Privacy Policy
Welcome to Vroompulses’ Privacy Policy.
You can use the links below to get to specific topics.
What does this Policy cover?
What data do we collect, use, and share?
What data do we collect?
How do we use your data?
Cookies
When do we share data with others?
Social features
Why we can use your data
How long do we keep your data?
Retention & Deletion
How can you control your data?
Your data choices
Communication preferences
Region and Service-specific notices
Changes to this Policy
Contact Us
What does this Policy cover?
At VroomPulse , d/b/a VroomPulse (“us”, “we”, “our” or the “Company”) we value your privacy and the importance of safeguarding your data. This Privacy Policy (the “Policy”) describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Policy, personal data (“Personal Data”) refers to any information that on its own, or in combination with other available information, can identify an individual.
This Policy tells you how we collect and use your personal data (also known as personal information). It also informs you about how we keep your data safe and the choices you may have, so please make sure you read it.
We want this Policy to be easy to read. In some sections, you can click to get more details about what we do. Please note, that all parts of this Policy apply to all the things we do. We may give further notices for some Services and places, and these should be read in conjunction with this Policy.
Our Services may contain links to other sites. We do not control these sites and we encourage you to read their privacy notices.
What data do we collect, use, and share? (summary)
This policy applies to the VroomPulse websites, domains, applications, services, and products.
This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through (non-VroomPulse) links that we may provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any Personal Data that you provide to these websites will be governed by the third-party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.
This section constitutes our notice at collection pursuant to the CCPA. During at least the past 12 months, we have disclosed personal data for the following business or commercial purposes:
Categories | Such as |
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Personal Identifiers | products or services you purchased, obtained or considered, or other purchasing or consuming histories or tendencies. |
Protected Classification Characteristics | age, race, ancestry, national origin, citizenship, marital status, and sex, all of which are considered sensitive personal information. |
Commercial Information | browsing history, search history, and information regarding a consumer’s interaction with an Internet website application, or advertisement. |
Internet or Network Activity Information | browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. |
Geolocation Information | data that is derived from your device by using satellite or cell phone tower signals to locate you within a geographic area. Precise geolocation data is equal to or less than the area of a circle with a radius of 1,850 feet and is considered sensitive personal information. |
Inferences | data above which could create a profile reflecting your preferences, characteristics, predispositions, behavior, abilities, and aptitudes. |
Purpose for Collecting Personal Information (depending on the nature of your interactions with us) |
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Providing our Services and carrying out your requests. When providing our Services we may use your data (as applicable): To register and secure your account. To receive and respond to calls and messages from you. To check your identity and eligibility for our Services. To help you get the best pricing and products we have. To direct you to the websites of our partners. To process transactions between you and us, or our partners. To personalize the Service you get. To keep your data up to date. To provide customer service and support. To complete data rights requests you have made. To enable you to use social sharing tools. To track sales and get paid by our partners. To allow you to use our Services on one device and pick up seamlessly where you left off on another device. |
Improving and promoting our Services and those of others. To help improve and promote our Services, and the Services of our partners, we may use your data: To carry out analysis and market research. To help present our Services clearly and most effectively. To run sweepstakes and surveys. To help us and our partners create better products for you. To process any rewards we may offer to you. To send updates and Service messages about your products and services. To let you know about our services and promotions by email, social media (e.g., Facebook), and using push notifications (where you agree). To build, train, and augment models that help us understand your likely interests and those of other consumers. To target advertising to you, on this and other websites, based on data we have collected or created. To provide location-based offers based on your device’s physical location (where you agree). To help us understand if and how our and others’ marketing works. Please note: We do not use profiling in a way that could have legal or similar effects. |
Operating our business. In the course of running our business we may use your data: To conduct tasks necessary for running our Services and business. To help secure our business and prevent fraud. To create reports for internal or external purposes. To comply with legitimate legal requests. To audit our business and processes. To protect the interests of our business, and those of our partners. For other purposes not described in this Privacy Policy that you consent to (from time to time) and as otherwise permitted by law. |
Other disclosures: We may share your personal data with your consent or to comply with laws or other legal processes.
Data Retention: We keep your data for as long as we need to in order to provide you with Services and to comply with our business and legal obligations. To work out how long we need to keep your data, we consider the amount of data, the type of data, the risks that unintended use or disclosure could bring, and whether we can do what we need to by using less data, and other legal reasons. When we no longer need your data for our stated purposes, we securely delete it.
What data do we collect?
When you use our Services, we collect and use data.
We collect this data in four main ways:
- You give us data when using our Services (such as your name or email).
- Data is collected automatically as you use our Services (such as your IP address).
- We obtain data from other parties to help run our Services.
- We use or combine the data we get to infer things about you (such as, what appears to interest you).
We collect the data needed for our legitimate purposes.
How do we use your data?
We use your data to serve you and operate our business.
Depending on the Services you use and the choices you make, we will use your data to:
- Provide our Services and carry out your requests.
- Improve and promote the Services of us and others.
- Operate and secure our business.
Providing our Service and carrying out your requests.
When providing our Services we may use your data (as applicable):
- To register and secure your account.
- To receive and respond to calls and messages from you.
- To check your identity and eligibility for our Services.
- To help you get the best pricing and products we have.
- To direct you to the websites of our partners.
- To process transactions between you and us, or our partners.
- To personalize the Service you get.
- To keep your data updated with the best information we have.
- To provide customer service and support.
- To complete data rights requests you have made.
- To enable you to use social sharing tools.
- To track sales and get paid by our partners.
Improving and promoting the Services of us and others.
To help improve and promote our Services, and the Services of our partners, we may use your data:
- To carry out analysis and market research.
- To help present our Services clearly and in the most effective way.
- To run sweepstakes and surveys.
- To help us and our partners create better products for you.
- To process any rewards we may offer to you.
- To send updates and Service messages about your products and services.
- To let you know about our services and promotions by email, social media (e.g., Facebook), and using push notifications (where you agree).
- To build, train, and augment models that help us understand your likely interests and those of other consumers.
- To target advertising to you, on this and other websites, based on data we have collected or created.
- To help us understand if and how our and others’ marketing works.
Please note: We do not use profiling in a way that could have legal or similar effects.
Operating our business.
In the course of running our business we may use your data:
- To conduct tasks necessary for running our Services and business.
- To help secure our business and prevent fraud.
- To create reports for internal or external purposes.
- To comply with legitimate legal requests.
- To audit our business and processes.
- To protect the interests of our business, and those of our partners.
For other purposes not described in this Privacy Policy that you consent to (from time to time) and as otherwise permitted by law.
Device and Usage Data
When you visit a VroomPulse website, we automatically collect and store information about your visit using browser cookies (files that are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.
Data we collect from third parties
We may receive your Personal Data from third parties such as companies subscribing to VroomPulse services, partners, and other sources. This Personal Data is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Data. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at VroomPulse (contact details below).
Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.
Purpose and Legal Basis for the Processing of Personal Data
We collect and use your Personal Data with your consent to provide, maintain, and develop our products and services and understand how to improve them.
Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. Consent will be required to initiate services with you. New consent will be required if any changes are made to the type of data collected. Within our contract, if you fail to provide consent, some services may not be available to you.
International Data Transfer and Storage
Where possible, we store and process data on servers within the general geographical region where you reside (note: this may not be within the country in which you reside). Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those in your jurisdiction. We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy as well as applicable data protection law. More information about these clauses can be found here: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914
Sharing and Disclosure
We will share your Personal Data with third parties only in the ways set out in this Policy or set out at the point when the Personal Data is collected.
Legal Requirement
We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.
Service Providers and Other Third Parties
We may use a third party service provider, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services. For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section below.
Cookies
What are Cookies?
A cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site in addition to potential partners and third parties to that business. The collection of this information may be used in the function of the site and/or to improve your experience.
How we use cookies
Our Policy: Cookie Policy
- To give you the best experience possible, we use the following types of cookies:
- Strictly Necessary. As a web application, we require certain necessary cookies to run our service.
- Preference.
- We use preference cookies to help us remember the way you like to use our service.
- Some cookies are used to personalize content and present you with a tailored experience. For example, location could be used to give you services and offers in your area.
When do we share data with others?
To offer our Services and run our business, we must share some data.
We may share data with third parties to provide our Services. For example, with the partners whose products you have selected.
We may share data with third parties whose services we use to run our business. For example, we pay for a third party to host our databases for us.
We may share data with third parties to comply with the law and defend our interests, and those of our partners. For example, we share data with lawyers, external advisors, and other professionals.
Social features
Some of our Services let you use “Social Features” that are offered by third parties. For example, you may be able to ‘like’ or ‘share’ things on Facebook / Instagram, Google / YouTube, Linked In, Snapchat, TikTok, and Twitter. To use these features you may need to have an account with the provider, and you should make sure you understand their privacy practices.
If you choose to use Social Features on our Services or access our Services from Social Features, both we and the provider may have access to data about your use. If you are logged in to a provider’s services, they may be able to connect your visit with other personal data they hold about you. We (and others) may use this data to place ads based on your interests on these providers’ services. In addition, we may ask you if we can access and collect data from your accounts, and post content to your contacts for you.
When you link a Social Feature provider with an account for one of our Services, you grant us access to certain data about you to provide content and services. This access is governed by the privacy policy and choices you make with that provider.
Why we can use your data
To collect and use your data, we must have a valid reason.
These reasons vary based on what we are doing but they will normally be because:
- you have given us your consent to use your data.
- we need to fulfill a contract we have with you or take steps toward forming a contract,
- it is our legal duty to use your data in certain ways, or
- using your data for certain reasons is legitimate.
We need to have good reasons to collect and use your data. Our key reasons are:
Contract: We use your data when we have an agreement with you, or when we need to do things before making an agreement.
Consent: You give us your consent to use your data in certain ways (you can change your mind later if you want).
Legal requirement: We (or another company) must use your data to follow the laws or regulations to which we are subject.
Other legitimate purposes: We have good reasons to use your data to better serve you, to help us make our services better, or to keep our business running well. Some examples include:
- Sharing data with our partners as part of our Services.
- Sharing data with partners who help us offer rewards and benefits.
- Sending you emails of your results when you use our Services.
- Getting in touch to let you know about our Services, and changes to them.
- Doing research to learn more about what people like (or don’t like) about our Services.
- Checking and improving our processes to make sure everything is done right.
- Keeping our services safe and available online.
- Stopping fraud to protect you and others.
Sometimes, we might use your data if we think it will help protect an individual (either you or another consumer)
How long do we keep your data?
We keep your data for as long as it is needed to provide you with our Services.
To determine how long we need to keep your data, we consider:
- the amount of data,
- the type of data,
- the risks that unintended use or disclosure could bring, and
- whether we can do what we need to by using less data.
In addition, we may also keep and use your data for as long as it is needed for legal or contractual reasons, dispute resolution, fraud prevention, and security.
We keep your data for as long as we need it to offer our Services to you, and for other valid business reasons, such as:
- Financial record-keeping
- Complying with the law or other regulatory requirements
- Ensuring the security and availability of our Services
When we decide how long to keep your data, we think about how much we have, what kind of data it is, the risks that unintended use or disclosure could bring, and what the law says. This means we may keep some of your data for longer than we hold other data. Of course, you have choices too – you may request that we delete or correct your data.
At any time, we may make your data anonymous, which means it can’t be linked with you.
When we no longer need to keep data for our purposes, or when we get a valid request to delete, we begin a process to safely delete the data from our systems.
Retention & Deletion
We take the protection of your data very seriously.
We use best practices to help keep your data safe. However, there is always some risk when storing data or sending it over the internet. As such, we cannot guarantee the security of your data, and you should know that sharing it is done at your own risk.
To the extent we store and use de-identified data, we will not attempt to reidentify the data unless permitted by law.
We work hard to keep your data safe and secure. We use tools and techniques to monitor and protect the data we collect and use about you. We also have rules in place to make sure that your data can only be used by those who have valid business reasons, such as providing our Services to you.
While we work hard to protect your data, it’s important to know that no method of sending data online or storing it is perfect. Sometimes things can happen beyond our control. If we ever need to tell you about a problem with your data, we will let you know as best we can using messages, letters, or phone calls.
If you create an account on our websites, you may need to create a password. It’s really important to keep this password to yourself and not share it with anyone. You are responsible for making sure nobody else can access your account using your password or device. If you ever think someone else might be using your account, please tell us right away so we can help.
How can you control your data?
You can make certain choices about the way we collect, use, store, and share your data.
Sometimes these choices apply to everyone who uses a Service (for example, anyone who gets a newsletter from us can opt out of future emails); other times these choices only apply to those covered by a certain privacy law. We manage all of the requests raised to us as the law requires. This means there may be legal reasons why we cannot complete all requests.
Please note: we may need proof of your identity before we can start your request.
To make these choices you should use the links to the forms below to submit a request.
See below for more details.
Your data choices
You have choices about your data and how we communicate with you, using our online form here
- Access to your data: You can request access to the data we have about you, and we will honor valid requests.
- Changes to your data: It’s important to keep your data accurate and up to date. If you need to update your data, please let us know. Sometimes, we have to keep data for legal reasons, but we will try to update it.
- Deleting your data: You can request that we delete the data we have about you. Sometimes we have to keep your data for specific reasons, like following the law or resolving problems, but we’ll delete what we must.
- Objecting to certain uses: If there’s something you don’t like about how we use your data, please tell us. We’ll listen and see if we can make changes. For example, you can opt out of targeted advertising by using our cookie controls, and if you’re in California, you can tell us Do Not Sell or Share My Personal Information with other companies.
- Withdrawing your consent: If you change your mind and want to withdraw your consent for things you previously agreed to, you can tell us. Just remember that, if you do that, we might not be able to provide some Services to you.
If you choose to submit a request to us, it may limit your ability to use some of our Services (e.g., if we have deleted the data used to provide the Service), but we will not alter how we provide our Services to you.
To protect your data, we need to make sure it’s you making these requests. So, we often ask for some information to verify your identity. Once you submit a request to us, we will email you with a link to our identity verification service.
If you want to make any of these choices but prefer not to use our online form, you can contact us by email or mail, using the details below.
- Email: contact@vroompulse.com
We recognize the Global Privacy Control preference signals so you can make your own privacy choices.
Authorized agents: If someone else, like the parent or guardian of individuals aged 16 to 18, needs to make these choices for you, they can do it too. They just need to follow the same steps we mentioned.
If you submit a request and we can’t honor it, we’ll tell you why. We will also make an appeal form available to you if you are not satisfied with our decision.
Communication preferences
You can also choose how we communicate with you. Here are your options:
- Promotional Emails: If you don’t want to receive emails with special offers or surveys, you can unsubscribe by following the instructions in the emails. But don’t worry, we may still send you important messages about our Services.
- Promotional Mailings: If you don’t want to receive physical mail from us, like offers or catalogs, just let us know. Send us an email with “NO SNAIL MAIL” in the subject line, along with your name, address, and zip code. Even if you ask us to stop, you might still get some mailings that were already on their way before we removed your name.
- Text Messages and Push Notifications: If you receive text messages with promotions from us, you can opt out by replying with “STOP” or “UNSUBSCRIBE.” You can also control push notifications on your device.
Please note: We may still need to communicate with you for transactional or Service reasons. For example, sending a password reset email or updates to our terms.
Region and Service-specific notices
Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights may include:
- Right to Access (PIPEDA, GDPR Article 15, CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA, LGPD, POPIA)You have the right to learn whether we are processing your Personal Data and to request a copy of the Personal Data we are processing about you.
- Right to Rectification (PIPEDA, GDPR Article 16, CPRA, CPA, VCDPA, CTDPA, LGPD, POPIA)You have the right to have incomplete or inaccurate Personal Data that we process about you rectified.
- Right to be Forgotten (right to erasure) (GDPR Article 17, CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA, LGPD, POPIA)You have the right to request that we delete Personal Data that we process about you, unless we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Right to Restriction of Processing (GDPR Article 18, LGPD)You have the right to restrict our processing of your Personal Data under certain circumstances. In this case, we will not process your Data for any purpose other than storing it.
- Right to Portability (PIPEDA, GDPR Article 20, LGPD)You have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to transmit such Personal Data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you or the third party that subscribes to services.
- Right to Opt Out (CPRA, CPA, VCDPA, CTDPA, UCPA)You have the right to opt out of the processing of your Personal Data for purposes of: (1) Targeted advertising; (2) The sale of Personal Data; and/or (3) Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Under CPRA, you have the right to opt out of the sharing of your Personal Data to third parties and our use and disclosure of your Sensitive Personal Data to uses necessary to provide the products and services reasonably expected by you.
- Right to Objection (GDPR Article 21, LGPD, POPIA)Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for processing that override your interests and rights, or if we need to continue to process the Personal Data for the establishment, exercise, or defense of a legal claim.
- Nondiscrimination and nonretaliation (CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA)You have the right not to be denied service or have an altered experience for exercising your rights.
- File an Appeal (CPA, VCDPA, CTDPA)You have the right to file an appeal based on our response to you exercising any of these rights. In the event you disagree with how we resolved the appeal, you have the right to contact the attorney general located here:
If you are based in Colorado, please visit this website to file a complaint.
If you are based in Virginia, please visit this website to file a complaint.
If you are based in Connecticut, please visit this website to file a complaint. - File a Complaint (GDPR Article 77, LGPD, POPIA)You have the right to bring a claim before their competent data protection authority.If you are based in the EEA, please visit this website (http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061) for a list of local data protection authorities.
Withdrawing Consent
If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, such as when you wish to opt-out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us using the information found at the bottom of this page.
How to Exercise Your Rights
You can make a request to exercise any of these rights in relation to your Personal Data by sending the request to our privacy team by using the form above.
For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.
Children’s Privacy
We do not knowingly collect Personal Data from children under the age of 16 Years.
Complaints
We would appreciate it if you gave us a chance to address any complaints you may have. You can use the details below to submit a complaint and you may also be able to raise a complaint with your local regulator.
Changes to this Policy
Sometimes we need to make changes to how we collect, use, and protect your data. When we do, we will let you know by updating this policy. If the changes we make are important, we’ll also post a special notice on our website.
Any changes will usually only affect the data we collect after the new policy has been published. Any data we collected before the changes will still be covered by the old policy.
We will also let you know when we last made these changes by publishing the date we last changed it.
Contact Us
For any other request, or ask a question about your data privacy.
contact us, please email contact@vroompulse.com