MCGEE CHEVROLET OF GREENWICH MASTER PRIVACY POLICY

Effective Date January 1, 2025

Updated Date May 1, 2026

1.           INTRODUCTION AND SCOPE

The McGee Chevrolet of Greenwich ("we," "us," or "our") is committed to safeguarding the privacy of our customers. Our dealerships take your privacy seriously and are committed to safeguarding your privacy online. Because we do gather certain types of information and data from visitors to our sites, we have developed a Master Privacy Policy statement to help you understand the terms and conditions surrounding the collection and use of that information. In this Policy, personal data ("Personal Data") refers to any information or data that on its own, or in combination with other available information, can identify an individual.

This Master Privacy Policy discloses the types of information we gather and use across all McGee-affiliated dealership websites, mobile applications, and physical retail locations.  This Master Privacy Policy also discloses how you can gain access to and edit any Personal Data that we've collected about you at any time. We operate in accordance with applicable federal and state data protection laws to ensure the highest standard of consumer transparency. This includes, but is not limited to, compliance with:

●        The Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA).

●        The New Hampshire Data Privacy Act (NHPA).

●        The Connecticut Data Privacy Act (CTDPA).

●        The California Consumer Privacy Act (CCPA) / CPRA.

●        The New York SHIELD Act. and Massachusetts Data Privacy Regulations.

●         The Massachusetts Data Privacy Act (MDPA), M.G.L. c. 93H (Security Breaches), and 201 CMR 17.00 (Standards for the Protection of Personal Information).

McGee's products and services are not directed to individuals under the age of eighteen (18), and we request that these individuals not provide any information to us. By providing information to us or by using our products or services, you agree to the terms and conditions of this Privacy Policy and McGee's Terms of Use, which includes mandatory arbitration.

 

Please note that personal information collected in connection with your application for, or receipt of, financial products or services (such as vehicle financing or leasing) is primarily governed by the federal Gramm-Leach-Bliley Act (GLBA) and our separate Financial Privacy Notice, which is provided to you at the time of your transaction.

 

2.           Guiding Principles

We respect the privacy of individuals who visit our Web sites, send us e-mail, or participate in features/services we offer online. Accordingly, our policy regarding online privacy has been developed using the following guiding principles: we maintain a strict "no-spam" policy. Subscribers to our e-mail services (or any other feature/service found on our Web site) will not receive unsolicited e-mail messages from us. We collect information online primarily to provide our visitors with a more relevant experience on our sites. When doing so, we will make every reasonable effort to avoid excessive or irrelevant collection of data. We will take reasonable physical, electronic, and managerial measures to safeguard and secure any information you provide to us (e.g. data will be stored in protected databases on secured servers with restricted access). We will not share any information you've provided to us with anyone without your consent other than to provide the service you've requested. At the time you register for any such service, you will be notified of, and asked to consent to, the sharing of your information with any particular third party necessary to the provision of the requested service.

 

3.           MANDATORY ARBITRATION NOTICE

PLEASE NOTE: EXCEPT WHERE PROHIBITED BY LAW, BY PROVIDING INFORMATION TO US OR BY USING OUR PRODUCTS OR SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND MCGEE'S TERMS OF USE, WHICH INCLUDES MANDATORY ARBITRATION THAT REQUIRES YOU TO ARBITRATE ANY CLAIMS YOU MAY HAVE AGAINST US ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WAIVE THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY.

 

4.           NOTICE REGARDING COLLECTION OF PERSONAL DATA

 

The chart below describes the categories of information and Personal Data we collect about you through various mediums (online, printed documents, emails, or web-based chats) and examples of the purposes for which your Personal Data may be used.

 

Categories	Examples	Purposes
Identifiers (Sensitive Personal Information)	Your name, address, email address, phone number, IP address, social security number, driver's license number, passport number, and other state identification numbers.	To respond to your questions and requests as to our products and services; to process transactions with you; to collect payments from you; to send you marketing material; to confirm your insurance coverage; and to confirm your identity and legal right to drive.
Customer Records	Records (both electronic and paper) containing information about you, including your insurance information, bank account information, credit/debit card information, signature, education, employment, and military service history.	To respond to your questions and requests as to our products and services; to process transactions with you; to collect payments from you; to send you marketing material; to confirm your insurance coverage; and to confirm your identity and legal right to drive.
Internet Activity	Your IP address, browsing/search history, and interactions with our websites or advertisements.	To improve your experiences with our website and online arrangements, to assist us to tailor our operations to your needs and interests, and to help us market products relevant to you.
Protected Classifications	Your sex, age, race, or citizenship; copies of your government ID; and your veteran/military status.	To fulfill the reason for which the information was provided; to confirm your identity; and to determine your eligibility for rebates.
Commercial Information	Records of the vehicles you purchase, lease, or consider purchasing or leasing, along with the service/repair history of your vehicles.	To retain records of our sales and lease transactions as required by applicable law; to   communicate with you regarding our products and services; to appraise vehicles; and to fulfill warranty/recall information pertaining to vehicles.
Biometric Information	Biometric information such as thumbprints or records of your voice.	To communicate with you; to confirm your identity; and (with your permission) for training and quality assurance improvements.
Professional/Educational Information	Your occupation and your employment and education history.	To determine your eligibility for rebates, financing, and other promotions; to enter into transactions with you; and to complete and submit government forms.
Geolocation Data (Sensitive Personal Information)	Geographic location information about an individual, vehicle, or device.	To improve your experiences with us, to tailor our operations, and to carry out our contractual obligations.
Profiles & Inferences	Inferences drawn from information above to reflect preferences or behavior.	To improve experiences, tailor operations, and market relevant products.
Telematics Data	VIN, speed, odometer readings, and safety-related camera/sensor images.	To monitor vehicle health; fulfill remote service; and for safety reporting.

 

You may, at any time, request that we identify the categories and specific Personal Data that we have collected about you, and that we delete certain (but not all) of your Personal Data. We may disclose your Personal Data to service providers and third parties to whom you or your agents authorize us to disclose your Personal Data in connection with delivering our products or services. In addition, we "sell"  or "share" your Personal Data (for example, when you purchase a car from one our dealerships, we share your Personal Data with our automobile manufacturer and distributor partners, which, depending on their use of the information, constitutes "selling" or "sharing" your Personal Data for cross-context behavioral advertising or targeted advertising pursuant to some applicable laws) unless you instruct us not to do so through the "Do Not Sell or Share My Personal Information" link or by contacting us (see How to Contact Us) below.

 

5.           HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect Personal Data and data through various sources, including:

●     Digital Services: Our websites, software applications, and social media pages.

●     Direct Correspondence: Credit applications, contracts, surveys, and trade-in information.

●     Offline Sources: Visits to our dealerships, test drives, or contact with customer service.

●     Vehicle Data: Telematics log data including performance, usage, and safety-related sensor/camera data.

●     Third Parties: Public databases, joint marketing partners, and vehicle manufacturers.

As you interact with our websites, we may automatically collect the following types of data (all as described above): device data about your equipment, usage data about your browsing actions and patterns, and contact data where tasks carried out via our websites remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Section (below) for further details.

 

As noted above, we may receive personal data or information about you from various third parties, including:

·         Account Information and Payment Information from another individual when they purchase a gift for you on our website;

·         Device and Usage Data from third parties, including analytics providers such as Google;

·         Account Information and Payment Data from social media platforms when you log in to our website using such social media platforms;

·         Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;

·         Account Information and Payment Data from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and

·         Account Information, Payment Data, and Financial Data from providers of technical, payment and delivery services.

If you provide us or our service providers with any personal data relating to other individuals you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Master Privacy Policy. If you believe that your personal data has been provided to us improperly, or to otherwise exercise your rights relating to your personal data, please contact us by using the information set out in the "Contact us" section below.

 

6.           COOKIES AND WEBSITE TRACKING TECHNOLOGIES

As mentioned above, we may use cookies and other similar technologies on our website. Cookies are small text files placed on your device that uniquely identify your device and which a website can transfer to a consumer's hard drive to keep records of his or her visit to a website. Cookies allow us to collect information such as browser type, time spent on pages visited, language preferences, and other web traffic data. We and our service providers use the information for security purposes, to facilitate online navigation, to display information more effectively, to personalize your experience while using our website, and to otherwise analyze user activity. We can recognize your device to assist your use of our website. We also gather statistical information about the usage of our website in order to continually improve its design and functionality, understand how the website is used, and to assist us with resolving questions regarding our website. Cookies further allow us to select which offers are most likely to appeal to you and to display them to you. We may also use cookies to see how you interact with our offers.

 

We may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device's hard drive until you delete them or they expire. Different cookies are used to perform different functions, which are explained below:

·         Essential. Some cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, we cannot enable appropriate content based on the type of device you are using.

·         Analytics. We use website and analytics services provided by third parties that use cookies  to measure how you interact with our website and to improve your user experience. and other similar technologies to collect information about website or application use and to report trends, without identifying individual visitors. The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google's practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

 

We, whether acting alone or through our third-party vendors, may also use pixels (also known as web beacons and GIFs) to monitor your interactions with our websites. These pixels collect anonymized information. If you later provide personal information to us via a form or other submission, we may link that information to information collected by the pixels, allowing us to attribute specific activity on our websites to you. Please note that our website may include pixels controlled by our OEM partners. These pixels may collect personal information of website users and share that personal information with the respective OEM.

 

Some of our email marketing campaigns may contain personalized URLs, which direct recipients to personalized landing pages. If you click on a personalized URL, you will be taken to a tracked landing page that will allow us to associate your activity on that page with you.

 

There are several ways to manage our collection of your personal information via cookies and pixels. You can control the use of these technologies at the browser level, by instructing your browser to accept cookies, disable cookies or notify you when receiving a new cookie. Please note that if you reject the use of these technologies on the website, you may still use our website, but your ability to use some features or areas of our website may be limited.

 

7.           HOW WE USE COLLECTED INFORMATION

In addition to the purposes listed above, we may use information collected to:

●     Provide and improve our products, services, and websites and to fulfill the reason for which information was provided to us.

●     Communicate with you, including responding to inquiries and sending safety-related alerts, and to allow you to participate in contests or promotions that we may conduct from time to time.

●     Market our products and services and to present tailored offers to you.

●     To send you administrative information relating to our dealership, our products and services, and any changes to our terms, conditions, or policies.

●     Conduct business operations, such as data analysis, audits, and fraud monitoring.

●     Comply with legal obligations, including law enforcement requests or government regulations.

In any event, and except as otherwise stated in this Master Privacy Policy, we may use or share information that does not personally identify you for any purpose, including for operational or research purposes, for industry analysis, to improve or modify products and services, to better tailor products and services to your needs, and where legally required. If our business is sold, or in the event of a merger, you grant us the right to assign the personal information collected in connection with the sale or merger.

 

8.           SHARING OF COLLECTED INFORMATION

We share Personal Data with the following categories of third parties:

●     Service Providers: For website hosting, analytics providers, data storage, payment processing, and marketing.

●     Manufacturers: Automobile manufacturers (OEMs) for marketing, warranty, and reporting.

●     Financial Partners: Institutions involved in the purchase, lease, or financing of your vehicle, including banks, payment processors, and insurance companies.

●     Legal & Safety: To respond to subpoenas or to protect the rights and safety of McGee or the public.

 

9.           SMS AND TCPA COMPLIANCE

By providing your phone number and opting in via our digital lead forms, you provide your prior express written consent to be contacted by us via automated or manual telephone calls, text messages, or SMS/MMS. Consent is not a condition of purchase, and you may revoke it at any time by replying "STOP". You may always opt-out of receiving future communications from our dealership. Our sites allow users to opt-out of receiving such communications at the point where personal information is requested, or through other means as identified. If you revoke your consent for the processing of your Personal Data (such as by replying 'STOP' to an SMS or through our online portal), we will cease processing such data as soon as practicable, but in no event later than fifteen (15) days from the receipt of your request.

 

10.        YOUR PRIVACY RIGHTS AND CHOICES

Regardless of your state of residency, we provide the following rights to our customers:

 

·         Right to Know or Access: You have the right to obtain confirmation about whether we process your personal information and access a copy of the specific pieces of data held, along with info on processing purposes and recipients.

·         Right to Correct: You have the right to correct or update inaccurate personal information.

·         Right to Delete: You have the right to request deletion of your information, subject to certain legal exceptions.

·         Right to Opt-out (Sale, Sharing, Targeted Advertising): You have the right to opt-out of the sale and sharing of your info to third parties and for targeted advertising purposes.

·         Right to Limit Sensitive Data: You have the right to limit the use of sensitive info (e.g., SSN, precise geolocation) if used to infer characteristics.

·         Right to Data Portability: You have the right to receive your personal info in a structured, machine-readable format and send it to another controller.

·         Right to Nondiscrimination: You have the right to receive equal service and pricing after exercising these rights.

·         Right to Appeal: If we decline to take action on your privacy request, you have the right to appeal our decision within a reasonable period of time. To initiate an appeal, please contact us at compliance@mcgeecars.com with the subject line "Privacy Appeal." We will respond to your appeal in writing within sixty (60) days. If your appeal is denied, you may contact the Attorney General of your state of residency to submit a complaint (e.g., the New Hampshire Attorney General or the Connecticut Attorney General).

·         Global Privacy Control: Our websites recognize Global Privacy Control (GPC) opt-out preference signals.

 

11.        SERVICE AVAILABILITY AND NON-DISCRIMINATION

We will not discriminate against you for exercising your rights. However, certain services (like online credit applications and trade-in appraisals) require personal data to function. If you choose not to provide necessary data, we may be unable to provide those specific services.

 

12.         RETENTION AND DELETION

We retain the below information for as long as necessary for the purpose for which that data was collected and to the extent required to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need Personal Data, we will remove it from our systems and/or take steps to anonymize it.

 

13.        SECURITY

We implement reasonable security measures to ensure the security of your personal information. 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. If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using our websites or by providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our website. We may post a notice via our website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

 

14.        THIRD-PARTY LINKS

Our websites contain links to other sites. We are not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.

 

15.        VIDEO CONTENT

Our websites may contain video content, audiovisual content, or content of a like nature (collectively, "Video Content"). Video Content is provided for the purpose of enhancing your experience within our websites and is, therefore, provided in connection with our provision of automotive dealership-related services. We are not in the business of renting, selling, or delivering Video Content in a commercial manner. By using our websites, you agree that we are not a "video tape service provider" as defined in the Video Privacy Protection Act, 18 U.S.C.A. § 2710.

 

16.        INTERNATIONAL DATA TRANSFERS AND RESIDENCY

Our websites and services are intended for use solely in the United States by residents of the United States. We make no claims that these services are appropriate for use outside of the United States. Any information you provide during your visit to our websites will be processed and maintained on our web server and other internal systems located within the U.S. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the U.S. and other jurisdictions which may not have the same data protection laws as your home jurisdiction. We do not knowingly collect or solicit personal information from residents of the European Union.

 

17.        CHANGES

We may modify this Master Privacy Policy at any time. If we make changes to this Master Privacy Policy, then we will post an updated version of this Master Privacy Policy on our websites. When using our websites or our services, you may be asked to review and accept our Master Privacy Policy. In this manner, we may record your acceptance and notify you of any future changes to this Policy.

 

18.        DATA CONTROLLER AND CONTACT INFORMATION

As required by the Rhode Island RIDTPPA, McGee Automotive Family is the designated Data Controller. To exercise your rights, contact us:

McGee Automotive Family

860 Washington Street

Hanover, MA 02339

Email: compliance@mcgeecars.com

Telephone: (781) 826-8333

 

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