Effective date: February 12, 2018
VIN Voyager, LLC (“VIN Voyager,” “we,” or “us”) provides a website, software, and mobile application platform that enables end users to generate and publish content to advertise motor vehicles for sale, and search for vehicles to purchase. Through the VIN Voyager Vingo app, users can post and search vehicle listing information at various online advertising channels, including VIN Voyager’s own automotive dealer network.
1. Information Collected by VIN Voyager.
User Entered Data. VIN Voyager allows Users to input User Content concerning vehicles that the User wants to advertise, buy, or sell, including vehicle VIN, year, make, model, trim, color, options, mileage, condition, vehicle asking price, vehicle photos, seller and vehicle location, purchaser location, and related information (“Vehicle Listing”). VIN Voyager uses mobile location services to determine the location of vehicles offered for sale, and the location of buyers and sellers. Such location services are required for vehicles to be posted to online advertising channels, including the VIN Voyager Dealer Network. If a User does not consent to our use of location services, such User must manually input their zip code in their account profile. The VIN Voyager app uses a camera and photos to scan VIN barcodes and upload images of vehicles for sale. The mobile location and photographic services may be referred to collectively as “Mobile Services.” To connect vehicle buyers and sellers, VIN Voyager allows advertising and selling Users to provide contact information including their name, zip code, telephone number, and email contact information, along with preferred methods of contact (“Seller Contact Information”). VIN Voyager allows Users to search for and locate vehicles to purchase and provides them an option to describe vehicles they would be interested in purchasing (the “Vehicle of Interest”). VIN Voyager allows Users to manage preferences for receiving notification of events within our Services, such as received purchase offers. VIN Voyager further allows User to opt into receiving text messages related to their purchase or sale of vehicles.
In providing VIN Voyager Services, we collect: (a) your name, username, password, and email address when you register for a VIN Voyager account; (b) the profile information you provide for your user profile (first and last name, picture, address and zip code, phone numbers, email addresses, and text message opt-in); (c) the above-described User Content, Vehicle Listing, Seller Contact Information, and other information that you post to the Services; (d) communications between you and VIN Voyager, including service-related emails, account verification, changes or updates to the Services, and technical and security notices; and (e) your mobile location information. If you participate in the VIN Voyager Referral and Cash-Back Program, you will submit personal information about you and the customers you refer, including without limitation names, telephone numbers, and email addresses. For the cash-back award, you will submit information about the purchase, sale, and/or trade-in of your vehicle. You agree to receive communications from us in connection with your participation in the Referral and Cash-Back Program, and to allow us to communicate with referred customers and Dealers about your participation, including without limitation disclosing to them that you referred them and provided their contact information.
Analytics Information. VIN Voyager uses third-party analytics tools to measure traffic volume and usage trends for the Services. These tools collect information sent by your device or our Services, including web pages you visit and other information that assist us in providing and improving the Services. We collect, aggregate, and use this analytic information with analytic information from other Users so that it cannot reasonably be used to identify any particular User.
Log File Information. Log file information is automatically reported by your browser each time you make a request to access a web page or app, and such information can be provided when the content of the web page or app is downloaded to your browser or device. When you use VIN Voyager Services, our servers automatically record certain log file information, including your web request, IP address, browser type, referring and exit pages, URLs, number of clicks, how you interact with links on the Services, domain names, landing pages, pages viewed, and other similar information. We may also collect similar information from emails sent to other Users which help us track which emails are opened and which links are clicked by recipients. This information provides for more accurate reporting in and improvements to the Services.
Device Identifiers. When you use a mobile device to access VIN Voyager Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device which uniquely identify your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by VIN Voyager. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports, personalized content, and advertising material. Some features of VIN Voyager Services may not function properly if the use or availability of device identifiers is impaired or disabled.
Metadata. Metadata is technical data that is associated with User Content. For example, metadata can describe how, when, and by whom a piece of User Content was collected and how that content is formatted. Users can add or may have metadata added to their User Content including a hashtag to mark keywords when you post a vehicle photo, geotag to mark your location to a photo, or other data. If you geotag your VIN Voyager photos and make them public, your latitude and longitude will be stored with the photo and searchable through a location or map feature.
2. How VIN Voyager Uses Your Information.
Vehicle Listing and Seller Contact Information. Vehicle Listings can be posted to the VIN Voyager Dealer Network by the consumer to advertise vehicles for purchase and sale. When a vehicle is posted in the VIN Voyager Dealer Network, Vehicle of Interest data are shared with auto dealers participating in the network. Mobile Services are used to collect vehicle location and photographic information required for vehicle advertising, such as zip code, scanned VIN barcodes, and vehicle images. VIN Voyager may also use the Seller Contact Information to contact you concerning service updates and promotions.
VIN Voyager Dealer Network. When Users post Vehicle Listing data to the VIN Voyager Dealer Network, the Vehicle Listing, Vehicle of Interest data, and related information will be transmitted to affiliated auto dealers to enable them to identify listings they are interested in and make purchase offers. VIN Voyager will withhold the Seller Contact Information until the User chooses to accept an offer from a specific dealer (“Accepted Dealer”), at which time the User will be alerted that their contact information is being shared with the Accepted Dealer. VIN Voyager will also provide the Accepted Dealer’s contact information to the User.
Vin Voyager Analytics and Marketing. Within the VIN Voyager Services, we may use your information to provide analytic metrics concerning automotive markets, operation of the Services, traffic volume, number and types of vehicles listed and sold, geographic distribution of vehicle listings and sales, consumer behavior and preference trends, and similar business purposes. This information may be also used for internal operational purposes and external marketing, but such use will not include personally identifiable information.
In addition to the specific uses of information described above, VIN Voyager may use the information we receive to: (a) help you efficiently access your information after you sign in and otherwise use the Services; (b) remember information so you will not have to re-enter it during your visit or the next time you visit the Services; (c) provide personalized content and information to you and others, which may include online ads or other forms of marketing; (d) provide, monitor, and improve the effectiveness of our Services, and develop new products and features; (e) monitor operational metrics such as the total number of visitors, traffic volume, and demographic patterns; and (f) diagnose or fix technology problems, and automatically update the VIN Voyager app on your device.
3. Sharing Your Information.
User Content Shared by You. User Content, Vehicle Listing data, Seller Contact Information, and other information that you voluntarily disclose for posting to VIN Voyager Services may become available to the public, subject to specific privacy settings that you select in your profile. Once you have shared User Content or other information or made it public, that User Content and information may be searchable and re-shared by others. If you remove information that you posted to the VIN Voyager Services, copies may remain viewable in cached and archived pages of the Services, or other Users or third parties may have copied or saved that information.
Legal Requests. VIN Voyager may share your personal information in response to a legal request (such as a search warrant, subpoena, or court order) if we have a good faith belief that the law requires us to do so, within or without the United States. We may also share personal information when we have a good faith belief that it is necessary to: (a) detect, prevent, and remedy any fraudulent or other illegal activity; (b) protect VIN Voyager, our affiliated companies, you, and others from harm. User Content and other information we receive about you may be accessed and retained for an extended period of time when it is the subject of a legal request, governmental investigation, investigation concerning possible violations of our terms or policies, or otherwise to prevent harm.
VIN Voyager optionally allows the End User to create a username and password for the purpose of retrieving information from another device. To help ensure account security, VIN Voyager encrypts passwords with a one-way encryption and provides Users with an option to use two-factor authentication on their accounts. VIN Voyager complies with applicable Payment Card Industry Data Security Standards (PCI-DSS) and Payment Application Data Security Standards (PA-DSS). VIN Voyager uses encrypted connections through a transport layer security (TLS) protocol to secure connections between you and the Services. VIN Voyager uses commercially reasonable safeguards to help secure information collected through the Services and we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, VIN Voyager cannot ensure the security of information you transmit to VIN Voyager Services or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and VIN Voyager. We are not responsible for the functionality, privacy, or security measures of any other person or organization.
5. Removing Content from VIN Voyager Services. Users can review, change, and deactivate Vehicle Listing data, Seller Contact Information, and any personally identifiable information from the VIN Voyager app. When you deactivate a Vehicle Listing, the listing information will be removed from online advertising websites that have your active Vehicle Listing, subject to such site’s normal update cycle. If a User wishes to deactivate their VIN Voyager account, such User may request deactivation of their account by sending a request to email@example.com. Following termination or deactivation of your account, VIN Voyager or its service providers may retain your User Content and information for a commercially reasonable time for backup, archival, and/or audit purposes.
6. Account Information and Profile/Privacy Settings. You may review and update your VIN Voyager account at any time by logging in and changing your profile settings. You may unsubscribe from VIN Voyager email communications by clicking on the “unsubscribe link” provided in such communications. As indicated above, you may not opt out of service-related communications (such as account verification, purchase and billing confirmations and reminders, changes or updates to features of the Services, and technical and security notices).