PRIVACY POLICY (Effective February 10, 2020)
At The Key, LLC dba The Key Cars (“We, us, our”), we respect your privacy and are committed to protecting it. This Privacy Policy describes the types of personal information we collect from consumers through www.thekeyonline.com (the “Site”) and in connection with our products and services, including when you visit our dealerships. This notice also describes how we use the information, with whom we may share it, the choices available to you regarding our use of the information, the measures we take to protect the security of the information, and how you can contact us about our privacy practices.
- Information We Obtain
We may collect and store personal information (such as name and other contact details) that you choose to provide to us when you provide them through the Site or when you contact us. The types of personal information we collect may include:
- Contact information, such as your name and e-mail address;
- Other personal information you may submit to us, such as when you contact us.
- Automated Collection of Information
When you use the Site, we may obtain certain information by automated means, such as browser cookies, device identifiers, server logs, and other technologies. The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with the Site (such as the web pages you visit, links you click, videos you watch and features you use), the pages that led or referred you to the Site, dates and times of access to the Site, geolocation information, and other information about your use of the Site.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use beacons in emails to help us track response rates, identify when our emails are accessed or forwarded, and for other purposes listed below.
These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with the Site; (3) tailor the Site around your preferences; (4) measure the usability of the Site; (5) provide you with interest-based advertising; and (6) otherwise manage and enhance the functionality of the Site.
To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer. Additionally, you can stop certain types of cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting https://www.allaboutcookies.org.
The Site is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.
- Third-Party Analytics
We use third-party online analytics services, including Google Analytics, to collect information about the use of our Site. Google is governed by its own privacy policy, which is available at: https://policies.google.com/privacy?hl=en
To learn more about how Google uses information from sites or apps that uses Google Analytics, visit: https://marketingplatform.google.com/about/analytics/terms/us/
We also use the analytics and reporting system, Foureyes, provided by our website analytics vendor, Adpearance, Inc., an Oregon corporation. Additional Privacy Terms related to Foureyes can be found at https://foureyes.io/privacy-policy
- Interest-Based Advertising
As noted above, we allow third party partners to use cookies, web beacons, and similar technologies to collect or receive information regarding your activities on the Site. We may also share this information with third party advertising companies to use for the purpose of delivering future targeted advertisements to you. This practice is commonly referred to as interest-based advertising or online behavioral advertising. It is customized based on predictions generated over time from your visits across different websites, including our Site and applications.
The Key uses the AdWords and Remarketing Lists features of Google Analytics for Display Advertisers. The Key and Google use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) to inform, optimize, and serve ads based on your past visits to our Site. This means that vendors including Google will display The Key promotional material on other sites you visit across the Internet.
You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting https://tools.google.com/dlpage/gaoptout, to enable you to opt-out of Google’s programs.
- Industry-wide Opt-out:
Many third-party advertising and analytics providers are also members of associations, which provide a simple way to opt out of of analytics and ad targeting, which you can access at:
NAI: https://www.networkadvertising.org/managing/opt_out.aspx
DAA: https://www.aboutads.info/choices/
- How We Use The Information We Obtain
We use and process your personal information for a number of business and commercial purposes. These include:
- Completing your transactions with us;
- Processing payments;
- Sending you promotional marketing material about us, our products, and our services;
- Customizing, analyzing, adjusting, and improving the Site;
- Providing you with important administrative information regarding the Site, such as changes to this Privacy Policy and our Terms of Use and other policies;
- Preventing fraud and other prohibited or illegal activities;
- Complying with requests of law enforcement or data protection agencies;
- Providing you with technical and customer support;
- Seeking your opinion or feedback on our services;
- Enforcement of our legal rights or comply with legal or regulatory requirements;
- How and With Whom We Share Your Personal Information
- Affiliated Businesses. We may share information about you, including personal information, with our affiliated companies, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- When you submit your email address and/or phone number to us through the Site, you expressly consent to being contacted by us by various means, including by phone at the number you provided, text message, email, automatic telephone dialing system and/or an artificial or prerecorded voice.
- Vendors and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
- Legal Authorities. We cooperate with legal authorities and may in some circumstances be required to disclose personal information in response to requests from law enforcement authorities, or in response to a subpoena or other legal process. We also share information about you if we believe we should in order to (i) prevent a violation of the law (ii) protect or defend our interests and our legal rights or property (iii) protect the rights, interests, safety, and security of users of the site or members of the public (iv) protect against fraud or for risk management purposes or (v) comply with prudent legal practice as we may determine, and applicable law or legal process. We also may share your information in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, and in the unlikely even of bankruptcy.
- Your Rights and Choices
You may opt-out of any or all future marketing emails from us by emailing privacy@thekeyonline.com or the unsubscribe link we place at the footer of every email we send that is not in response to an action taken by the user. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, or ongoing business relations.
For questions regarding this Privacy Policy, please contact us at privacy@thekeyonline.com or
The Key
P.O. Box 892220
Oklahoma City, OK 73189
Attn: Privacy
- Storing and Retaining Your Personal Information
Your personal information is stored on servers in the U.S. Also, some of our service providers may store information in servers hosted in countries different from where you reside. As such, your personal information may be subject to the laws of other countries, where the data protection and other laws may not be as comprehensive as your country of residence.
Any personal information that we collect is kept as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or our recordkeeping policies and practices. When we no longer have reason to retain your personal information and as required by our retention policies, it will be destroyed or deidentified in a manner designed to preserve its private and confidential nature, however we may retain inactive archival copies.
- Security
We have implemented administrative, technical, personnel, and physical security measures designed to help protect the personal information stored in our systems against loss, theft and unauthorized use, disclosure or modification. We also employ processes to help protect against unauthorized access to your personal information. Although we take reasonable precautions to assess the reliability of such technology, we rely on the statements of the vendors of those products and services as part of its security evaluation. While we have endeavored to create a secure and reliable site for users, the confidentiality of any communication or material transmitted to/from the site, and the security of your personal information, cannot be guaranteed. We urge you to take every precaution to protect your personal information when you are on the Internet.
- California
If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with the right to request that we disclose certain information to you about its collection, use, disclosure and sale of your personal information over the past 12 months, and the right to request that we delete any of your personal information that we have collected from you, subject to certain exceptions. To exercise these access and deletion requests, please submit a verifiable consumer request by emailing us at privacy@thekeyonline.com or sending your request to The Key, Attn: Privacy, P.O. Box 892220, Oklahoma City, OK 73189. Requests must: (a) include your name, email address, street address, city, state and zip code in order for us to verify your request; and (b) describe your request in sufficient detail to allow us to understand, evaluate and respond to it. We are only required to respond to two such requests per customer each year.
In the past 12 months, we may have shared the following categories of personal information, which are further described in section 1of this Privacy Policy, of California residents for business and operational purposes, including to process transactions and for the other purposes set forth in sections 1 through 3:
- Identifiers;
- Commercial information;
- Online activities;
- Telephone number;
- Date of birth;
- Demographics;
- Geolocation data;
- Records of your interactions with us;
- Credit report information; and
- Financial information.
Section 3 of this Policy further describes the ways in which we may share your information with third parties. Some of this sharing may be considered a “sale” under the CCPA. California residents have the right to opt out of the sale of their personal information. To do so, please email us at privacy@thekeyonline.com or send your request to The Key, Attn: Privacy, P.O. Box 892220, Oklahoma City, OK 73189. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
You may designate an authorized agent to make a request under this section on your behalf. To do so, please submit a written form signed by you and your authorized agent that authorizes your agent to act on your behalf, such as a power of attorney.
We will not discriminate against you for exercising your rights under the CCPA.
- Nevada
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacy@thekeyonline.com
- International Transfer
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the site from outside of the U.S., please be aware that information collected through the site may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the site or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.
- Children
The site is intended for a general audience and is not directed at children under (13) years of age.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacy@thekeyonline.com. We will remove the data to the extent required by applicable laws.
We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without their affirmative authorization.
If you are a California resident under 18 years old and registered to use the site, you can ask us to remove any content or information you have posted on the site. To make a request, email us at the email address set out in “Contact Us” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Changes to this Privacy Policy
The Key reserves the right to make changes to this Privacy Policy at any time and for any reason, so please revisit www.thekeyonline.com frequently. If we make a material change to our Privacy Policy, then we will notify you either by email or by posting a notice of the Site. If The Key, in its reasonable discretion, believes that any part of this Privacy Policy must be amended in order to comply with any legal requirements, the amendments may take effect immediately or as required by law and without any prior notice. All changes are effective as of the date indicated at the top of this page, and your continued use of the Site and other services after the indicated date will constitute acceptance to be bound by those changes.
