SINGER GROUP, INC. CONSUMER PRIVACY STATEMENT
Your privacy is important to Singer Group, Inc. and its affiliates (“Singer” or ˙“we”) as is your trust in Singer’s products and services. We want you to know that the information you share with us will be treated with care. This Privacy Statement addresses what personal information we collect and how we handle the personal information shared with us.
This Privacy Statement applies to personal information we obtain from and about individuals interacting with Singer and its products, services, and websites. It does not apply to personal information we obtain in our capacity as an employer. This Privacy Statement covers all Singer controlled subsidiaries.
As you interact with Singer, there will be opportunities for you to provide us with your information. Additionally, we collect certain information about you or your vehicle as further described below.
We also obtain information about you and your vehicle from Singer affiliates, licensees, partners and other sources such as companies that provide lists of potential vehicle purchasers and current owners, if such companies are permitted to share your information with us pursuant to their privacy statements. We may combine information that we receive from the various sources described in this Privacy Statement, including third-party sources, with information you provide, and use or share it for the purposes identified below.
The types of information that Singer collects about data subjects includes:
contact information (such as name, address, city, state and ZIP code, email address and telephone number)
payment information (such as your credit card number, CVV code and expiration date)
information about your vehicle (such as license plate number, vehicle identification number (VIN), make, model, model year, date of purchase, service history, mileage, oil/battery status, fuel or charging history, electrical system function, gear status, and diagnostic trouble codes)
information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information)
demographic information (such as gender, date of birth, marital status and household composition)
marketing profile information (such as the vehicle in which you’re interested)
photographs and videos such as those that you may submit for social sharing
relationships you have with Singer in addition to the servicing of your vehicle (such as through a Singer networking or social club)
Use of Information Collected
The information Singer collects about data subjects and their vehicles will be used:
to provide products and services and maintain customer relationships
to improve the quality, safety, and security of our products and services
to administer your account(s) and process your payments for products and services
to operate our websites and applications, including online registration processes
to autofill data fields on our websites to improve your online experience
to develop new products and services
to provide customer and vehicle support and service (such as recall information)
for warranty administration and validation
to provide information and product updates
to evaluate vehicle performance and safety as described in the vehicle owner manual
for research, evaluation of use, and troubleshooting purposes
to verify eligibility for vehicle purchase or incentive programs
for marketing and analytics purposes
to support the electronic signature and delivery process
to customize and improve communication content
to comply with legal, regulatory or contractual requirements
Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social media and other electronic messages, or via our websites and applications. Singer may send you text messages using an automated telephone dialing system to the mobile phone number you have provided if you have opted into receive text messages. Opting into receive text messages is not a requirement to buy products or services from Singer, and message and data rates may apply. You may opt-out of receiving text messages at any time. See “Choices” below to learn how to manage your communication preferences.
Sharing of Information
Singer will share the information it collects about you or your vehicle in the following instances:
within Singer, with our Singer controlled subsidiaries and affiliates, with Singer partners and with Singer licensees
with our services providers who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them
with our business partners for Singer marketing activities, business partner marketing activities or both
in connection with the sale, transfer or financing of a Singer business or its assets
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a law enforcement request
as required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process
Apart from the purposes listed above, Singer will not share information about you or your vehicle with other third parties for their independent use without your prior consent.
If you do not want to receive marketing communications from Singer, please write to us at Singer Group, Inc., ATTN: Data Protection Officer, 19500 S Vermont Ave, Torrance, CA 90502. Please include your name, address, phone number, and e-mail address with a brief statement explaining the nature of your request. This will allow you to opt out of marketing telephone and email communications and/or to change previously submitted opt-out preferences.
If you opt out of receiving marketing communications from Singer your personal information will not be used for marketing, but may still be used for the other purposes described in this Privacy Statement (such as vehicle support and service).
If you have subscribed to a particular email newsletter or other communication, you should follow the instructions in the email or on a related website to unsubscribe.
If you have opted into receiving text messages from Singer, you may opt-out at any time by following the opt-out instructions in that specific text message program. If you have opted into any of our text message programs and you later decide to change your phone number or cancel your phone plan you should immediately opt-out of any text message programs and re-opt in with your new phone number if you wish to continue to receive text messages from Singer. This will help us ensure we continue to honor your preferences and text the correct phone number.
To measure site activity, provide a better user experience, and tailor our marketing communications, we or Google Analytics may compile information from the cookies, pixel tags, web beacons or other technologies on our websites. This information may be combined with other information collected online or offline about you, including data provided by third party sources, and may be used or shared for the purposes described in this Privacy Statement.
By accessing Singer websites, applications and advertisements, you consent to the collection and use of your information by Google Analytics. You can object to this at any time, and request that your data is not used for marketing purposes, by contacting us as per the above ‘Choices’ section.
At this time, we do not honor “do no track” signals from a web site browser. However, you may refuse or delete cookies. Please refer to your browser Help instructions to learn more about cookies and other technologies and how to manage their use. If you elect to refuse or delete cookies, you will need to repeat this process if you use another computer, or change browsers. If you choose to decline cookies, some of the functionality of a website may be impaired.
The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.
Singer Marketing and/or Brand Partners
Singer and Singer Marketing and/or Brand Partners are separate legal entities with their own privacy practices. For questions about the privacy practices of a Singer Marketing and/or Brand Partner that you are in contact with including opting out of marketing communications, please contact the Singer Marketing and/or Brand Partner directly.
When you communicate with a Singer Marketing and/or Brand Partner, the Singer Marketing and/or Brand Partner may share your information with Singer. Please be aware that each Singer Marketing and/or Brand Partner is a separate legal entity and you should read the Singer Marketing or Brand Partner’s privacy statement to ensure that you understand its privacy practices and procedures. Additionally, because the Singer Marketing and/or Brand Partner may be the first contact with you, the Singer Marketing and/or Brand Partner can answer any questions you may have about its privacy practices. While Singer encourages its Marketing and/or Brand Partners to ensure full compliance with all applicable privacy legislation and has provided information relating to privacy obligations, Singer is not responsible for a Marketing and/or Brand Partner’s compliance with applicable law.
Access and Update
You may contact us via written correspondence to Singer Group, Inc., ATTN: Data Protection Officer, 19500 S Vermont Ave, Torrance, CA 90502. You can also contact us via email to Alex Cox at firstname.lastname@example.org. Please include your name, address, phone number, and e-mail address with a brief statement explaining the nature of your request. You may ask to learn about how to access, review, correct, update, or delete the information about you in our records. We may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law.
How We Safeguard Your Information
We maintain reasonable and adequate technical, administrative, and physical security and confidentiality measures designed to help protect your information from unauthorized access or acquisition. We also require by contract (other than in an emergency situations) that third party services providers acting on our behalf or with whom we share your information also undertake to provide such security and confidentiality measures in accordance with industry standards. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.
How Long We Keep Your Information
We may keep the information we collect for as long as necessary to provide products or services to you, to operate our business, to enable us to communicate with you, for our safety, research, evaluation of use, or troubleshooting purposes, or to satisfy our legal or contractual obligations. Where required, we will anonymize or dispose of the information we collect when we no longer need it for the uses described above. Generally, we retain this information for approximately seven (7) years after our relationship with you has ended, but the term for which we retain this may be longer or shorter. We do so in accordance with our data retention policies and applicable law.
Singer websites do not target or knowingly collect any information from children under the age of 13. In the event that we learn that a person under the age of 13 has provided personal information to us, we will delete such personal information as soon as possible.
International Data Transfers
When Singer and its controlled subsidiaries and affiliates in the United States receive information from Singer controlled subsidiaries and affiliates in Europe, we comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA, UK or Switzerland. Singer U.S. acts as a data processor for its Singer controlled subsidiaries and affiliates in Europe (collectively, “Singer Europe companies”) by providing data hosting, maintenance, support, and troubleshooting of services, as well as other redundant back office support. Singer Europe companies act as controllers of their own European customer data, and Singer U.S. acts as a data processor for these companies. We store your information in the United States, the European Economic Area (EEA), UK, Switzerland, and other locations where we or our service providers maintain servers. With respect to such transfers from the EEA/UK/Switzerland to the United States and other non-EEA jurisdictions, we implement standard contractual clauses and other mechanisms to protect such data.
How To Contact Us
If you have concerns or questions regarding Singer’s consumer privacy practices or this Privacy Statement you may contact us via written correspondence to Singer Group, Inc., ATTN: Data Protection Officer, 19500 S Vermont Ave, Torrance, CA 90502. You can also contact us via email to Alex Cox at email@example.com.
Changes To This Privacy Statement
We may update this Privacy Statement from time to time. We will do so by posting additions or modifications to our website at www.singervehicledesign.com. If we make material changes to the Privacy Statement, we will notify you by placing a prominent notice on our websites.
UK AND EU PRIVACY STATEMENT
This PRIVACY STATEMENT FOR UK and EU RESIDENTS supplements the information contained in the Privacy Statement of Singer Group, Inc. and its affiliates (collectively, “Singer” or “We”) and applies solely to visitors, users, and others who reside in the UK or EU.
European Union data protection law requires that we have a lawful basis in respect of any processing of personal data that we undertake. We have set this out below against each purpose for which the personal data is used:
To provide products and services and maintain customer relationships. Our lawful basis is fulfilment of contracts and legitimate interests in running and managing our business and responding to queries.
To improve the quality, safety, and security of our products and services. Our lawful basis is compliance with laws and our legitimate interests in running and protecting the business.
To administer your account(s) and process your payments for products and services. Our lawful basis is fulfilment of contracts.
To operate our websites and applications, including online registration processes. Our lawful basis is our legitimate interests in operating our website and applications and fulfilment of contracts in respect of registrations.
To autofill data fields on our websites to improve your online experience. Our lawful basis is our legitimate interests in providing a more efficient registration process.
To develop new products and services. Our lawful basis is our legitimate interests in seeking to analyze and improve on our performance and business growth.
To provide customer and vehicle support and service (such as recall information). Our lawful basis is fulfilment of contracts, compliance with applicable laws and legitimate interests in terms of appropriate customer contact and service provision.
For warranty administration and validation. Our lawful basis is our legitimate interests of protecting against fraud.
To provide information and product updates. In respect of direct marketing, we rely on consent. For other information and updates our lawful basis is our legitimate interests in corresponding appropriately with customers.
To evaluate vehicle performance and safety as described in the vehicle owner manual. Our lawful basis is compliance with applicable laws, fulfillment of a contract and legitimate interests of our business in providing and assessing services.
For research, evaluation of use, and troubleshooting purposes. Our lawful basis is our legitimate interests in terms of continuous improvement and also compliance with applicable law where relevant.
To verify eligibility for vehicle purchase or incentive programs. Our lawful basis is in protecting our business in ensuring that individuals are eligible.
For marketing and analytics purposes. For direct marketing and cookies, we rely on consent, for other marketing and analytics our lawful basis is legitimate interests in analysis and improvement and promotion of the business.
To support the electronic signature and delivery process. Our lawful basis is fulfilment of contract.
To customize and improve communication content. Our lawful basis is legitimate interests in improving our communications.
To comply with legal, regulatory or contractual requirements. Our lawful basis is compliance with applicable laws or contract fulfilment.
You have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
The right to rectification – You’re entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing– You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability– You have rights to obtain and reuse your personal data for your own purposes across different services. This enables you to move, copy or transfer your information easily between our IT systems and third parties safely and securely, without affecting its usability.
The right to object –You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).
The right to lodge a complaint – You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
The right to withdraw consent – If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
baseless or excessive/repeated requests, or
further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
If you feel that your Personal Information is processed in a way that does not comply with the EU General Data Protection Regulation (GDPR), we encourage you to let us know so that we may address your concern. We have designated [X] as our Data Protection Officer and [s]he may be reached at [EMAIL] or by writing to us at the address above. We have also designated [X] as our EEA Representative and [s]he may be reached at [x]. You also have the right to lodge a complaint with the relevant supervisory authority which is usually the supervisory authority of the EEA Member State (including the UK and Switzerland) in which you reside. The supervisory authority will be the point of contact with respect to the progress and outcome of your complaint. For UK customers, the relevant supervisory authority is the Information Commissioner’s Office (“ICO”), the contact details of which can be found at https://ico.org.uk/global/contact-us/ .
CALIFORNIA PRIVACY STATEMENT
This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS (“California Privacy Statement”) supplements the information contained in the Privacy Statement of Singer Group, Inc. and its affiliates (collectively, “Singer” or “We”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Statement.
Collection of Personal Information
We may collect certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household (“Personal Information”). Personal Information does not include de-identified or aggregated information. Please see the following disclosure regarding what we may collect, use, and share based on your use of the products and services and the consent(s) you have provided to us:
Your Rights and Choices
The CCPA provides certain consumers (i.e., California residents) with specific rights regarding their Personal Information. This section describes the CCPA rights that you may have and explains how to exercise those rights. You have a right not to receive discriminatory treatment for exercising these privacy rights.
Sale of Personal Information
Singer does not sell Personal Information to third parties.
Right to Know About Personal Information Collected, Used, Disclosed, or Sold
You have the right to request up to twice in a 12-month period that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past 12 months. To exercise your right to know, you may submit a request to us using the methods provided below. Once we receive your request and verify your identity, we will disclose to you the information you request in the following areas: (1) the categories of Personal Information we collected about you; (2) the categories of sources for the Personal Information; (3) our business or commercial purpose for collecting or selling that Personal Information; (4) the categories of third parties with whom we shared that Personal Information; and (5) the specific pieces of Personal Information we collected about you in the preceding 12 months.
Right to Delete Personal Information Collected or Maintained
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. To exercise your right to delete, you may submit a request to us using the methods provided below. Once we receive and confirm your request and verify your identity, we will delete your Personal Information from our records, unless an exception under the CCPA applies.
Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us by via written correspondence to Singer Group, Inc., ATTN: Data Protection Officer, 19500 S Vermont Ave, Torrance, CA 90502. You can also contact us via email to Alex Cox at firstname.lastname@example.org.
Authorizing an Agent
You may designate an authorized agent to submit your consumer request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.
Verifying Your Request
We cannot respond to your request to know or request to delete if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. To verify your identity, we ask that you to provide us with the following information when you submit your request: (1) first name, (2) last name, and (3) phone number or email.
We will use the above information to verify your identity. We will require additional information to verify your identity and fulfill your request depending on the type of request or the information requested by you.
Other California Privacy Rights
If you are a California resident you have the right to request information from Singer regarding the manner in which Singer shares certain categories of your personal information with third parties, for the third parties direct marketing purposes. California law provides that you have the right to submit a request to Singer at its designated address and receive the following information:
- The categories of information Singer disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and
- The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
You may make such a request by contacting us via written correspondence to Singer Group, Inc., ATTN: Data Protection Officer, 19500 S Vermont Ave, Torrance, CA 90502. You can also contact us via email to Alex Cox at email@example.com.