Updated: April 1, 2021
Legal Department, The Detroit Bureau
1122 Oberlin Road
Raleigh, NC 27605
“Professional(s)” means individuals, companies and other organizations or persons engaged in a business relevant to the Sites, including but not limited to, automakers, aftermarket auto service providers, auto product suppliers and other automotive professionals.
“Consumer” (or “consumer”) has its ordinary meaning but generally includes any visitor to or user of the Sites other than Professionals.
Except as otherwise indicated, Professionals, consumers and other persons using the Sites are individually and collectively referred to as “you,” and The Detroit Bureau, together with its affiliates, is referred to as, “The Detroit Bureau”, “we”, “us” and “our.”
We use the Sites to provide you with information, resources, tools, products and services specific to the automotive industry and related markets, and to provide you with information about us and our advertisers, and our respective products and services.
To that end, we want you to understand what kinds of information we gather about you, how this information, particularly Personal Information (defined below), is used and safeguarded, and how you can control its use.
What Information is Collected From Me?
Information You Give Us: Information collected from you will vary, depending on how you access, visit, use or otherwise take advantage of the Sites and what information you may choose to provide to us (whether through email or otherwise). It may be possible to browse various sections of the Sites without submitting any Personal Information.
“Personal Information” means individually identifiable information about you that we collect online or otherwise through the Sites, including, but not limited to, your full name, a username and password, email address, phone number, physical address and for certain e-commerce transactions your credit card information.
Automatic Collection of Information: Like many websites or media on or using the Internet, we automatically track certain information about you as you access, visit, use or otherwise take advantage of our Sites; this is for various reasons, including to help us (i) better understand, offer, operate, improve and modify the Sites, (ii) better understand how the Sites are used and experienced and (iii) enhance, or better understand how we can enhance, your or others’ overall experience on one or more of the Sites, including providing advertising and other information that is relevant to you.
Information from Cookies: Cookies are small files that we or others send to and store on or with your computer so that your computer, browser, mobile app or other application can be recognized as unique the next time you access, visit, use or otherwise take advantage of the Sites or other media. Cookies may also reflect demographic data pertaining to you or other data linked to information you submit. One use or consequence of cookies is to enable you to receive customized ads, alerts, content, services or information.
You are always free to decline any cookies we use by adjusting the settings of your browser, as your browser may permit; however, some products, services or features might not be available or operate properly if cookies are not enabled. Some of our advertisers and third-party service providers may also utilize their own cookies.
In addition, we, our service providers and others sometimes use “web beacons” or “clear GIFs.” These perform statistical and administrative functions, such as ascertaining and measuring site and page traffic, verifying advertising paths, better understanding user interests and activity, gathering related information (such as information relating to a particular browser, device or IP address) and positioning images, and typically do so without detracting from your online experience. Web beacons and clear GIFs are not necessarily designed to collect Personal Information. In addition, if you have provided your email address, we might use a non-human unreadable form (or “hash”) of your email address to deliver, or facilitate delivery of, relevant advertisements and information to you on or by way of the Sites or on or by way of other Websites or media, including, for example, popular social media sites and features.
Information Sharing Disclosure – How Is Information About Me Used and Shared?
The use of information about you depends on the context in which it is collected. Therefore, pay special attention to the categories below that relate to the features of the Sites that you wish to utilize.
We may share the Personal Information we collect from you with your consent or under the following circumstances or understandings.
User-Requested Services and Information: Certain features, products or services on or of our Sites may seek or obtain Personal Information from or about you, which may be used in the following ways:
The information you submit is used by us to provide the information, features, product or service you’ve requested. For example, we might try to show you ads or stories that we think you’ll find interesting based on your activities on our site.
When sharing Personal Information in such a manner, we may also share your computer’s Internet Protocol (IP) address, identification number or location. In addition, we may use and share any registration information that you submit as set forth in the “Registration Information” section below.
- We may use other companies and individuals (1) to perform supporting functions for the various tools, functionality, information, products and services offered through our Sites on our behalf, (2) to perform or support various tasks or initiatives instrumental to the business of, or related to operating or improving, the Sites or (3) to assist us in testing, maintaining or improving the features, content or effectiveness of the Sites or in performing research or development. These service providers may be permitted to receive from us and use information collected from you but will not be authorized by us to use Personal Information for any other purpose other than in connection with performing the support functions for The Detroit Bureau or such other tasks, initiatives or assistance for or expressly permitted by The Detroit Bureau.
User-Initiated Communication: From time to time, portions of the Sites may enable you to send email and other types of messages to us or to third parties and to participate in bulletin boards and discussion groups. All such emails and messages, and all such postings to bulletin boards and discussion groups, become our property once you submit them. Your computer’s Internet Protocol (IP) address may be included in any email that you send, whether to us or to third parties. Whenever you choose to initiate these kinds of communication with us, or anyone else, you may be contacted in return. Also, remember that our bulletin boards and discussion groups are open to the public, and, therefore, your postings can be seen by anyone and are not protected by us or any other entity. Please use your own discretion when deciding whether and what to post and whom to contact. We reserve the right, in our sole discretion, to edit or delete postings from our bulletin boards and discussion groups. This reservation of rights shall not under any circumstances obligate us to conduct such edits or deletions, nor shall it cause us to be liable for any such edits or deletions.
Leads and Referrals
If you participate in or inquire about any lead, referral or similar service we may offer:
- We may use the information you submit, as well as other data we might have or obtain ourselves or from other sources (for example, from cookies), to determine which of our participating Professional(s) may be willing, able and/or compatible to serve your needs or possible interests and to assist them or others in doing so.
- We may forward or share information relating to you, which may include such information as well as Personal Information obtained through our sign-up form or otherwise, to certain Professional(s), which may sometimes include multiple Professionals (such as in cases where a given Professional has a marketing or business relationship with one or more other Professionals and designates them to receive such information, or in cases where the nature of a product, service or feature offered on or through a Site is designed to involve participation by multiple Professionals). Those Professionals or their affiliates, contractors, advertisers, agents or other designees may use such information and contact you regarding your needs or possible interests, as may we ourselves. We always endeavor to make clear when your information is being shared with other Professionals.
- The following paragraph applies only to Professionals; others may not infer any commitments or assurances from such following paragraphs.
Protection of rights
Asset transfers: We continue to develop our business and in doing so might choose to buy or sell, or expand or otherwise restructure (e.g., by way of joint ventures) with respect to, businesses or assets. Personal Information and other information we collect from you is generally one of the assets acquired, transferred and otherwise shared or affected in connection with such transactions.
The Personal Information you provide when you become a registered user or customer of one of the Sites is used primarily to help us customize or enhance your or others’ online experience, increase the convenience of accessing new or existing tools, products and services, and, if applicable, provide the information, features, products and/or services you purchase or request. This Personal Information may also be shared among the Sites to make use of the Sites more convenient by, for example, limiting the number of times you have to register with us. Your email address serves as a unique identifier in our record system, and together with your password is designed to help us prevent unauthorized access to information you choose to store on the Sites. The data you give us about your personal preferences and demographics (e.g., your age, ZIP code, occupation or the like), as well as other information we might have or obtain ourselves or from other sources (for example, based on or related to such data), may be used to help us offer content, advertisements, products and services that we believe will be of interest to you. In addition, we may share this information, in aggregate or other protected form (see “Information You Give Us,” above) or under confidentiality terms, with our current and potential advertisers and service providers so that they, or we, can present and deliver advertisements more effectively. If you forget your password for any registered area of the Sites, we have an automated password recovery system, which can be accessed by clicking on the “Forgot Password?” link on the sign-in page.
- Consumers: Unless you specify that you would prefer not to hear from us, we may use the email address and other information (including Personal Information) you provide at the time of registration to contact you for promotional or other purposes. You may have promotional email communications terminated at any time by opting out through your member profile on the applicable Site, or by clicking on any “unsubscribe” link contained in a promotional email. Please be aware that opting out on one of our Sites does not opt you out from any of our other Sites unless that option is specifically provided. If you would like to request to opt out with respect to all of the Sites please email email@example.com with your requests. The following paragraph applies only to Professionals; others may not infer any commitments or assurances from such following paragraphs.
Special Messaging Consent
By submitting a request or inquiry about (or a request or inquiry for information about), or a request or authorization to be contacted about, real estate-, moving-, neighborhood-, mortgage-, credit-, care- or home-related products, services, offerings, procedures, details or matters you are providing to The Detroit Bureau’s associated advertisers, lead customers (e.g., lead or referral service customers), subscribers and Professionals (each, a “Provider”), and to The Detroit Bureau, your consent to be contacted for marketing, informational and related purposes in connection with such request, authorization or inquiry by one or more Providers and by The Detroit Bureau by telephone device (including, but not limited to, being contacted on a recorded line and potentially by use of automated dialing systems and artificial or prerecorded voice messaging), email, mail or otherwise, based on the phone number, email address and/or other data you have provided. This consent applies even if your phone number, email address or other data is on a corporate, federal, State, local or other do-not-contact type of list or directory (such as the U.S. National Do Not Call Registry). You are not required to consent to receiving autodialer calls, or to otherwise provide this consent, as a condition of purchasing any products or services from Providers or The Detroit Bureau. You agree that your submitted request, authorization or inquiry (as described above) acts as your electronic signature for this consent. You acknowledge that for text, SMS, calls and other electronic messages that message and data rates (for example, from your network provider) may apply. We endeavor to obtain your express consent. If you ever prefer to opt-out, email firstname.lastname@example.org.
Children’s Privacy: Our Sites are general audience Websites and media. If you are under the age of 16 you should not register or provide information on our Sites. We do not collect Personal Information from any person we actually know is a child under the age of 16. If you have knowledge that a child under the age of 16 has submitted Personal Information to us, please email email@example.com.
How Can I Access and Change Personal Information?
If you would like us to no longer use or share with our affiliates, partners or other service providers, Personal Information we may gather from you to market information to you, please send a request to firstname.lastname@example.org. We will take reasonable steps to comply with your instructions. We are not responsible for the acts or omissions of our affiliates, partners or other service providers.
How Is Personal Information Protected?
Whenever Personal Information is stored on our computers, that information is protected from unauthorized access or use by way of passwords or other industry-acknowledged means. In addition, servers of ours that store this information are located behind a firewall. Since your Personal Information is especially sensitive, we take special care to keep it secure. We will only electronically transmit or ask for this information over secure Internet connections using precautions such as SSL (Secure Sockets Layer) encryption (an accepted standard for online security), security keys and password authentication from any third parties receiving this information.
Online Behavioral Advertising (OBA) – Information
Sometimes ads might appear on the Sites that are delivered to you based on OBA methods.
Additional EU Disclosures:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where you have consented to a certain use of your personal data
- Where we need to comply with a legal or regulatory obligation
- To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.
We are the data controller of all personal data collected through our Site. To contact us, please see the section titled “Contact Us”. If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager at email@example.com.
Provision of personal data and failure to provide personal data:
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.
Collection of Personal Information from third-party sources:
We also collect personal data about you from various third parties and public sources.
Withdrawing your consent:
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org.
We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR.
Use of your personal data for marketing purposes:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of Three Ships and its related businesses for marketing purposes.
- To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.
Data Subject Rights:
If you are a situated in the EU, under GDPR, as a data subject, you have the following rights:
- Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being processed and provides access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
- Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
- Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
- Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
- Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
- To exercise your rights under the GDPR, please contact us at email@example.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
Effective Date and Modifications