Privacy Notice

This Privacy Notice describes how we collect and use your personal information in relation to Nowcom websites, applications, products, services, events, and experiences that reference this Privacy Notice (together, “Nowcom Services”).

This Privacy Notice does not apply to the “content” processed, stored, or hosted by our customers using Nowcom Services in connection with an Account. This Privacy Notice also does not apply to any products, services, websites, or content offered by third parties or which have their own privacy notice.

If you interacted with Nowcom for products or services which are to be used primarily for personal, family, or household purposes, the following section applies to you.

CONSUMER PRIVACY

FACTS WHAT DOES NOWCOM DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on how you interact online with us.
This information can include:
• Social Security number and income
• Account balances and payment history
• Credit history and credit scores
• Contact and identity data
• Demographic data
• Device data
• Online and mobile activity data
• Marketing data
• Communications data
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Nowcom chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does Nowcom share? Can you limit sharing?
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or to request credit reports from credit bureaus Yes No
For our marketing purposes — with service providers we use to offer our products and services to you (please see below to limit the ways we contact you) Yes No
For joint marketing with other financial companies – such as to offer you insurance, financing, or other products from financial companies with which we have a joint marketing agreement Yes No
For our affiliates’ everyday business purposes — Information about your transactions and experiences Yes No
For our affiliates’ everyday business purposes — Information about your creditworthiness Yes Yes
For nonaffiliates to market to you — for automotive financing and vehicle interest submissions — your name, contact information, and vehicle interests, but not information about your creditworthiness. Yes Yes
To limit our sharing • Call: 888-669-2669 during business hours and talk to Support
• Email: [email protected]Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice, or immediately upon receiving your information if you were presented the opportunity to opt-out during the interaction with us. When you are no longer our customer, we continue to share your information as described in this notice.However, you can contact us at any time to limit our sharing.
Questions? Call 888-669-2669 or go to www.nowcom.com
Who are we
Who is providing this notice? Nowcom, LLC, with headquarters at 4751 Wilshire Blvd., Suite 115, Los Angeles 90010, and utilizing the trademarks, service marks, or d/b/a of DealerCenter® and CarZing®.
What we do
How does Nowcom protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Nowcom collect my personal information? We collect your personal information, for example, when you

• prequalify for a loan
• perform transactions
• request a credit report

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing? Federal law gives you the right to limit some but not all sharing related to:

• affiliates’ everyday business purposes—information about your creditworthiness
• affiliates from using your information to market to you
• nonaffiliates to market to you

State laws and individual companies may give you more rights to limit sharing. See Other important information section for your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to you alone unless you tell us otherwise.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include Westlake Services LLC, d/b/a Westlake Financial Services, Western Funding Inc., Midway Rent A Car Inc., d/b/a Midway Leasing, North Hollywood Toyota, Knight Insurance Group, Credit Union Leasing of America, and Hankey Investment Company
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Nonaffiliates we share with can include financial services companies such as finance companies, insurance agencies, automobile dealerships, automobile manufacturers, credit reporting bureaus, nonfinancial companies such as market analysis companies, marketing companies, technology service companies, and membership groups.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Our joint marketing partners include financial service companies, automobile dealerships, automobile manufacturers.
Other important information
Do Not Call Policy. This notice is the Nowcom Do Not Call Policy under the Telephone Consumer Protection Act. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless the law allows. Nowcom employees receive training on how to document and process telephone marketing choices. Consumers who ask not to receive telephone solicitations from Nowcom will be placed on the Nowcom Do Not Call list and will not be called in any future campaigns.
Call Monitoring and Recording. If you communicate with us by telephone, we may monitor or record the call.
For Nevada residents only. We are providing you this notice under state law. You may be placed on our internal Do Not Call List by following the directions in the “To limit our sharing” section, above. Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702.486.3132; email: [email protected]. Nowcom, LLC, 4751 Wilshire Blvd., Suite 115, Los Angeles, CA 90010; Phone number: 888-669-2669; email: [email protected]
Vermont: Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, unless the law allows. For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.
California: See Privacy Notice for California Residents

If you interacted with Nowcom for products or services which are to be used primarily for business purposes, the following section applies to you.

ONLINE PRIVACY FOR BUSINESS CUSTOMERS

  1. Personal Information We Collect
    1. We collect your personal information in the course of providing Nowcom Services to you. Personal information means personally identifiable information such as information you provide via forms, surveys, applications or other online fields including name, postal or email addresses, telephone, fax or mobile numbers, or account numbers.
    2. Here are the types of information we gather:
      1. Information You Give Us: We collect any information you provide in relation to Nowcom Services. You provide information to us when you:
        1. communicate with us by phone, email, or otherwise;
        2. search for, subscribe, or purchase Nowcom Services;
        3. create or administer your Account;
        4. complete a support ticket, questionnaire, or other information request form; and
        5. post on Nowcom websites or participate in community features.
      2. Automatic Information: We automatically collect certain types of information when you interact with Nowcom Services. Examples of the information we automatically collect include:
        1. computer and device information, such as application or browser type and version, browser plug-in type and version, operating system, time zone settings, and device version and type;
        2. the location of your device or computer;
        3. authentication and security credential information;
        4. content interaction information, such as downloads, page views (including interaction such as scrolling, clicks, and mouse-overs), Service usage, occurrences of technical errors, diagnostic reports, your settings preferences, API calls, and other logs;
        5. email addresses and phone numbers used to contact us; and
        6. identifiers and information contained in cookies.
      3. Information from Other Sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources. Examples of information we receive from other sources include:
        1. subscription, purchase, support, or other information about your interactions with products and services offered by us from our affiliates or third parties;
        2. marketing information, including your name, email address, physical address, phone number and other similar contact information;
        3. search results and links, including paid listings; and
        4. credit history information from credit bureaus.
  2. How We Use Personal Information
    1. We use your personal information to operate, provide, and improve Nowcom Services. Our purposes for using personal information include:
      1. Provide Nowcom Services: We use your personal information to provide and deliver Nowcom Services and process transactions related to Nowcom Services, including registrations, subscriptions, purchases, and payments.
      2. Measure, Support, and Improve Nowcom Services: We use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop Nowcom Services.
      3. Recommendations and Personalization: We use your personal information to recommend Nowcom Services that might be of interest to you, identify your preferences, and personalize your experience with Nowcom Services.
      4. Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information. For example, we collect bank account information from Subscribers of Credit Reporting Services for identity verification.
      5. Communicate with You: We use your personal information to communicate with you in relation to Nowcom Services via different channels (e.g., by phone, email, chat) and to respond to your requests.
      6. Marketing: We use your personal information to market and promote Nowcom Services. We might display interest-based ads for Nowcom Services. To learn more, please read our Interest-Based Ads notice.
      7. Fraud and Abuse Prevention and Credit Risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Nowcom Services, and others. We may also use scoring methods to assess and manage credit risks.
      8. Purposes for Which We Seek Your Consent: We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.
    2. Cookies
      1. To enable our systems to recognize your browser or device and to provide Nowcom Services to you, we use cookies. Cookies are pieces of information stored directly on the device you are using. Cookies we use do not contain or capture unencrypted personal information. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and your relationship with us. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize/tailor your experience while engaging with us, and to recognize your device to allow your use of our online products and services. We collect statistical information about the usage of the Site in order to continually improve the design and functionality, to monitor responses to our advertisements and content, to understand how account holders and visitors use the Site and to assist us with resolving questions regarding the Site. We also utilize cookies for advertising purposes.
  3. How We Share Personal Information
    1. Information about our customers is an important part of our business and we are not in the business of selling our customers’ personal information to others. We share personal information only as described below and with affiliates that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.
      1. Transactions Involving Third Parties: We make available to you services and content provided by third parties for use on or through Nowcom Services. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party. For example, you can interact with services and content from third parties using Nowcom Services and we provide those third parties information to facilitate your subscription, purchases, or support.
      2. Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include: sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process that information in accordance with this Privacy Notice and as permitted by applicable data protection law.
      3. Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the individual consents otherwise). Also, in the unlikely event that Nowcom or substantially all of its assets are acquired, your information will of course be one of the transferred assets.
      4. Protection of Us and Others: We release account and other personal information when we believe release is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of Nowcom, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
      5. At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.
  4. Location of Personal Information
    1. Nowcom is located in the United States, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with Nowcom Services, your personal information may be stored in or accessed from multiple countries, including the United States. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by applicable data protection laws.
  5. How We Secure Information
    1. At Nowcom, security is our highest priority. We design our systems with your security and privacy in mind.
      1. We maintain a wide variety of compliance programs that validate our security controls.
      2. We protect the security of your information during transmission to or from Nowcom Services by using encryption protocols and software.
      3. We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.
      4. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.
  6. Internet Advertising and Third Parties
    1. Nowcom Services may include third-party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. We do not provide any personal information to advertisers or to third-party sites that serve our interest-based ads. We do not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by our Privacy Notice.
  7. Access and Choice
    1. You can view, update, and delete certain information about your account and your interactions with Nowcom Services. If you cannot access or update your information yourself, you can always contact us for assistance.
      1. Examples of information you can access through Nowcom Services include:
        1. your name, email address, physical address, phone number, and other similar contact information;
        2. usernames, roles, and other authentication and security credential information;
        3. your subscription, purchase, usage, billing, and payment history;
    2. You have choices about the collection and use of your personal information. Many Nowcom Services include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of certain Nowcom Services.
      1. Account Information: If you want to add, update, or delete information related to your Account, please go to the administration or settings section of the Nowcom Service. When you update or delete any information, we usually keep a copy of the prior version for our records.
      2. Communications: If you do not want to receive promotional messages from us, please unsubscribe or adjust your communication preferences in the Nowcom Service. If you do not want to receive in-app notifications from us, please adjust your notification settings in the app or your device.
      3. Browser and Devices: The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
  8. Children’s Personal Information
    1. We don’t provide Nowcom Services for purchase by children. If you’re under 18, you may use Nowcom Services only with the involvement of a parent or guardian.
  9. Retention of Personal Information
    1. We keep your personal information to enable your continued use of Nowcom Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.
  10. Other Important Information
    1. California residents, see Privacy Notice for California Residents.

REV. 6/24/2021

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