General RV US State Privacy Policy
Effective Date: 6/15/2023
This Privacy Policy for California Residents supplements the information contained in General RV's Privacy Policy and applies to consumers who reside in states that have adopted consumer privacy laws. This policy applies to the My General RV App (the “App”), and www.generalrv.com (the “Website”). Because of differences in certain state laws, this supplement is broken into two sections: California (CCPA) Specific Notices, applicable to California residents only, and an Other State Specific Section, that may apply to residents of one or more states with consumer privacy laws requiring such information. Such states as of the date of this Privacy Notice are California, Colorado, Connecticut, Utah, and Virginia (collectively, “US State Privacy Laws”).
California (CCPA) Specific Notices
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
· Publicly available information from government records.
- Deidentified or aggregated consumer information.
· Information excluded from the CCPA's scope, like:
· 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;
· 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.
We have collected the following categories of personal information from consumers within the last twelve (12) months:
Category |
Examples |
A. Identifiers |
· A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
B. Personal information categories listed in Cal. Civ. Code § 1798.80(e) |
· A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. · Some personal information included in this category may overlap with other categories. |
C. Protected classification characteristics under California or federal law |
· Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
D. Commercial information |
· Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
E. Internet or other similar network activity |
· Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
F. Geolocation data |
|
G. Sensory data |
· Audio, electronic, visual, thermal, olfactory, or similar information. |
H. Professional or employment-related information |
· Current or past job history or performance evaluations. |
I. Non-public education information (per 20 U.S.C. Section 1232g, 34 C.F.R. Part 99) |
· Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
J. Inferences drawn from other personal information |
· Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
K. Biometric |
|
We obtain the categories of personal information listed above from the following categories of sources:
· Directly from you. For example, from forms you complete or products and services you purchase.
· Indirectly from you. For example, from observing your actions on our Website or App.
We may use or disclose the personal information we collect for one or more of the following purposes:
· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
· To provide, support, personalize, and develop our Website, App, products, and services.
To create, maintain, customize, and secure your account with us.
· To process your requests, purchases, transactions, and payments and prevent transactional fraud.
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To personalize your Website or App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
· For testing, research, analysis, and product development, including to develop and improve our Website, App, products, and services.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website or App users/consumers is among the assets transferred.
· To communicate with you concerning our services, details about new products and services, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels. Please see the Your Rights and Choices section of this policy to set or change your communications preferences.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
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.
We do not sell personal information. In the preceding twelve (12) months, General RV has not sold personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Do Not Share My Personal Information/Targeted Advertising Opt Out.
Personal Information Category |
Business Purpose Disclosures |
A: Identifiers |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
B: California Customer Records personal information categories |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
C: Protected classification characteristics under California or federal law |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
D: Commercial information |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
E: Biometric information |
|
F: Internet or other similar network activity |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
G: Geolocation data |
· Service providers, such as financial services, technical support, research and analytics providers, etc.
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
H: Sensory data |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
I: Professional or employment-related information |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
J: Non-public education information |
· Service providers, such as financial services, technical support, research, and analytics providers, etc. · Marketing and advertising partners or providers
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
K: Inferences drawn from other personal information |
· Service providers, such as financial services, technical support, research, and analytics providers, etc.
· Public or law enforcement officials, as well as private parties involved in other legal processes
· Companies or other users to whom your data is shared at your direction · Supplemental product providers, such as those who offer vehicle accessories, insurance, etc.
|
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You 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 your request and confirm your identity (see Exercising Your Rights to Know or Delete ), we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
· sales, identifying the personal information categories that each category of recipient purchased; and
· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
· The specific pieces of personal information we collected about you (also called a data portability request).
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete ), 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.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit this form to the following email address, or mail to the following address:
· ATTN: Opt Out, 25000 Assembly Park Dr., Wixom, MI 48393
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may also make a request to know or delete on behalf of your child by emailing us at the above email address.
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, which may include:
· Government-Issued Identification, such as driver’s license or passport;
· Provide personal identifiers we can match against information we may have collected from you previously;
· Provide an account number, recent order number, or other transactional information if you’ve purchased a product or service from us; and/or
· Confirm your request using the email or telephone number stated in the request.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Do Not Share My Personal Information/Targeted Advertising Opt Out.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact optout@generalrv.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.
Do Not Share My Personal Information/Targeted Advertising Opt Out
If you would like to opt out of the sharing of your personal information/data or opt out of cookies-based “targeted advertising,” as defined by applicable state law, please visit this link.
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 prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to optout@generalrv.com or write us at: ATTN: Opt Out 25000 Assembly Park Dr., Wixom, MI 48393.
Other State Specific Section
Sale and Use of Personal Information for Targeted Advertising Programs
If you do not wish for use to use your personal information for targeted advertising purposes, please either visit the settings under your profile on the App or Website or send this form to optout@generalrv.com.We have not sold personal information in the past twelve months. We have also not “shared” or made available personal information for the purposes of targeted advertising in the past twelve months.
Use of De-Identified Information
We may de-identify personal information in a secure manner when we determine it is appropriate as part of our business operations. We take reasonable measures to maintain and use the information in a de-identified manner. We do not make any attempts to re-identify such information, except as permitted under applicable law.
Your Rights Under Applicable US State Privacy Laws
To the extent applicable under US State Privacy Laws, you may have the following rights in connection with your personal information:
· You have a right to confirm whether we process your personal information as well as to access and receive a copy of specific personal information we have collected about you.
· You have a right to deletion of your personal information, subject ot exceptions under applicable US State Privacy Laws.
· You have a right to request correction of any inaccurate personal information we hold about you.
· You have a right to opt-out of our use of personal information for targeted advertising purposes. Please see the section below entitled, “Do Not Sell or Share My Personal Information.”
· You have a right to receive notice of our practices at or before collection of personal information and you have a right not to receive discriminatory treatment for exercising your rights described under this section. We will not discriminate against you based on your exercise of any of your rights.
You can assert these rights only when we received a verified request from you.
Use of Agents
If you are a consumer in a jurisdiction that recognizes the ability to use an authorized agent and wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf to optout@generalrv.com , along with a certified statement, that the agent is authorized to act on your behalf. To verify the request, we may ask you to verify your identity.
Appeals
If you are in a jurisdiction that recognizes your ability to appeal a decision, we have made in connection with your attempt to assert a right under applicable US State Privacy Laws, you may file an appeal of our decision refusing your request to exercise your rights under this Privacy notice. Requests to change our policies or practices are not grounds for appeal. You may request an appeal of such decision by contacting us at: optout@generalrv.com. Please provide the state that you are writing from, accompanies with documentation you may have regarding the matter you are appealing. If your jurisdiction allows you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request, you may do so by consulting the website for your state’s Attorney General’s Office. If you do not have a General RV account, we may not be able to respond to requests to exercise rights under this Privacy notice, including, for example, the right to know or delete personal information. Because we only collect limited information about individuals without an account, we are unable to verify requests from non-account holders to the standard required by US State Privacy Laws.
Retention of Personal Information
We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, and to fulfill the purposes described in your Privacy Policy. Specifically, we retain information for our legitimate and essential business purposes, such as operating, maintaining and improving our services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our terms of use. Our retention of information is based on many factors, such as your relationship with General RV (e.g., whether you are a current General RV account holder); the nature of the information; compliance with our legal obligations; defending or resolving actual or anticipate legal claims. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.
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 .
If you have any questions or comments about this notice, the ways in which General RV collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under State or California law, please do not hesitate to contact us at:
Phone: 888-436-7578
Website: https://www.generalrv.com/opt-out
Email: optout@generalrv.com
Postal Address: General RV Center, Inc.
Attn: Opt Out
25000 Assembly Park Dr.
Wixom, MI 48393