FordDirect Privacy Statement
EFFECTIVE DATE: February 1, 2019
SUMMARY OF PRIVACY STATEMENT
At FordDirect, we care about privacy and believe in providing transparency to consumers about our information handling practices. This Privacy Statement applies to personal information – information that identifies you or reasonably can be linked to information that identifies you – that FordDirect collects through your use or interaction with our websites, applications, social media, software, and other services provided by or on behalf of FordDirect (collectively, the “Services”). We will continue to share your information as described in this notice, even after the end of your relationship with us. FordDirect is a member of the Digital Advertising Alliance (DAA) and adheres to certain DAA principles.
Information We Collect
The information we collect through our Services may include:
- your contact information (name, postal or email address, phone number, etc.);
- your demographic information;
- information about the device you use to connect or interact with our Services, including geo-location;
- details about your online activity, use and interaction with our Services;
- your vehicle information;
- your financial information (income, assets, employment information, etc.)
- your shopping and other preferences; and
- social media details and any other information you choose to share.
How We Collect Information
We collect information about you from a variety of sources, including:
- details you choose to provide via our Services;
- from our affiliates;
- from our business customers;
- from outside, third-party sources; and
- automatically, from devices that you use to connect or interact with to our Services.
How We Use Your Information
We may use the information we collect to:
- provide the Services;
- communicate with you;
- provide and promote our products and Services;
- market to you;
- operate our business;
- analyze the use of our products and Services;
- facilitate employee recruitment; and
- comply with applicable laws, rules and our policies.
We may share the information we collect:
- within our enterprise;
- with our suppliers;
- with our affiliates, Dealers, Dealer Associations, and business customers;
- with our marketing partners;
- as we otherwise may notify you; and
- if FordDirect or its assets are acquired.
At FordDirect, we care about privacy, and we believe in providing transparency to consumers about our personal information practices. This Privacy Statement explains how FordDirect collects, uses, discloses, and protects your personal information.
FordDirect is dedicated to helping visitors to our websites and those that use and interact with our Services connect with Ford and Lincoln dealers (“Dealers”), Ford Dealership Associations (“Dealer Associations”), and Ford Motor Company (and its affiliates and subsidiaries) to learn about Ford and Lincoln vehicles and related products and services.
This Privacy Statement applies to the personal information FordDirect collects about you through websites, applications, social media, software, and other Services provided by or on behalf of FordDirect. When you use or interact with the Services, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Statement.
If a Service is co-branded or developed by a third party (such as RouteOne) or linked to a third party, the third party’s privacy statement may apply in addition to or in lieu of this Privacy Statement.
INFORMATION WE COLLECT
Information About You. The information that you provide directly to us and that we obtain from others is what we need to serve you, our affiliates and business customers. This information may include your contact details (such as name, postal and email addresses, phone number, social media handles and other online aliases); information specific to the Service you request (such as financial information when you apply for credit); details about your vehicle and Dealer transactions; contact information of individuals with whom you would like to share FordDirect content; social media information; demographic and household information; your responses and engagement with our Services; and other information you may choose to share with us by interacting with our Services or with our affiliates, business customers, suppliers or other businesses that share information with us.
Information About Your Device. The information we collect by automated means also helps us, our affiliates and our business customers to provide and tailor various products and services. Examples of information we collect by automated means include the following:
Usage Information. We and our suppliers may automatically collect your usage activity, preferences, and browser details (such as your IP address and browser type), as well the ID and type of the device you use to connect or interact with our Services, and other details about your use or interaction with our Services. This may also include the collection of information about your online activities over time and across third-party websites or online services and across devices that you use.
FordDirect does not itself respond to web browser-based do-not-track signals. However, certain of our websites participate in the AdChoices program. If the website that you are visiting displays an AdChoices icon, you may click on the icon and follow instructions to adjust your privacy preferences. If you opt-out using AdChoices, our websites that participate in the program will no longer collect information about your online activities over time and across third-party websites or online services for behavioral advertising purposes.
Location Data. Some of our Services may collect geo-location data to provide or improve our Services and location-related functionality, such as the location of your nearest Dealer and (ii) your precise location while at a Dealer. We may link location data to other information we have collected about you.
HOW WE COLLECT INFORMATION
Information You Provide. We and our suppliers collect the information you voluntarily provide to us in connection with using our Services, including through product inquiries, requests for vehicle information, financing requests, technical services or questions, product registration and support, events and promotions, job applications, other inquiries and transactions. Our suppliers also may collect information from you, including, for example, when you participate in our contests, sweepstakes, surveys, and other promotions. Some portions of the Services may allow you to submit comments, reviews, ratings and other content.
Information We Obtain from Affiliates, Business Customers, Suppliers and Others. We may obtain information about you from outside sources. For example, our affiliates, Dealers and Dealer associations that deploy FordDirect products and Services and suppliers may share with us certain information you provided to them. They may also inform us whether you have been approved for credit and related information. We also may obtain demographic and other information about you from third parties. If you engage via social media with us, our affiliates, our business customers, or our suppliers, the social media platforms also may share certain information with FordDirect. You may be able to adjust your social media privacy settings to limit the sharing of your social media data.
DATA COLLECTION AND USE BY THIRD PARTIES
Our Services may include third-party advertising, promotions, co-branded features, links to other websites, and other programs offered by or in collaboration with third-party businesses, such as Facebook, Microsoft and Google. In addition to collecting information directly from you, these third-party businesses may use tracking technology to measure the effectiveness of their ads, personalize or optimize advertising content, and track users who click on the links made available through the Services. We also use Bing Universal Event Tracking (UET) from Microsoft Bing Ads that places a tag on your computer when you visit one of our websites through Bing Ads advertisements. The UET tag is used for user tracking and data sharing with third parties for advertising and marketing purposes, and to measure ad effectiveness. For more information about Microsoft's privacy practices, please see Microsoft's Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement. When you use or interact with our Services, these third-party businesses may collect information about you, including your online activities over time and across third-party websites or online services. We are not responsible for the privacy practices of these third parties, Dealers, Dealer Associations, and their suppliers, and we encourage you to read their privacy policies, which may apply to these third-party programs. Some of the ads you receive on websites are customized based on predictions about your interests generated from your visits to different websites. This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising. The Digital Advertising Alliance (“DAA”) provides a “Consumer Opt-out" for certain companies that have agreed to provide that functionality.
HOW WE USE YOUR INFORMATION
A primary use of your information is to serve you, which requires certain sharing with our affiliates and business customers. The following are examples of the types of general purposes for which we may use your information.
Provide Products and Services. We may, for example, use your information to complete a transaction you have asked us to do, including e-commerce transactions or “get a quote” or “find a dealer” requests, or to send you communications regarding products, service reminders or vehicle information. We may also, for example, use your information to provide you with an improved experience when interacting with us, our affiliates, Dealers and Dealer Associations.
Operate our Business and Develop and Improve Our Products and Services. Examples include using information collected through cookies and similar technology to better understand how our Services are used, develop new offerings, or personalize your experience when using the Services.
Customer Service. If you request support or other information, we may use your information to respond to your request. We may follow up with you to notify you periodically about important topics, like Services updates or changes to our Privacy Statement.
Marketing. We may use your information to let you know about current offers, invite you to participate in those offers and manage your participation in them. We also may use information about you, your use or your interaction with our Services to tailor our offers to your preferences or to offer you products and services that we believe may be of interest to you. Dealers, Dealer Associations and our affiliates may use your information for their own marketing purposes. Among other privacy choices described in this Privacy Statement, you may direct us to not send you email marketing communications by clicking on the unsubscribe link included in the emails you receive from us.
Recruitment and Job Applications. We may use the information submitted on resumes and similar documents through FordDirect and our suppliers for the purpose of employment consideration. We may keep your information on file for future consideration.
Compliance with Legal Requirements, Rules and Internal Policies. We may be required by law or internal data retention policies to maintain information about you for a certain period of time, or to notify you of a security breach. We also may be required by social media platform rules (such as Facebook) to handle the social media information you or the platform share with us in a certain manner.
A primary use of your information is to serve you, which requires certain sharing with our affiliates and business customers. This section describes the types of organizations with whom we may share your information.
Within FordDirect. FordDirect may authorize access to your information within our enterprise, by our employees and other personnel, to fulfill our obligations to you and to operate our business.
Affiliates, Dealers, Dealer Associations and Suppliers. Our affiliates, Dealers, Dealer Associations and suppliers may access and use your information for the purposes we describe in this Privacy Statement, including as necessary to provide functionality, products, and services to us and you in connection with the Services. For example, when you register for a sweepstakes, a supplier may process the sweepstakes entry. FordDirect requires suppliers to process your information under the direction of FordDirect and in accordance with contractual restrictions and applicable law. We also may share data collected through cookies and similar technology with our suppliers to advertise or market to you on other websites as you browse the web. We may also allow our affiliates, Dealers, Dealer Associations and suppliers to have access and use aggregate statistics – statistics not linked by us to any specific consumer – about consumer behavior, sales, online activity patterns, and related Services information. Except as necessary to provide you with the Services, we will not provide our affiliates with personal financial information that we obtain when you use the Services to submit a request for credit.
Marketing Partners. We may share your information with our marketing partners when, for example, we participate in a co-branded promotion with another company. Other than as described in this Privacy Statement, we will not share your information with third parties for their own marketing purposes. Except as necessary to provide you with the Services, we also will not provide our marketing partners with personal financial information that we obtain when you use the Services to submit a request for credit.
Your Public Comments. Some portions of our Services may allow you to submit comments, reviews, ratings and other content. This content may be displayed on the Services and may be viewable by other users of the Services or the public generally.
Mergers, Acquisitions or Insolvency. If FordDirect should ever file for bankruptcy or merge with another company, or if FordDirect should decide to buy, sell, or reorganize some part or all of its business, FordDirect reserves the right to disclose your information, including to prospective or actual purchasers in connection with one of these transactions.
As Required by Law and Other Disclosures. FordDirect may be required to disclose your information if it:
- believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority;
- would potentially lessen our liability in an actual or potential lawsuit or investigation; or
- is necessary to protect our or others' rights or property.
We take reasonable measures to secure our systems and protect your personal information. When we receive your personal financial information (for example, when you use the Services to submit a request for credit), we protect your information from unauthorized access and use with security measures that comply with federal law. These measures include computer safeguards and physical controls. However, data transmissions over the Internet and otherwise can never be guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us and you do so at your own risk.
By providing your email address to us or using the Services, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically. You may have a legal right to receive this notice in writing. To receive a free written notice in the event of a security breach (or to withdraw your consent from receiving electronic notice), or if you want to update the contact information you have previously provided to us, you should contact us at firstname.lastname@example.org.
ACCESS AND CONTROL OF INFORMATION YOU HAVE PROVIDED TO US
You may request to access, correct, update or delete the personal information you have provided to us, or otherwise adjust your privacy preferences by writing to us at email@example.com. We may limit or deny access to information where providing such access is unreasonably burdensome or expensive under the circumstances, or as we otherwise deem appropriate. In addition, please note that we may not be able to edit or delete your information stored with our third-party service providers, or we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
We may use or share non-personal information, aggregated information, de-identified or pseudonymized information, and statistical information for any lawful purpose. Any obligations or restrictions contained in this Privacy Statement do not apply to such information.
Our Services are not directed at children or intended to be used by children. Do not send any information about yourself to us if you are under the age of sixteen (16). In addition, if we learn a person under the age of thirteen (13) has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately at firstname.lastname@example.org.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you may request that we provide to you:
- a list of the categories of personal information about you that FordDirect has disclosed to third parties for the third parties' direct marketing purposes during the calendar year preceding your request;
- the names and addresses of such third parties; and
- if the nature of the third parties' business cannot reasonably be determined from their names, examples of the products or services marketed, if known to FordDirect, sufficient to give you a reasonable indication of the nature of the third parties' business.
To submit your request, please email email@example.com.
This is a U.S. website, and this site and our Services are subject to U.S. laws, including those governing the privacy and security of your information. If you use or interact with the Services, you are transferring your information to FordDirect in the United States. By using the Services or providing your information to us through the Services you consent to the transfer of your personal information to the United States, and our handling of your information in accordance with applicable U.S. requirements.
CHANGES TO THIS PRIVACY STATEMENT
In the future, we may change our Privacy Statement, and we will post the new Privacy Statement on www.forddirectprivacy.com in advance of the date it becomes effective. You agree to the new Privacy Statement by continuing to use or interact with the Services.
RETENTION OF YOUR INFORMATION
We retain your information for as long as it is necessary and relevant for the purposes described in this Privacy Statement. The information we retain about you will be handled in accordance with this Privacy Statement.
If you have any questions, comments, or concerns about our information practices or this Privacy Statement, please email us at firstname.lastname@example.org or write to us at:
FordDirect Legal and Compliance Department
Attn: Data Privacy
4 Parklane Blvd, Suite 675
Dearborn, MI 48126