Privacy Policy

Howard & Pepper, Inc. doing business as Trailer Hitch RV (hereinafter referred to as “Dealership” or “we” or “us”) respects your privacy and the information that you have entrusted to us. This Privacy Policy describes the Dealership’s privacy practices in connection with its website and other aspects of its business, including its offline interactions with customers. This Privacy Policy also describes the rights and choices available to consumers with respect to their personal information. Please review this Privacy Policy carefully before accessing the Dealership’s website and/or using its services. By using our website and/or accessing any of the Dealership’s services, you consent to the collection and processing of all personal information provided by you and sharing of such information in accordance with the terms of this Privacy Policy.

The Dealership may provide additional or supplemental privacy policies to individuals for specific interactions at the time it collects personal information, such as employment interactions or collections of credit information. These supplemental privacy policies will govern how the Dealership may process the information in the context of the specific interaction.

Collection of Your Personal Information

The Dealership collects personal information that you, the consumer, voluntarily provide to us when expressing an interest about any of our products or services or when otherwise contacting us. We also may collect personal information from one of our trusted third-party service providers, which are more thoroughly described below. The personal information that we collect depends on the context of your interactions with us and the products or services that you express interest in.

We collect the following categories of “personal information:”

• Audio/Video/Visual Information such as photographs, recorded calls, voicemails, and video.
• Commercial Information such as vehicles, products, services, and repairs purchased, obtained, or considered; personal property records (e.g., vehicle titles and registration cards); or other purchasing or consuming histories or tendencies.
• Customer Records as defined under California Civil Code Section 1798.80(e), such as digital and electronic signatures, telephone numbers, insurance policy numbers, credit and debit card numbers, financial and credit-related information, physical characteristics and descriptions (e.g., government identification), bank account numbers, and employment history.
• Biometric Information such as voice recordings of telephone conversations and completing a thumbprint form to sell, purchase and/or finance a vehicle.
• Education Information such as diplomas and transcripts for financing and student rebate eligibility (if offered by the Dealership).
• Geolocation Information such as tracking and user-enabled location identification, as permitted by law.
• Sensory Data such as audio information from voicemail messages and/or recorded phone calls (with consumer’s consent).
• Personal Identifiers such as real name, alias, postal address, IP address, email address, online identifier, social security number, driver’s license number, vehicle identification number, credit information, mileage information, passport number, cookies, pixel tags, and similar identifiers.
• Inferences that can create a profile about you reflecting your product or vehicle preferences, psychological trends, predispositions, purchasing tendencies and behaviors.
• Internet and Network Activity such as interactions with our websites, applications, and advertisements, your IP address, and the dates and times you access our websites.
• Professional/Employment such as job title, occupation, company or business name, and employment history information.
• Protected Classes under California or federal law, such as gender, age, and veteran status.

We collect personal information through a variety of different ways and from a number of different sources. In addition to collecting this information directly from you, the consumer, the Dealership also collects the above-listed categories of personal information from the following sources:

• Advertising Networks & Agencies such as digital advertising companies and other marketing firms.
• Finance Companies such as companies and institutions that offer loans, lease programs, and other financial services to our customers.
• Credit Reporting Agencies such as Experian, Transunion and Equifax that gather account information from various creditors and provide that information to dealers in connection with an application for credit.
• Vendors and Service Providers, such as advertising agencies and Dealership-focused software and marketing companies.
• Directly from Consumers through our website forms and via in-person applications, forms, and contracts.
• Government Entities such as the Department of Motor Vehicles (DMV) and various other state and federal agencies.
• Insurance Companies that provide us with information relating to consumer insurance coverage, vehicle collisions, auto accidents, and other claims.
• Online Lead Providers and third-party websites that collect and share data relating to consumers whose product preferences or inquiries align with the offerings of our Dealership.
• Social Media Networks such as Facebook, Instagram, YouTube, and other platforms used to run various advertising campaigns.
• Vehicle Manufacturers for which we are franchised to sell new motor vehicles.
• Our Affiliates, such as other dealerships or businesses that we have an ownership or contractual relationship with.

The Dealership’s websites and communications through the websites may contain links and pointers to other third-party websites, including, without limitation, business and advertising partners. This Privacy Policy does not apply to these third-party websites, and we are not responsible for the privacy practices, policies, or content of any such third-party websites, even if you link to them through the Dealership’s website. We have no control over how such third-party websites collect or use personal information, and we have no responsibility for any personal information you provide or content you post on such third-party websites. We encourage you to review the privacy statements of websites you choose to link to from our website so that you can understand how those websites collect, use, and share your information. We are not responsible for the privacy statements or other content on websites outside of our website.

Use of Your Personal Information

We use the categories of personal information listed above for one or more of the following business purposes:

• Advertising & Marketing: To send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
• Contextual and Behavioral Targeting: To provide contextual customization of ads shown as part of an interaction with our website or application, such as through the use of “first-party” or “session” cookies.
• Counting Ad Impressions & Website Interactions: To audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.
• Customer Service: To provide customer service, respond to consumer inquiries, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
• Defending Against Claims & Litigation: To defend against or respond to potential or actual claims and litigation, including, but not limited to, those against the Dealership or the manufacturer of a particular vehicle or product we’ve sold.
• Fraud Prevention: To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.
• Processing Transactions: To process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility for manufacturer rebates, and perform similar activities.
• Safety: To protect the safety, security, and legal rights of our customers, our third-party service providers, and manufacturing partners.
• Sales, Service, and Warranties: To process, complete, and maintain records on transactions including servicing or purchases of vehicles, products, parts or accessories; to reserve a vehicle that a customer expressed an interest in, to schedule, manage and keep track of customer appointments; to maintain records of when customers decline a service or sale; and to complete vehicle appraisals.
• Providing Financing: To provide or facilitate financing in connection with a vehicle purchase, lease or related products or services.
• Auto Ownership Records: To create and maintain vehicle titling/registration, state record retention/access requirements and judicial or state agency inquiries.
• Business Transfers: In the event that our Dealership sells or transfers a particular portion of its business assets, consumer information may be one of the business assets transferred as part of the transaction.
• Other Purposes: To fulfill any other purpose for which you provide information to us or to which you consent.

We may keep track of the websites and pages our users visit within our website, in order to determine what services or products are the most popular. This data is used to deliver customized content and advertising within our website to customers whose behavior indicates that they are interested in a particular subject area. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and other services you visit. Because there is no consensus among industry participants as to what “Do Not Track” means in this context, like many websites and online service providers, the Dealership currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.

Sharing Personal Information

We do not sell, rent, or lease your personal information to third parties. In order to provide our products and services to you, we may share data with trusted third-party service providers to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. When we disclose personal information to a service provider, we enter a contract that describes the purpose and requires the recipient to both keep personal information confidential and not use it for any purpose except performing the contract.

We will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Dealership or the website; (b) protect and defend the rights or property of the Dealership; and, (c) protect against malicious, deceptive, fraudulent, or illegal activity.

Retention of Personal Information

In general, we will only retain your personal information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of information and the reason that we have the information.

Use of Cookies

Our website may use "cookies" to help you personalize your online experience. “Cookies” are small data files which are transferred from our website to your computer’s hard drive. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize our pages, or register with our website or services, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as shipping addresses and so on. When you return to our website, the information you previously provided can be retrieved, so you can easily use our features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please note that disabling cookies may interfere with the interactive features of our services or websites you visit.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to aggregate and analyze data about your use of our website. The information about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purposes of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. To learn more about how Google collects and processes data, you may review its policy at https://policies.google.com/technologies/partner-sites.

Children Under Thirteen

We do not knowingly collect personally identifiable information from children under the age of thirteen. We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If we learn that a child under the age of thirteen has submitted information about themselves to us, we delete it as soon as possible. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address the issue.

Opt-Out & Unsubscribe

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from us by contacting us.

Your Rights Under the CCPA

If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA”) regarding your personal information. However, these rights are not absolute, and, in certain cases, we may decline your request as permitted by law.

1. Right to Know About Personal Information Collected, Disclosed, or Sold

   You can request the following information about how we have collected and used your personal information during the past 12 months:

   • The categories of personal information that we have collected about you.
   • The categories of sources from which we collected personal information.
   • The business or commercial purpose for collecting your personal information.
   • The categories of third parties with whom we share personal information.
   • The specific pieces of personal information we collected about you.
   • If we sold your personal information, a list identifying the personal information categories that each category of recipient purchased.
   • If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

2. Right to Access Personal Information

   You can request a copy of the personal information that we have collected about you during the past 12 months.

3. Right to Deletion

   You are permitted to ask the Dealership to delete the personal information it has collected from you. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 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, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provide by law; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligation, exercise or defend legal claims; or make other internal and lawful uses of the information that is compatible with the context in which it was provided to us.

4. Right to Opt-Out of the Sale of Information

   If we sell your personal information, you can opt-out. In addition, if you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

5. Right to Non-Discrimination for the Exercise of Your CCPA Rights

   You are entitled to exercise the rights describe above free from discrimination. This means we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

6. How to Exercise Your Rights

   You may exercise your California privacy rights by contacting us by phone at (800) 847-2989 or by email at info@trailerhitchrv.com.

   Only you, or a person you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. To protect against fraud, identity theft, and the unauthorized disclosure or deletion of personal information, we require that consumers submitting requests under the CCPA first verify their identity. This may include a combination of phone verification, email verification, and one or more questions regarding the consumer’s particular interaction or transaction with our dealership. We will also need to confirm your California residency to process your right to exercise your information, access, or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity and understand and respond to the request. If the consumer fails to verify their request via these methods, or the information provided by the consumer otherwise does not match our existing records, we will deny the request.

   You may only make two requests over a 12-month period. The Dealership will respond to your requests within 45 days of receiving the request and will provide information from the 12-month period prior to your request. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Security

We take precautions to protect your information. The Dealership maintains reasonably physical, electronic, and procedural safeguards designed to help us protect your nonpublic personal information against loss, misuse, disclosure, and alteration. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

While we endeavor to use reasonable efforts to safeguard the confidentiality of your information, the Internet is not totally secure. Due to the possibility of transmission errors, hacking, or other unauthorized third-party activities, we cannot guarantee that data related to the services will remain secure. If we become aware of a security breach involving such data, the Dealership will make all legally required disclosures, consistent with our ability to determine the scope of the breach, our need to restore the integrity of the system and the needs of law enforcement.

Changes To This Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion at any time. When we make changes to this Privacy Policy, we will post the updated Policy on the website and update the Policy’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such change.

How To Contact Us

If you have any questions about this Privacy Policy or to exercise your rights provided under the CCPA, please contact us by email at info@trailerhitchrv.com or by phone at (800) 847-2989. The Dealership will use reasonable efforts to supply you with requested personal information or delete your personal information from our databases.

Effective Date: January 1, 2022