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LAUNCHPAD PRIVACY POLICY

2018


This Privacy Policy applies to the use of the Launchpad application operated by Constellation Agency, LLC and does not describe the collection, use, and disclosure practices of any corporate affiliates or third parties.  By using the Launchpad application, you signify your consent to the data practices described in this Privacy Policy.    

Services offered by the Launchpad application are not directed to individuals under the age of thirteen (13) and we will not knowingly allow any individual under the age of 13 to provide any personally identifiable information.  If you are under 13, you should not provide any personal information to us.

This Privacy Policy includes the following information:

 

+   INFORMATION WE COLLECT

+   HOW WE MAY USE THE INFORMATION THAT WE COLLECT

+   INFORMATION THAT WE SHARE

+   LINKS, APPLICATIONS, WIDGETS, AND SOCIAL MEDIA

+   DATA SECURITY

+   DISPUTES

+   UPDATES TO THIS PRIVACY POLICY

+   CONTACT INFORMATION

+   YOUR CALIFORNIA PRIVACY RIGHTS

 


 

INFORMATION WE COLLECT

Information you provide.  We may collect information that you choose to provide to the Launchpad application including when you:

·      Register for use of the Launchpad application.  This information may include your name, username, password, address, telephone number, zip code, e-mail address, your dealership name, brand/OEM of your dealership, dealership website URLs, and dealership Facebook pages;

·      Make information available to us via social networking logins, such as Facebook or Twitter;

·      Provide payment card information for one of our products or services;

·      Enter information into one or more fields of the Launchpad application;

·      Select or activate one or more elements of the Launchpad application; and

·      Upload inventory, pricing, images, or other data to the Launchpad application.

Automated Information.  Information regarding your use of the Launchpad application may be collected and/or aggregated through automated means and may include the collection of:

·      Your IP address, browser information, and the type and operating system of the device used to access the Launchpad application;

·      Date and time that you accessed the Launchpad application including which portions of the Launchpad application you have accessed;

·      Cookies stored on your device for the purpose of identifying the browser or settings information for your device; 

·      Local shared objects, sometimes referred to as Flash Cookies, that store your preferences or display content based on previous usage of the Launchpad application. 

·      Web beacons that link web pages to web servers and their cookies and may be used by the Launchpad application to track your traffic patterns.

Publicly Posted Information. Information that you make available to us and others via publicly available web sites, social media networks, forums, blogs, list serves, chat rooms, applications, other public facing portals, or similar functionality is public information that we or others may share or use in accordance with the law.  This includes any data that may be scraped from your web site or other public facing portals.

Inventory Data. Information that you make available to us about your vehicle inventory including models in stock, number of vehicles of each model in stock, or other similar data.

HOW WE MAY USE THE INFORMATION THAT WE COLLECT

We may use information we collect for the following purposes:

·      Everyday business purposes, such as establishing and managing your user account, providing products and services you request, processing and collecting payments and providing customer support;

·      To create listings, advertisements, messages, posts, or other offers for vehicles in your inventory.  These listings, advertisements, messages, posts, or other offers may be published by us to websites, applications, mobile applications, social media, or services of third parties on your behalf;

·      To evaluate and improve our business, including developing new products and services and analyzing the effectiveness of our products, services, applications and websites;

·      To diagnose and address technical and service problems;

·      To perform data analyses, including market and consumer research, trend analysis, demographic analysis and financial analysis;

·      To comply with applicable legal requirements and our policies; and

·      To contact you via telephone, email, text, or chat. We will obtain your consent to contact you when and in the manner required by law.

INFORMATION WE SHARE

We do not sell, trade, rent, or otherwise transfer information about you that we collect or receive, except as described below:

·      Affiliates. We may share information about you, including personal information, with our corporate affiliates, who will use it in accordance with their privacy policies;

·      Our Service Providers. We may engage third parties to provide the services offered through or in connection with the Launchpad application on our behalf. We require such providers to maintain information about you as confidential and to use the information only to perform the services specified by us in a manner consistent with this Privacy Policy;

·      Manufacturers. We may share usage information about your use of the Launchpad application with vehicle manufacturers of the brand/OEM of your dealership.

·      Potential Customers. We may hash or otherwise anonymize the usage information about your use of the Launchpad application and share the hashed or anonymized usage information with potential customers.

·      Business Transfers. If another company acquires Constellation Agency LLC or all or substantially all of our assets, that company will possess the same information and will assume the rights and obligations with respect to that information as described in this Privacy Policy.

·      Other. We may access or disclose information, including personal information, to:

o   Protect or defend our interests and the legal rights or property of Constellation Agency LLC and our affiliates;

o   Protect the rights, interests, safety and security of users of the Launchpad application or members of the public;

o   Protect against fraud or for risk management purposes;

o   Comply with prudent legal practice as we may determine, and applicable law or legal process; or

o   With your consent.

DATA SECURITY

We maintain commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard and prevent unauthorized access to the information that the Launchpad application collects.  These measures are designed to safeguard the information against loss, theft and unauthorized use, disclosure or modification.  Despite these measures, we cannot guarantee or warrant perfect security of networks, servers and databases we operate or that are operated on our behalf.

DISPUTES

Any dispute regarding privacy is subject to this Privacy Policy and the Terms of Service of the Launchpad application, including limitations on damages, resolution of disputes, and the application of the law of the state of New York.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy to provide clarification or notice of changes to our practices.  If we make changes, we will revise the date at the top of this Privacy Policy.  We will provide you with additional notice of material changes by posting notice of the changes for thirty (30) days before we implement those changes.

CONTACT INFORMATION

If you have any questions or comments on this Privacy Policy, you may contact us via e-mail at info@constellationagency.com or in writing at the following address:

Constellation Agency, LLC

33 Irving Place

3rd Floor

New York, NY 10019

YOUR CALIFORNIA PRIVACY RIGHTS

Constellation Agency LLC does not disclose your personal information to third parties for the purpose of directly marketing their services to you unless you first agree to such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed above.