Privacy Policy
Galves Market Data Privacy Policy
Updated: 08/01/19
Overview
Galves Market Data, LLC (“Galves”) is serious about protecting your privacy and recognizes that you care how information about you is used and shared. We appreciate your trust that we will do so carefully and sensibly. This notice (this “Privacy Policy”) describes how we may collect personal information about you, how we may use it, with whom we may share it, what choices you have regarding it, and how we protect it. This Privacy Policy is incorporated into and is a part of the Terms of Use of this Galves Web site (www.galves.com, this “Site”), and the aforesaid Terms of Use is incorporated into and is a part of this Privacy Policy, and we encourage you to become familiar with the terms and conditions contained therein and herein. By accessing and using this Site, you agree that you have read and understand this Privacy Policy, and that you accept and consent to the privacy practices described in this Privacy Policy.
Changes to Privacy Policy
From time to time, Galves may change its privacy practices because of changes in relevant and applicable legal or regulatory requirements, the business or business practices of Galves, or in its attempts to better serve your needs. Notice of such changes to our privacy practices will be given in the manner described in Galves’ Terms of Use for this Site and a revised Privacy Policy will be posted at this location.
What Information Do We Collect?
Galves may collect various types of information from or about you. During the product subscriber registration process, you supply us with basic contact information (such as name, address, telephone number, e-mail address and company name), as well as billing information. This information enables you to take full advantage of the products and services that we offer. Should you license or subscribe to any Galves products or services on or through the Site, the information that you supplied during the registration process, and as a result of using those products or services, may be used to track details about your use activities and your location.
Galves may also retain the content of any correspondence you may have with Galves, and the information and data which applied to your use of Galves’ products and services, regardless of the mode of communication by which such correspondence was made. This information helps Galves to improve the functionality of the Site and the materials, products, and services that we offer on the Site, and which may be of specific interest to you, and to respond more effectively and efficiently to both current and future inquiries.
As with many other Web sites, the Web servers used to operate the Galves Site, and the application services provided on the Site, collect certain data pertaining to you and the equipment and communications method that you use to access the Internet, the Site, and the products and services of the Site. Without combining these data with other sources of information, they do not readily identify you. They do reveal such things as the Internet protocol (“IP”) address assigned to your computer, your location, pages you accessed on the Site, or immediately prior to visiting the Site, and the length of time you spent at the Site.
This information is collected to, among other things, facilitate Site operation and system administration, to generate aggregate, non-identifiable statistical information, and to improve content and content delivery with regard to the Site and the materials, products, and services that Galves makes available on the Site.
Cookies and Location Based Identifiers
Galves uses “cookies” (small text files stored on your computer) and other identifiers and technologies, including GPS technologies to help track and customize your access and use of the Site, and your location. Cookies store and retain information that helps us recognize you when you return to the Site following a previous visit. Cookies may also store any login or ID assigned to you by Galves and the associated password, though this information is stored in encrypted form. Most popular Internet browser packages allow you to configure the browser so as not to accept cookies and other data identifying and location technologies. However, setting your browser to reject cookies and data identifiers may prevent you from taking full advantage of the Site and the materials, products, and services that Galves makes available on the Site.
How Do We Use The Information That We Collect?
In addition to the uses mentioned or described above, Galves uses the information that it collects from or about you to improve the materials, products and services that Galves makes available on the Site, to notify you of changes made to the Site or new products made available on or through the Site, to evaluate your needs and customize Site content delivered to you according to those needs, to facilitate the processing of any uses you make of the Site, to send you promotional material from Galves and some of our affiliates and business associates, and for other legitimate and lawful business purposes of Galves and its affiliates. Specifically, Galves and its affiliates will use your information to perform data, demographics and market analysis regarding car buying and selling preferences and tendencies in order to provide values for cars that you would like to buy and sell. Galves will share your information with its affiliates for the purposes set forth herein. Galves does not share information collected about you with third parties, except as is necessary to provide the products and services herein offered and except as relates to those special programs that we offer in connection with some of our business associates which are an aspect and derivation of the products and services offered on the Galves Web site. When we do share your information with third parties as herein prescribed, we ensure that such third parties’ privacy standards are compliant with those of Galves. It is our policy not to sell lists containing personal information about Site users, registrants, or subscribers.
What Choices Do You Have?
You may update at any time the information about you and your personal preferences that is stored from your use of the Site or subscriber registration. You may also ask us at any time to remove your name from our list of Site users who wish to receive electronic communications and e-mail advertisements from Galves and our affiliates and business associates by simply sending such a request to us at support@galves.com. Once you opt-out, we will honor your choice until you inform us otherwise. Please remember, however, that if we have already shared information about you pursuant to your registration and participation in any special programs of our business associates (as described above), we have no control over how such business associates may further use that information and you will need to contact them directly in that regard.
How Do We Protect Information Collected About You?
Galves places a high value on protecting information transmitted via this Site. For this reason, we use state-of-the-art security solutions, technological and physical safeguards including encryption technology to process payments and to provide secure communication methods. In addition, the Site is protected by a firewall that provides a high level of security. Galves takes commercially reasonable measures to secure and protect your specific information transmitted via, or stored on, our Site, or if and when disposed of by Galves. However, no security system is impenetrable. We cannot guarantee that information users supply will be totally secure. In the event of a data breach, Galves’ policies and procedures will comply with applicable Federal and State data breach notification laws.
Business Transfers
As Galves continues to grow and develop its business, it is possible that its business structure might change or that it might merge or otherwise combine with, or that substantially all of its assets might be acquired by, another company. In any such transactions, customer information generally is, will most probably be, and should be expected to be one of the transferred business assets, and by your use of this Site and the Galves’ products and services, you grant us the right to transfer such information in these instances. Galves would ensure the protection of your information in these transactions.
Retention and Legal Disclosure of Personal Information
Galves may retain your personal information for as long as your account is active or as needed to provide you services, comply with our legal obligations or to resolve disputes and enforce our agreements. It may be necessary by law, for legal reasons, national security purposes or other issues of public importance, or to enforce the terms and conditions of Galves’ Terms of Use, including this Privacy Policy, for Galves to disclose your personal information.
Linked Sites
For your convenience, some hyperlinks may be posted on the Site that link to other Web sites not under the control of Galves. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites. We encourage you to seek out and read the privacy policy of any Web site that you visit. In addition, when you initiate a transaction on a Web site that our Site links to, even if you reached that site through our Site, the information that you submit to complete that transaction becomes subject to the privacy practices of the owner of that linked site. You should read their privacy policies to understand how they use and protect personal information that they collect. Galves is not responsible for the privacy or information practices of its suppliers or any third-party Web sites.
International Transfer of Personal Information
Galves is headquartered in the United States. The information which you provide to us, or that we obtain as a result of your use of the Galves’ products and services, is processed, and stored in the United States. If you are not a resident of the United States, by accessing and using this Site, you agree to having your information processed and stored in the United States, outside of your country of residence, and as a result, different legal rights regarding such information may apply in the United States than in your home country.
Children Under the Age of 16
Our Site is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site. Galves does not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or through any of its features, register on the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to Galves, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe Galves might have any information from or about a child under 16, please contact us at support@galves.com or 877-654-2583.
California Residents Privacy Rights
This section provides additional details about the personal information Galves collects about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information Galves has collected over the last 12 months, including the categories of sources, please see below. Galves has collected the following categories of personal information from individuals within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Galves obtains the categories of personal information listed above from the multiple categories of sources, including you directly, internet service providers, data analytic providers, and operating systems and platforms. For additional details about the methods and manner of collection, as well as the business and commercial purposes for which Galves collects it, see the “What Information Do We Collect?” and “How Do We Use The Information That We Collect?” sections, above.
Galves shares this information with the categories of third parties described in the “How Do We Use The Information That We Collect?” section, above. Within the preceding twelve (12) months we have shared or disclosed the following categories of personal information with our trusted service providers or third parties:
| Personal Information Category | Category of Third-Party Recipients: Business Purpose Disclosures | Category of Third-Party Recipients: Sales |
|---|---|---|
| A: Identifiers. | Service providers and/or trusted third parties | None |
| B: California Customer Records personal information categories. | Service providers and/or trusted third parties | None |
| C: Protected classification characteristics under California or federal law. | None | None |
| D: Commercial information. | Service providers and/or trusted third parties | None |
| E: Biometric information. | None | None |
| F: Internet or other similar network activity. | Service providers and/or trusted third parties | None |
| G: Geolocation data. | None | None |
| H: Sensory data. | None | None |
| I: Professional or employment-related information. | None | None |
| J: Non-public education information. | None | None |
| K: Inferences drawn from other personal information. | None | None |
Galves does not sell (as that term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in “Cookies and Location Based Identifiers” section above.
Subject to certain limitations, the CCPA provides California consumers a right to request to know more details about the categories or specific pieces of personal information Galves collects (including how Galves uses and discloses this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting Galves at support@galves.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
Right to Know. You have the right to know and see what data Galves has collected about you over the past 12 months. This includes:
- The categories of personal information collected about you.
- The categories of sources for the personal information collected about you.
- Galves’ business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom Galves shares that personal information.
- If Galves sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information Galves collected about you (also called a data portability request).
Right to Delete. You have the right to request that Galves deletes the personal information we have collected from you (and direct our service providers to do the same), subject to certain exceptions, including when such information is necessary to complete your transaction or to provide you the requested services. Galves 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Deletion Process. Once you have submitted a deletion request, and we have received verification from you that the request is authentic, you will be provided the opportunity to agree with what personal information will deleted.
Disclosure Rights. You can request certain information about Galves’ disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request may be made once a year free of charge.
Non-Discrimination. You have the right not to be discriminated against for exercising any of the rights listed above. Unless permitted by the CCPA, Galves will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, Galves may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive Galves offers will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us at support@galves.com. You may also utilize the link on our website, www.galves.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom Galves collected personal information or an authorized representative, and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Galves cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm the personal information relates to you. You do not need to create an account with Galves to submit a request to know or delete. Galves will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format. Galves aims to respond to a consumer request for access or deletion within ten (10) days of receiving requests for disclosure or deletion with information on how the request will be processed. If Galves needs additional time the reasons for that will be stated to you within the ten days. Any substantive response to the request will be given within 45 days of receiving a verified request.
If you have an account with Galves, we will deliver our written response to that account. If you do not have an account with Galves, we will deliver our written response by mail or electronically, at your option. Any disclosures Galves provides will only cover the 12-month period preceding our receipt of your request. The response Galves provides will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Galves does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Who Can You Contact For More Information?
Please direct any other questions regarding our privacy practices or this Privacy Policy to Galves by email at support@galves.com, or by calling our customer service line at 877-654-2583.
Acknowledgement
BY USING THIS SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND CONSENT TO THE PRIVACY PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED HEREIN.