WASH DEPOT PRIVACY POLICY
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
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:
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 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.
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"). We adopt this notice and policy to
comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms
defined in the CCPA have the same meaning when used in this Policy. 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 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)]
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, household, or device.
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").
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.
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 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 |
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
•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 |
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 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:
info@washdepot.com
• 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 info@washdepot.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.
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.
Changes to Our Privacy
Policy
We
reserve the right to amend this privacy policy at our discretion and at any
time. When we make changes to this privacy policy, we will post the updated
notice on the Website and update the notice's effective date. Your continued use of our website following
the posting of changes constitutes your acceptance of such changes.
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