Data Privacy / Privacy Practices - May 1, 2019


INTRODUCTION. At VehicleOwnersGuide.com (“VOG,” “we,” “us” or “our”) we take your privacy and the security of your information very seriously. This Privacy Policy (“Policy”) covers VehicleOwnersGuide.com owned and operated websites (“Site” or “Sites”), including EstimateScrubber.com, and any services offered via the Site (collectively, the “Services”). These Services include Services that assist our customers by providing solutions tailored to meet the specific business needs of the property & casualty and collision repair industries.

This Privacy Policy is incorporated into, and is part of, our Terms of Use available at EstimateScrubber.com/terms-of-use, which govern your access to the Site and your use of the Site and/or Services, unless you have entered into a separate written agreement with VehicleOwnersGuide.com. If you have entered into a separate written agreement with VehicleOwnersGuide.com, that separate written agreement controls, and only those terms within this Privacy Policy that do not conflict with that separate written agreement apply. Unless otherwise defined herein, capitalized terms have the meaning assigned to such terms in the Terms of Use. The Policy describes the types of information we gather from people visiting our Site and/or using our Services and from individual users (“you” or “users”) interacting with our Site and/or Services, and how we use, transfer, and secure such information. By accessing any Site or using any Services, you agree to be bound by this Policy. This Policy does not govern information we receive from third parties. If you do not agree to the terms of this Policy, please do not use the Site or any of our Services. Each time you use any Site or any Services, the current version of this Privacy Policy applies. Accordingly, when you use any Site or Services, please check the date of this Policy (which appears at the top) and review any changes made since you last reviewed the Policy.

WHAT DATA WE COLLECT/STORE. EstimateScrubber.com is a (VOG) hosted solution. As a hosted product, EstimateScrubber.com stores data, including aggregated metrics, user generated profiles, login information, shop demographic information, and other non-specific estimate information (the “data”). We use the aggregated information to provide benchmarking (for example we aggregate millions of estimate line items to provide low/average/high labor hour forecasts for non-included operations that is presented to users when scrubbing estimates). We use the data in the ordinary course of our business (for example, comparing scrubbed metrics against all users metrics, or viewing user generated wiki information for a particular vehicle make/model, or logging into EstimateScrubber.com). In that context, VOG may provide the data to third parties in de-identified, aggregated fashion. For example, VOG may aggregate various data points for industry reporting and analysis but will de-identify the data so that repair facilities and their customers cannot be identified.

We collect Personal Information that you voluntarily provide to us when you use our Sites and Services. For example, you may provide us with your email address, first name and last name, phone number, or other Personal Information. If you choose to share information publicly through our Site or Services, please understand that we cannot control the actions of third parties who could collect this information.

Some links on our Site may redirect you to third party websites and services that we do not operate. The privacy practices of these websites and services will be governed by their own policies. We make no representations or warranties as to the privacy policies of any third parties. If you are submitting information to any third party through our Site or Services, you should review and understand that party’s applicable policies, including their privacy policy, before providing your information.

Aggregate Information is information that does not identify you. Aggregate Information may be collected when you visit our Site or interact with our Services, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without restriction. For example, when you visit our Site, some information is automatically collected. Such information could include your operating system, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called the “exit page”), information about other websites you have recently visited, browser (software used to browse the internet) type and language, device identifier numbers, your site activity, and the time and date of your visit. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser to help us identify you when you come to our Site. You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, you may be unable to use those aspects of our Sites that require registration in order to participate. You can learn more about cookies and how they work at www.allaboutcookies.org. You can always disable cookies through your browser settings. Doing so, however, may disable certain features on our Sites. You can opt-out from third party cookies that are used for advertising purposes on the NAI website at networkadvertising.org/managing/opt_out.asp.

We may use third parties, such as Google Analytics, The Linkedin Insight Tag, or other analytics providers, to analyze traffic to a Site. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at google.com/intl/en/analytics/privacyoverview.html. You may find additional information about Google Analytics at google.com/policies/privacy/partners/. You have the option to opt out of Google's use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page at google.com/policies/technologies/ads/. The LinkedIn Insight Tag is a piece of lightweight JavaScript added to the Sites to enable in-depth campaign reporting and to help us unlock valuable insights about visitors to our Sites. We may use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about members interacting with our LinkedIn adverts. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie or the cookie expires (there’s a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag). You can opt out of cookies from LinkedIn on your LinkedIn settings page at http://linkedin.com/psettings/ and recommend you read their Cookie Policy at http://linkedin.com/legal/cookie-policy for more information. We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Sites or social media and whether or not certain content, such as a video was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Privacy Policy.

We may also participate in interest-based advertising using similar technology. This means that you may see advertising on our Sites tailored to how you browse or shop, or you may see advertising for VOG and its properties on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for VOG and its Sites. Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites such as Facebook and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information. You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (networkadvertising.org/choices/) and DAA website (aboutads.info/choices/).

DATA PROTECTION. We take the same care with any stored data that we take with handling our own information. To protect the data from loss, misuse, or unauthorized access, disclosure, alteration, or destruction, VOG uses commercially reasonable safeguards. It is important to note that no data storage and backup process is 100% fault-free and that EstimateScrubber.com is subject to risks of third party intrusion, loss of connectivity, and data loss or corruption. VOG has taken many steps to ensure the security and availability of the data, including: encryption of data during transmission; daily backups; and commercially reasonable disaster recovery measures. Any email or other communication purporting to be from one of our websites asking you to provide sensitive information via email, should be treated as unauthorized and suspicious and should be reported to us immediately by emailing legal@VehicleOwnersGuide.com.

WE NEVER STORE. We never store any insured, claimant, owner, or policy information in our databases. Any information we store in EstimateScrubber.com is used by users in the normal course of using the product (user profiles, login information, aggregated information).

ESTIMATE FILES. We may store uploaded estimate files on our servers for users to review archived past repairs. For example, to allow a specific user to view past uploaded estimates for Ford F-250 trucks. Any estimate file we store in EstimateScrubber.com is used by users in the normal course of using the product to view archived prior repairs.

ESTIMATE LINES. We use the estimate line items to generate forcasted values. The estimate lines are not stored on EstimateScrubber.com, but downloaded to a database at our facilities where we use artificial intellegence and machine learning to create aggregate metrics and patterns. We use physical security measures, including but not limited to use of security personnel, equipment access limitations, and background checks of employees with access to our systems.

SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES. We may transfer Personal Information to third parties for the purpose of providing the Services. We may disclose Personal Information to our affiliates or third party service providers to provide you with the Services. For example, we may transfer your Personal Information to third party service providers to (i) assist with providing the Services; or (ii) communicate with you about current or future offerings. These third party service providers are not authorized to retain, share, store or use the Personal Information for any purposes other than to provide the services they have been hired to provide.

CORRECTIONS/INFORMATION REMOVAL/OPT-OUT. You can request that any Personal Information stored by us to be deleted at any time by contacting us at legal@VehicleOwnersGuide.com. We may require you to provide certain information to verify that it is you making the request. However, we will not delete information that we are required to retain in order to comply with applicable laws and regulations. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication.

YOUR CALIFORNIA PRIVACY RIGHTS. California residents who provide personal information in obtaining Services are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing use. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2016 will receive information regarding 2015 sharing activities).

CANADIAN USERS/VISITORS. Canadian citizens, except under circumstances defined by law, are entitled to access their own Personal Information collected by VehicleOwnersGuide.com by writing to: VehicleOwnersGuide.com, attention Legal Department, P.O. 261084, San Diego, CA 92196. We may ask you to pay an administrative fee for accessing or copying your Personal Information, but will inform you of the anticipated charges and confirm that you want us to proceed before processing your request. If you believe that the Personal Information about you that we have collected is incomplete or inaccurate, we will correct the information upon verification of the omission or error and of the identity of the person requesting the change. If you wish to request additional information about our information management, or would like us to access, correct or have us investigate any matters in relation to your Personal Information, please contact us.

WILL WE CHANGE THIS DATA PRIVACY POLICY? Each time you use our Site or Services the current version of the Policy will apply. When you use our Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of your privacy without the consent of affected customers.

SECURITY. Data transmitted to and from VehicleOwnersGuide.com client Sites is encrypted for the user's protection. However, the security of information transmitted through the Internet can never be guaranteed. VehicleOwnersGuide.com is not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. User is responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of VehicleOwnersGuide.com sites. In order to protect you and your data, VehicleOwnersGuide.com may suspend your use of a client site, without notice, pending an investigation, if any breach of security is suspected.

GOVERNING LAW. This Policy is governed by the laws of the State of California, U.S.A. without giving effect to any principles of conflict of law.

CHILDREN AND PRIVACY. We do not knowingly collect Personal Information from children in connection with the features of our Sites or Services. If we become aware that an individual under the age of 13 has provided personally identifiable information through our Sites or Services, we will immediately remove the individual’s personally identifiable information from our files.