are. 

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

We provide links to third party websites operated by organizations not affiliated with Company. We do not disclose your Personal Information to organizations operating such linked third-party websites. We do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each and every website that you visit. This Privacy Policy applies solely to information collected by Company through the Services.

 

Links to and Plug-Ins from Other Web Sites or Media

The Site includes links from the Site to and plug-ins (such as Twitter buttons) from sites or applications operated by third parties (“Third Party Sites”).  Company does not control any Third Party Sites and is not responsible for any information they may collect. The information collection practices of a Third Party Site are governed by its privacy policy. It is your choice to enter any Third Party Site. We recommend that you read its privacy policy if you choose to do so.

 

Google Analytics

We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding our Site visitors.  These cookies collect data tied to a user’s IP address such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the Site.  Based on this information, Google Analytics compiles aggregate data about Site traffic and Site interactions, which we use to offer better Site experiences and tools in the future.  Google Analytics does not collect any personal information.

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 info@washdepot.com.

QUESTIONS AND FEEDBACK

We welcome your questions and comments about this Privacy Policy or our privacy practices. You can also contact us to exercise your privacy rights under applicable law. You can contact us as follows:

VIA EMAIL

info@washdepot.com

IN WRITING

Wash Depot Holdings, Inc.

2400 East Commercial Blvd., Suite 901
Fort Lauderdale, FL  33308

1-800-339-3949